VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division

TECHNICAL SUPPORT

DOCUMENT

FOR PERMIT

TO CONSTRUCT AND OPERATE #AOP-04-027 DEC#NS94-0007 January 13, 2005 Prepared By: Beth Eliason,

P.E.

APPLICANT:

SOURCE: FiberMark

North America,

Inc. P.O. Box 498Brattleboro, Vermont

05302 Pa perboard

Manufacturing FiberMark North America,

Inc. 161 .Wellington

Road Brattleboro, Vermont

05302 APPLICATION CONTACT:

Brian R. Maloy, Environmental

Engineer Tel. (802) 257-5982 Fax (802) 257-5910FiberMark North America, Inc. Permit # TAOP-04-027 1.0 INTRODUCTION FiberMark,

Inc. (hereinafter

"FiberMark"

and also referred to herein as "Owner/Operator") owns and operates

a paperboard

manufacturing

facility at 161 Wellington Road in Brattleboro,

Vermont

(also referred to herein as "Facility"). The Facility currently

operates

under a combined

construction

and operating permit issuedOctober

4, 2002 (#AOP-95-174).

This permit required

FiberMark to submit a hazardous

most stringent

emission

rate (HMSER)

analysis

for the Hazardous Air Contaminants

("HACs")

benzyl alcohol and formaldehyde. FiberMark submitted

an application

for renewal of their operating

permit on August 5, 2004. This Technical

Support

Document

details the Agency of Natural Resources, Department

of Environmental

Conservation,

Air Pollution

Control Division (hereinafter

"Agency")

review for renewal of the Facility's

combined

Air Pollution Control Permit to Construct

and Operate

and Title V permit modification resulting from incorporation

of the Agency's

HMSER

determination. The allowable

emissions

for the Facility are summarized

below:

2.0 Total

Total. Criteria HAPs 2 32.2 441.5

<100

7.6

<50

>10

<10/25 PM/PMI0 particulate matter and particulate matter of 10 micrometers

in size or smaller; SO2 sulfur dioxide; NO• oxides of nitrogen measured as NO2 equivalent; CO carbon monoxide; VOCs volatile organ=c compounds; HAPs hazardous air pollutants as defined in §112 of the federal Clean Air Act. Emissions of individual HAPs each 10 tpy and emissions of total HAPs combined <25 tpy. Actual total combined HAPs estimated at <1 tpy. FACILITY DESCRIPTION

AND LOCATION 2.1 Facility Locations

and Surrounding

Area FiberMark owns and operates

the paperboard

manufacturing

facility located at 161 Wellington

Road in Brattleboro,

Vermont.

The area surrounding

the Facility is primarily

industrial

and commercial

with neighbors

such as The Book Press, Fuller, and C&S Wholesale

Warehouse.

The Facility is located greater than 100 kilometers from the Great Gulf and Dry River Wilderness

areas =n New Hampshire and within 100 kilometer

of the Lye Brook Wilderness

Area in Manchester, Vermont.

The Facility location and layout are depicted

in Appendix A of this TechnicalAnalysis. 2.2 Facility Description The Facility is isted under the Standard

Industrial

Classification

("SIC") Code 2631 Paperboard

Mills. The regulated

sources of air contaminant

emissions

at the Facility are the paper making processes,

two (2) No. 6 fuel oil-fired Bigelow boilers rated at 38 million British Thermal

Units per hour ("MMBTU/hr")

each of heat input, and a temporary

No. 2fuel oil-fired supplemental

boiler (hereinafter "supplemental boiler") rated at less than 15 MMBTU/hr

of heat input. Specifications for emission

sources are presented

in Table 2-1.FiberMark North America, Inc. Permit # TAOP-04-027

Two (2) Bigelow boilers Cleaver Brooks Model 200-350 water tube boiler (rental)

38.2 (each)MMBTU/hr

No. 6

14.8 No. 2 Three (3) Safety-Kleen

Model 16 parts cleaner na One (1) Safety-Kleen

Model 81 •arts cleanerPaper Coating Line #1

na Paper Coating Line #2

na Two (2) Fuel Storage tanks

25,000 gallon 1960

1997

na unknown

na unknown

na

naNo, 6(2% sulfur) Mite/hr Million British Thermal Units per hour maxim L•m rated heal input. na not applicable 1988-1985
1989

Boilers The Boiler Room at the FiberMark

facility contains

two boilers.

A third skid- mounted

boiler is located outside the Boiler Room and feeds steam inside the boiler room to provide supplemental

steam. The two boilers located in the boiler room are identical

water tube boilers installed,

in 1960 and fire No. 6 fuel oil. The two boilers, manufactured

by The Bigelow Company,

are each equipped with one Model HT66 oil burner manufactured

by Cone Company.

Each Bigelow boiler has a heat input rating of 38.2 MMBTU/hr

1. No. 6 fuel oil for the Bigelow

boilers is delivered

and stored in two underground storage tanks located outside the southeastern

end of the facility building.

Each underground storage

tank has a capacity

of 25,000 gallons.

A fuel additive, Chemtreat BL-1544,

is added to the fuel in the underground

storage tanks at time of fuel delivery.

The fuel oil is piped to the boiler room and preheated

to a temperature of 210 ° F. A portion of the fuel oil piped to the boiler room is circulated back to the fuel storage tanks to keep the No. 6 fuel oil viscous •n the storage tanks.
There is a discrepancy

between

the heat input rating of 38.2 MMBTU/hr

noted in the application, and the information

which resides in the Agency's

files and registration inventory. The Agency's

files list a heat input of 37.5 MMBTU/hr

for each unit, while the registration inventory

lists 30 MMBTU/hr

of heat input. For the purposes

of thisTechnical Analysis, the Agency has utilized the heat input indicated

in the operating

permit application.FiberMark North America, Inc. Permit # TAOP-04-027
Each Bigelow

boiler generates

approximately

35,000 pounds per hour of steam at a pressure

of 230 psig to the Facility.

Approximately

ten (10) percent of the steam is utilized for space heating,

while the remaining

ninety (90) percent

is utilized in the manufacturing

of paperboard.

Process

steam is employed

by the paper machine

and coating dryers. As stated previously,

FiberMark

has installed

a third boiler to supplement

the steam production

at the Facility during the higher heat demand

months

(i.e., winter). This unit is located outside the boiler: room and is skid mounted.

This unit is a rental boiler and was first installed

in 1997. The heat input rating for the boiler is restricted

to less than 15 MMBTU/hr.

The supplemental

boiler only fires No. 2 fuel oil. Historically,

this unit has been identified

as a Cleaver

Brooks Model 200-350

water tube boiler. Fuel oil for this boiler is stored in an above ground portable

storage tank located in the spill containment

area next to the boiler room. No fuel additives

are added tothe No. 2 fuel oil. Paper Production

and Coatinq-

Raw materials,

including

recyclable

paper and treatment chemicals,

are conveyed

to the Facility and stored in the Materials Storage Area. Paper is transferred

to a pulperand

then pumped

as a slurry through piping (located

under the floor) to the Stock Prep area. The paper is mixed and cleaned

in the Stock Prep area. Cleaning

involves

the physical separation of impurities

(e.g., envelope

windows,

rubber bans, paper clips, etc.). Dyes for the paper, if necessary,

are added at this point.

Boil-out

and neutralization chemicals

may also be added here for cleaning

purposes. The cleaned

paper slurry exits the Stock Prep area and is pumped

to the "wet end" of the I•aper machine

(identified

as Paper Machine

No. by FiberMark). The. paper is formed and pressed

into a thin, continuous,

and cohesive

sheet of paper. Boil-out and neutralization

chemicals

may be added here as well as felt washes. The sheet of paper is conveyed

through steam heated dryers to remove moisture. The dried paper is passed, through

calendars

which impart physical properties to the paper. The continuous

sheet of paper is then wound into a roll at the "Winder." The roll of paper is either transported

to the "Converting"

area, the "Shipping" area, or to one of two coating lines. Converting Area The Converting

Area includes

cutting, slitting, winding,

and packaging of the paper. The paper is packaged

in stretch wrap and is loaded onto trucks for subsequent

.distribution. Coating Lines

FiberMark

employs

two coating

lines..Coating

Line No. 1 (installed in 1988) consists

of a roll coater that applies acrylic-based

coatings. The applied coating is then dried using a steam heat dryer. Coating

Line No. 2 (installed in 1985) utilizes a roll coater or rod:_coater

to apply the acrylic-based coatings. Applied coatings

on Coating

Line No..2 are also dried using a steam heated dryer. Each coating line uses similar steps to process

paper. The roll of paper exitingFiberMark North America, Inc. Permit # TAOP-04-027 the paper machine

is unwound

and passes through the coater which then applies an acrylic-based

film to the surfaces

of the paper sheeting.

The paper then passes through

an air flotation

dryer and to an "embosser"

which imprints

and forms the paper sheeting

into the desired format.

The paper sheeting

is finally rewound at the end of the coating line. The acrylic-based

film is mixed in batches

of 60 gallons and consists

of equal parts, of Rhoplex

HA•12 Dispersant

and Tamol 165A Dispersant

and transferred to the coating line. Dyes may also be mixed in with the coating film. Parts Cleaninq

FiberMark

utilizes four (4) Safety-Kleen

Parts Cleaning

Systems (Three Model #16 cleaners

and one Model #81 cleaner)

for cleaning

various machine parts [referred

to as cold cleaning

in the Regulations

see {}5- 253.14(b)]. The units are serviced

by Safety Kleen every twelve (12) weeks. 2.3 Description

of Existing

Air Pollution

Control Equipment This Facility is not equipped

with air pollution

control equipment. 2.4 Description

of Compliance

Monitoring

Devices This Facility is not equipped

with devices to continuously

monitor the emission

of air contaminants

to the ambient

air. 2.5 Proposed

Modifications

to Facility No modifications

have been proposed

for the Facility as part of the current permit renewal.2.6 Proposed

Limitations The Facility presently

operates

under the limitations

imposed

by a Permit to Construct and Operate

#AOP-95-174.

Additional

limitations

were developed

in order to implement

the HMSER

determination

for formaldehyde.

Below are summarized the primary limitations

on the operation

of this Facility and contained in the current permit:No. 2 fuel oil sulfur content restricted

to 0.5 percent by weight or less, and annual No. 2 fuel oil usage in the supplemental

boiler is limited to 280,000

gallons per year 2. Annual emissions

of formaldehyde

shall not exceed 65 pounds per year. 3Annual emissions

of NOx from the Facility Shall not exceed 100 tons per year. 4

2 The cap of 280,000 gallons per year on the use of No. 2 fuel oil in the supplemental boiler was imposed in Permit to Construct

#AP-97-022b,

issued on April 29, 1998. This cap was deleted from the Permit to Construct

and Operate #AOP-95-174,

issued on October 4, 2002, in error. The fuel cap of 280,000 gallons per year did not result in emissions of greater than 10 tons per year of any one pollutant,

nor did the 80,000 gallon increase exceed 10 tons per year of all pollutants

combined,

as a result the Facility was not subject to modeling

requirements

prior to installation

of the supplemental

boiler. 3 Hazardous

Most Stringent

Emission

Rate determin ation, 2004. 4 Emission

cap implemented

to avoid NO, RACT.FiberMark North America, Inc. F•ermit # TAOP-04-027 2.7 Identification

of Insignificant

and Exempt Activities Activities which qualify as an "insignificant

activity" pursuant

to {}5-1002(h)

of the Regulations need not be considered

when determining

the applicability

of Subchapter X of the Regulations

and must only be listed as such within the operating permit application.

Additionally,

guidance

provided

by the U.S. EPA (entitled "White Paper for Streamlined

Development

of Part 70 Permit Applications") lists activities

which are considered

as "trivial" sources

of air contaminants, and may be presumptively

omitted

from operating

permit applications.Although not required

for determining

applicability

with Subchapter

X, quantifiable emissions

from "insignificant

activities"

must be included

for the purposes of establishing

whether

or not a source is subject to other air pollution control requirements,

including,

but not imited to: reasonably

available

control technology, major source status, and Title V operating

permit applicability. In its application,

FiberMark

has not identified

any equipment

or activities

as insignificant or trivial. However,

the Agency is aware of the following

activities

or equipment at the Facility:

2.3.4. Forklifts;Repair and maintenance

shop activities; Soldering and welding equipment; Ventilating units used for human comfort; Fuel oil and propane

storage tanks [No. 6 oil (2) 25,000 gallon storage capacity (installed

post 1984) Chemical storage tanks (<10,000

gallon storage capacity

each); Paper testing laboratory;

and Intermittent construction

activities. Emissions were not quantified

from the above insignificant

activities

because they are considered

negligible

or not quantifiable.

The exclusion

of emissions producedby the insignificant

and trivial activities

does not alter the applicability status of the Facility under Subchapter

X of the Regulations. 3.0 QUANTIFICATION

OF POLLUTANTS The quantification

of emissions

from a stationary

source is necessary

in order to establish the regulatory

review process necessary

for the operating

permit application and to determine

applicability

with •/arious air pollution

control requirements.

These determinations are normally

based upon allowable

emissions.

Allowable

emission

is defined as the emission

rate calculated

using the maximum

rated capacity of the source and, if applicable,

either: (a) the applicable

emission

standard

contained

in the Regulations, if any, or (b) the emission

rate or design, operational

or equipment

standard specified in any order or agreement

issued under the Regulations

that is state and federally enforceable.

An applicant

may impose in its application

an emission

rate or design, or an operational

or equipment

limitation

which may be incorporated

in the Permit to restrict operation

to a lower level. Such limitations

may include fuel restrictions or production

limits.FiberMark North America. Inc. Permit # TAOP-04-027 3.1 Designation

of the Facility for the Permit to Operate The designation

of the Facility for the Permit to Operate

is determined

by its allowable emissions

following

issuance

of the permit, taking into account

any limitations contained

in the permit that restrict the Facility's

allowable

emissions. The proposed

Facility has annual allowable

emissions

greater then 10 tpy. The air contaminant sources at the Facility are presented

in Table 2-1. The calculated allowable emissions

for each source are detailed

in Table 3-1, Table 3-2, and Table 3-3. An emissions

summary

is presented

in Table 3-4. Emissions from Boilers

To estimate

emissions

from the boilers, the Agency used emission

factors published

by the U.S. EPA in the Compilation

of Air Pollutant Emission

Factors,

Volume I: Stationary

Point and Area Sources

(5th Edition including

Supplements);

estimated

fuel consumption

in the two Bigelow boilers, and the annual fuel cap-imposed

on the supplemental

boiler. The boilers are the only sources

of NOx at this Facility and are therefore

the only. emission units affected

by the 100 tpy emission

cap. As stated previously,

the Agency has limited NO× emissions

from the Facility to less than 100 tpy. The Agency has included

monitoring,

record keeping,

and reporting

requirements

in the Permit to assure compliance

with this emission

cap. The supplemental

boiler is subject to a fuel cap of 280,000

gallons of No. 2 fuel oil•. This emission

cap was approved

by the Agency

in the Permit to Construct #AP-97-022b issued on April 29, 1998, and was imposed

in order to keep emissions from the boiler below modeling

thresholds. Although a fuel cap has not been imposed

on the fuel burned in the Bigelow boilers, 2,749,000

gallons of No. 6 fuel oil was used to estimate

annual emissions from the boilers. This is the estimated

quantity of No. 6 fuel that could be burned in the Bigelow boilers without exceeding

the NOx emissions

cap. Emissions from Paper Makin.q and Paper Coatin.q

FiberMark

currently

submits annual VOC emission

inventories

in accordance

with Subchapter

VIII of the Regulations. The inventories

detail the emissions

produced

by the paper coating operations, the board machine,

and the cold cleaners.

For paper coatings, FiberMark calculates

the VOC emission

rates assuming

that 100% of each volatile constituent

is emitted to the atmosphere.

For board machine

emissions, FiberMark relies on guidance

published

in the Federal Register

(Vol. 63, No. 72, p. 18526) to assume

that only 20% of each VOC constituent

is emitted to the atmosphere. For cold cleaning

units, FiberMark

uses a mass balance

(based on manifest data) to assume

that 25% of the solvent is emitted to the atmosphere. FiberMark uses Material

Safety Data Sheets to determine

the composition

of each chemical

product

and usage records

to determine

the amount

of each product used at the Facility.

The Agency

also assumes

that 100% of the fuel treatment is emitted as VOC. The emission

inventories

indicate

that the Facility emitted

11.5 tons of VOC in the year 2002 and 11.3 tons of VOC in the year 2003. The Agency assumes

that the average

of the VOC emission

rates from the previous

two years is representative of expected

actual emissions.

Based on the emission

inventories.,FiberMark North America, Inc. Permit # TAOP-04-027 the average

actual VOC emissions

are 11.4 tons per year. Using a multiplying

factor, the Agency

scales actual emissions

to represent

the allowable emissions.

The Agency examines

operating

schedule

and production capacity to develop

the scaling factor. First, based on the information

listed in the application,

the Agency

assumes

that FiberMark

operates

8,760 hours per year. Second, the Agency assumes

that the Facility operates

at 50% production capacity. Based on these assumptions,

the Agency

has concluded

that a multiplying factor of 2 is appropriate

to calculate

allowable

emissions.

Therefore, the Agency

estimates

the allowable

VOC emissions

from the paper making and coating operations

to be 22.8 tons per year.FiberMark North America, Inc. Permit # TAOP-04-027

PM/PM10SO2NOx 5CONMTOC(VOCs)

HAPs

23.131472.74

0.76

0.15

63,501.9863,186.0199,962.313,745.0
2089.2

412.4

31.8431.6100.06.91.0

0.2

AP-42, Fuel Oil. Combustion, Tables 1.3-1 and 1.3-2, No. 6oilfired. 10-96AP-42, Fuel Oil Combustion, Tables 1.3-3, 10- 96AP-42, Fuel Oil Combustion, Tables 1.3-9 and 1.3-11, 10-96

Estimatedannual fuel usage of2,749,000gallons No. 6 fuel oil, 2% sulfur.

5 The permit requires fuel certifications

to state Nitrogen content of the No. 6 fuel oil. In the event that a fuel supplier does not state the nitrogen content of a specific delivery of No. 6 fuel oil, the Permittee shall assume that the No. 6 fuel oil contains 0.5% nitrogen,

by weight. This value is a conservative estimate of [he Nitrogen content of No. 6 fuel oil, as determined

from a review of current (2000-2004)

fuel certifications

from regional fuel suppliers.

This value should be reevaluated upon permit renewal.

The emiss•)n

factor of 72.74 pounds of NOx per 1000 gallons of fuel burned is based on the following

equation

(AP-42 Table 1.3-2): [20.54 + 104.39N]X[2x106 ]

NOx,(tons

)

where: X total monthly No. 6 fuel oil consumption,

in gallons, and N monthly weighted

average nitrogen content of the No. 6 fuel oil (e.g. if fuel contains

0.5% nitrogen by weight, N 0.5).FiberMark North America, nc. Permit # TAOP-04-027

PM/PM10SO2 3.271 NOx 20 CO 5 NMTOC 0.34 (vocs)

HAPs 0.04

896.019 880.05,600.011400.0

95.2

11.5

0.459.942.800.70
0.05

0.01

AP-42, Fuel Oil Combustion, Tables 1.3-1 and 1.3-2, distillate fuel. 10-96AP-42, Fuel Oil Combustion, Tables 1.3-3, 10- 96AP-42, Fuel Oil Combustion, Tables 1.3-9 and 1.3-11, 10-96

Annual fuel cap of280,000gallons No. 2 fuel oil,0.5% sulfur.

Summarized in Table 3-3 below are the future allowable

emissions

for the Facility.

•_ 32.2

441.5

7:6

.... <100

1.1

0.2 Paper •'•king and Coating 22.8

<0.01 Total: 32.2

441.5

7.6 <100

23.9

0.2 Given that emission factors used to calculate em ssions from the supplemental

boiler burning No. 2 fuel oil are smaller then emission factors for the two Bigelow boilers firing No. 6 fuel oil, maximum allowable emissions

from the Facility boilers were calculated

assuming that the two Bigelow boilers consumed 2,749,000

gallons per.year of No. 6 fuel, and that the supplemental

boiler was not used. 3,2 Designation

of Existing

Stationary

Source for the Permit to Construct No modifications

were proposed

as part of the permit renewal application. 4.0 APPLICABLE

REQUIREMENTS The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions regarding the compliance

status contained

herein are not binding against the state of Vermont in any future legal or administrative

proceedings.

The Agency will assess compliance with these standards

during any inspections

of the Facility.

The inspectionsFiberMa rk North America, Inc. Permit # TAOP-04-027 will include confirmation

of the proper operation

and. maintenance

of equipment,

visual observation of emission

points, and review of written records required

in the permit. 4.1 Vermont

Air Pollution

Control

Regulations

and Statutes §5-201 and §5-202

Open Burning

Prohibited

and Permissible Opening Burning Open burning of materials

is prohibited

except in conformance

with the requirements of this section.

Based on the application

submittal

and information available

to the Agency,

the Facility is in compliance

with this requirement.§5-211(1) Prohibition

of Visible Air Contaminants.

Installations constructed prior to April 30, 1970 This standard

applies to the Bigelow boilers.

FiberMark

has stated-that

it complies with the standard

based on their equipment

maintenance. To assure compliance

with the particulate

standard

the Agency

has included periodic

monitoring

and reporting

requirements

for the Bigelow boilers in the Permit.

FiberMark

must perform

monthly

testing to determine the CO and either CO2 or 02 concentrations

in the exhaust gas streams of the Bigelow

boilers.

With these measurements,

FiberMark must then compute

boiler efficiency

and make any operational

or maintenance-related changes

to assure that the boilers are running

at peak efficiency.

FiberMark

is also required

to file semi-annual

reports to the Agency

detailing

the results of the boiler efficiency

testing and any corrective measures

taken. §5-211(2) Prohibition

of Visible Air Contaminants.

Installations constructed subsequent

to April 30, 1970 This standard

applies to the supplemental

No. 2 oil-fired boiler and the paper making equipment.

FiberMark

has stated that it complies

with the standard based on their equipment

maintenance. Due to the clean burning

nature of No. 2 oil, the Agency

expects

this boiler to comply with the visible emission

standard.

For this reason, the Agency has concluded

that it is unnecessary

to apply periodic

monitoring requirements to this boiler to assure compliance

with the visible emission standard. Given the nature of operations,

the paper making process

is expected to produce

negligible

visible emissions. §5-221(1). Prohibition

of Potentially

Polluting

Materials

in Fuel; Sulfur Limitation

in Fuel This subsection

prohibits

the use of any fuel, in stationary

fuel burning equipment, with a sulfur content

more than 2.0% by weight.

This prohibition applies to all stationary

fuel burning equipment

used on-site. Compliance with this standard

is based on fuel analyses

following

the procedures prescribed

by the American

Society for Testing and Materials. FiberMark has stated that it complies

with this standard

based on theirFiberMark North America, Inc. Permit # TAOP-04-027 contract with fuel suppliers. To provide a reasonable

assurance

of compliance

with this standard,

the Agency has included

periodic

monitoring

and reporting

requirements

in the Permit. The Permittee

is required

to obtain fuel supplier

certifications detailing the sulfur content of fuel oil delivered

to the Facility, and submit semi-annual reports containing

the fuel supplier certifications. §5-231(3)(a).- Prohibition

of Particulate

Matter; Combustion Contaminants Based on the application

submitted

and information

available

to the Agency, this Facility currently

has fuel burning equipment

subject to this regulation. The allowable

emissions

of particulate

matter from the subject equipment are shown in Table 4-1.

• .--• kTabie 4:1if.Equipment

Subjectto

§5'231(3)(a) Equipment IDBigelow Boiler #1 Size 38.2 MMBTU/hr

EmissionStandard0.27Ib/MMBTU Bigelow Boiler #2 38.2 MMBTU/hr

0.27Ib/MMBTU Supplemental boiler

<15 MMBTU/hr

0.43Ib/MMBTU

Allowable Emissions 10.3 Ib/hr10.3 Ib/hr6.0 Ib/hr Compliance with the standard

in §5-231(3)(a)(ii)

of the Regulations

•s generally based on the use of Reference

Method

5 (40 CFR Part 60, Appendix A). FiberMark has stated that it complies

with the standard

based on their emission estimates,

and the scheduled

maintenance

of the boilers. The Agency has included

periodic

monitoring

and .reporting

requirements for the Bigelow

boilers in the Permit to assure compliance

with the particulate standard.

The Permittee

must perform

monthly

testing to determine the CO and either CO2 or 02 concentrations

in the exhaust gas streams of the Bigelow

boilers. With these measurements,

the Permittee must then compute

boiler efficiency

and make any operational

or maintenance-related changes

to assure that the boilers are running at peak efficiency.

These requirements

are premised

on a correlation between boiler efficiency

and particulate/visible

emission

rates. The Permittee is also required

to file semi-annual

reports to the Agency detailing the results of the boiler efficiency

testing and any corrective measures taken. Because of the clean burning nature of No. 2 oil, the Agency expects the No. 2 oil-fired

supplemental

boiler (Supplemental

<15 MMBTU/hr)

to comply with the particulate

emission

standard.

For this reason,

the Agency has concluded

that it is unnecessary

to apply periodic

monitoring requirements to the supplemental

boiler.FiberMark North America, Inc. Permit # TAOP-04-027 The Agency

will also assess visible emissions

from the fuel burning equipment during site inspections.

If visible emissions

are observed

to be in excess

of the respective

standard,

the Agency

may require performance of stack testing. §5-231(4) Prohibition

of Particulate

Matter; Fugitive

Particulate MatterThis section requires

the use of fugitive PM control equipment

on all process operations

and the application

of reason able precautions

to prevent PM from becoming

airborne

during the handling,

transportation, and storage of materials,

or use of roads. This requirement

applies to the entire Facility, and the Facility is therefore

expected

to comply with the fugitive emission

limitations

of this section. Based on the application

submittal

and information

available

to the Agency, the Facility currently

is not considered

a source of fugitive particulate matter subject to this regulation.

The Facility is required

to take reasonable

precautions

at all times to control and minimize emissions of fugitive particulate

matter from the operations

at the Facility. The Agency will verify compliance

with this standard

in the future during any inspections

of the Facility.

The inspections

will include confirmation of the proper operation

of any fugitive particulate

matter control measures and visual observations

of any emission

points. §5-241(1) & (2) Prohibition

of Nuisance

and Odor This requirement

applies to the entire Facility and prohibits

the discharge of air contaminants

that would be a nuisance

to the public or the discharge of objectionable

odors beyond the pro 2erty-line

of the Facility. Based on the application

submittal

and information

available

to the Agency, the Facility currently

•s in compliance

with this regulation.

The Agency will verify compliance

with this requirement

in the future during any inspections

of the Facility.

Additionally,

the Agency

investigates

all complaints that it receives

in order to determine

whether

or not there is a violation of this requirement. Section 5-251.3-

Control

of Nitrogen

Oxide Emissions This regulation

applies to stationary

sources

with NOx emissions

greater than 100 tons per year. NOx emissions

have been capped at 100 tons per year and the Facility is not required

to comply with this regulation. §5-253.10. Control

of Volatile

Organic

Compounds

Paper Coating. This section regulates

the release of VOCs from all paper coating units, except units within a paper coating source that have actual emissions without control devices

from all paper coating units within the source of less than fifteen (15) pounds of VOCs per day ("lbs/day").

Once a source becomes subject to this subsection,

it shall remain so even if emission levels subsequently

fall below the applicable

threshold.FiberMark North America, Inc. Permit # TAOP-04-027
Based on the registration

data FiberMark

submitted

for the year 2001, the Agency estimates

that VOC emissions

resulting

from the application

of coatings and dyes totaled 8,745 pounds.

Assuming

that the Facility operates 365 days per year, the Agency

estimates

that the daily VOC emissions from the coating operations

approach

24 pounds

per day. Using this estimate,

the Agency has determined

that FiberMark

is subject to {}5-253.10

of the Regulations. As a subject source, FiberMark

shall notcause,

allow or permit thedailyweighted average

VOC content of paper coatings

applied to exceed 2.9 pounds of VOCs per gallon (excluding

water and exempt compounds). To assure compliance

with this standard,

the Agency

has included monitoring and record keeping requirements

in the Permit. The Permittee is required

to record the amount of each paper coating used monthly,

as well as the density,

the Volatile organic compound

content (expressed

as a weight percentage

and volume

percentage),

and the solids content (expressed as a weight percentage)

of each paper coating.

Additionally, the Permittee

must submit a summary

of the VOC and solids content for each coating used on a semi-annual

basis. §5-253.14 Control

of Volatile

Organic

Compounds

Solvent

Metal Cleaning,This subsection

applies to all cold cleaning

operations,

open-top

vapor degreasing operations

with an open area of 10.8 square feet or greater., and conveyorized

degreasing

operations

with an air/solvent

interface

21.5 square feet or greater.

The cold cleaning

standards

require the units to be designed

and equipped

with a cover easily operated

with one hand if the vapor pressure

of the solvent

exceeds

0.3 psi and an internal drainage.area and additional

control measures

if the vapor pressure

of the solvent exceeds

0.6 psi. All cold cleaning

operations

regardless

of solvent va pot pressure

must: (i)(ii)(iii)(iv)(v)(vi)(vii) Provide a permanent,

legible, conspicuous

label, summarizing

the operating requirements; Store waste solvent in covered

containers; Close the cover whenever

parts are not being handled

in the cleaner;Drain the cleaned

parts until dripping

ceases; Supply a solvent spray, if used, that ensures

a solid fluid stream at a pressure

that does not exceed

10 pounds

per square inch gauge;Degrease only materials

that are neither porous nor absorbent; andCease operation

of the unit upon the detection

of any visible solvent leak until such solvent leak is repaired." That applicant

has stated that the Safety-Kleen

cold cleaning

unit and solvent used at the Facility has a vapor pressure

(0.008 psi) less than theFiberMark North America, Inc. Permit # TAOP-04-027 applicable levels requiring

controls

other than the requirements

of parts (iv) through

(x) above and that the unit is designed

and operated

in accordance with those provisions. The Agency

will assess compliance

with this regulation

in the future during any inspections

of the Facility.

The inspections

will include confirmation of the solvent used and the proper design and operation

of the unit.§5-261 Control

of Hazardous

Air Contaminants See Section 5.0 below. §5-402 Written Reports

When Required This section gives the Agency authority

to require the Facility to submit reports summarizing

records required

to be maintained

by the Agency. §5-403- Circumvention This section prohibits

the dilution or concealment

of an air discharge

in order to avoid air pollution

control requirements.

The Agency will assess compliance with this regulation

in the future during any inspections

of the Facility. 4.2 Federal Air Pollution

Control

Regulations

and the Clean Air Act Clean Air Act, Title Air Pollution

Prevention

and Control,

Part A Air Quality

and Emission

Limitations,

§111

Standards

of Performance for New Statio.nary

Sources.

FiberMark

is subject to one applicable federal

new source performance

standard

("NSPS")

and subject to a record keeping

requirement

in another

NSPS established under §111 of the federal C/ean Air Act and promulgated

within 40 CFR Part 60.40 C.F.R. Part 60 Subpart

Dc Standards

of Performance

for Small Industrial-Commercial.Institutional Steam Generating

Units The supplemental

boiler is considered

an affected

facility subject to 40 CFRPart 60 Subpart

Dc Standards

of Performance

for SmallIndustrialCommercial-Institutional Steam Generating

Units. Subpart

Dc specifies emission limitations

for PM/PM10,

SO2, and opacity, as well as monitoring, record keeping,

notification

and reporting

requirements.

Applicability

of Subpart Dc also subjects

FiberMark

to the general

notification,

record keeping, and other requirements

of 40 CFR Part 60 Subpart A. FiberMark has stated that it. complies

with these requirements. Permit conditions

require FiberMark

to monitor

fuel consumption

in the supplemental boiler, to obtain fuel supplier

certifications

stating the sulfur content of the fuel oil fired in the boiler, and to submit semi-annual

reports detailing these records.

These requirements

provide

a reasonable assurance of compliance

with Subpart Dc.FiberMark North America, Inc. Permit # TAOP-04-027 40 C.F.R. Part 60 Subpart

Kb Standards

of Performance

for Volatile Organic Liquid Storage

Vessels

(Including

Petroleum

Liquid Storage Vessels) for Which Construction,

Reconstruction,

or Modification Commenced after July 23, 1984 "(a)Except as provided

in paragraphs

(b), (c), and (d) of this section, the affected facility to which this Subpart applies is each storage vessel with a capacity greater than or equal to 40 cubic•.meters

(10,562 gallons)

that is used to store volatile

organic

liquids

for which construction, reconstruction, or modification

is commenced

after July 23, 1984." For all storage vessels

with a design capacity

less than 75 m3 (19,084 gallons) the only requirements

of this regulations

is to keep readily accessible records showing

the dimension

of the storage vessel and an analysis showing

the capacity

of the storage vessel.

For storage vessels greater than 75 m 3 (19084 gallons)

and storing a volatile organic liquid with a maximum

true vapor pressure

less than 15.0 kPa (2.18 psi), the only additional

requirement

of the regulation

is notify the EPA Administrator within 30 days when the vapor pressure

exceeds

the respective value. The record keeping

requirements

specified

by Subpart

Kb apply to the two 25,000 gallon storage tanks that FiberMark

uses to store No. 6 fuel oil.Section 112 of the Clean Air Act National

Emission

Standards

for Hazardous Air Pollutants

(NESHAPs). NESHAPs are promulgated

under 40 C.F.R. Part 61 and 63. No NESHAPs currently

apply to the Facility.

Total HAP emissions

are estimated to be less than one (1) tpy. 40 C.F.R. Part 64 Compliance

Assurance

Monitoring Pursuant to requirements

concerning

enhanced

monitoring

and compliance certification

under the Clean Air Act ("CAA"),

EPA promulgated new regulation

on October

22, 1997 and revised regulation on January

12, 2001. These new requirements

implemented

compliance assurance monitoring

("CAM") for major stationary

sources of air pollution that are required

to obtain operating

permits under Title V of the CAA. Subject to certain exemptions,

the new regulations

require owners or operators of such sources to conduct monitoring

that satisfies

particular criteria established

in the rule to provide a reasonable

assurance

of compliance with applicable

requirements

under the CAA. Monitoring

is proposed to focus on emissions

units that rely on pollution

control device equipment to achieve compliance

with the applicable

standards.

The regulations also provide procedures

for coordinating

these requirements with the operating

permits program

regulations. Section 64.2 of 40 C.F.R. specifies

that each pollutant

specific emission unit at a facility that meets a three-part

test is subject to the requirements for CAM. An emission

unit must: (1) be subject to an emission

limit or standard;FiberMark North America, Inc. Permit # TAOP-04-027 (2) use a control device to achieve compliance; (3) have pre-control

emissions

that exceed or are equivalent

to the major source threshold

in 40 CFR Part 70 (i.e., 10 tpy individual HAP, 25 tpy total HAP, 50 tpy VOCs, or 100 tpy for any other air contaminant). Equipment at the Facility that meets the first criteria are the boilers. The Facility does have emissions

of SO2 in excess of major source thresholds. However, none of the equipment

in use at the Facility, including

the boilers, utilizes a control device, and therefore

are not subject to CAM. As none of the equipment

at the Facility meet the three criteria listed above the Facility is currently

not subject to CAM. 4.3 Non-Applicable

Requirements

For Which a Permit Shield Provision Has Been Requested Pursuant to §5-1015(a)(14)

of the Regulations,

an owner/operator

may request to be shielded

from potentially

applicable

state or federal requirements. The Facility has not requested

a permit shield from any specific, potentially

applicable

requirement.

Accordingly,

the Agency has not granted any permit shields for the Facility. 5.0 CONTROL

TECHNOLOGY

REVIEW

FOR MAJOR

SOURCES

AND MAJOR MODIFICATIONS Pursuant to §5-261 of the Regulations

each new major source and major modification must apply control technology

adequate

to achieve the Most Stringent

Emission

Rate ("MSER") with respect to those air contaminants

.for which there would be a major or significant emission

increase,

respectively.

The Facility is not undergoing

changes subject to new source review, therefore

this section is not applicable. 6.0 AMBIENT

AIR QUALITY

IMPACT

EVALUATION An ambient

air quality impact evaluation

is performed

to demonstrate

whether

or not a proposed project will cause or contribute

to violations

of the ambient

air quality standards and/or significantly

deteriorate

existing air quality. The Agency's implementation procedures

concerning

the need for an ambient

air quality impact evaluation under §5-406(1)

of the Regulations,

specifies

that such analyses

may be required when a project results in an allowable

emissions

increase

of ten (10) tons per year or more of any air contaminam,

excluding

VOCs. Additionally,

the Agency may require an air quality impact evaluation

where the short-term

allowable

emission

rates will significantly

increase

as a result of a project. The Facility is not undergoing

changes

subject to new source review, therefore

this section is not applicable. 7.0 HAZARDOUS

AIR CONTAMINANTS The emissions

of hazardous

air contaminants

("HACs")

are regulated

under to §5-261 of the Regulations.

The Owner/Operator

of a source must quantify

its emissions

of HACs regulated by this rule. Any Facility whose emission

rate of a HAC exceeds

its respective Action Level ("AL") is subject to the rule for the HAC, and the Owner/Operator

must then demonstrate that the emissions

of the HAC are minimized

to the greatest

extent practicable by achieving

the Hazardous

Most Stringent

Emission

Rate ("HMSER")

forFiberMark North America, Inc. Permit # TAOP-04-027 that HAC. If the emission

rate of any HAC after achieving

HMSER

is still estimated

to exceed its action level after achieving

HMSER,

an air quality impact evaluation

may be required to further assess the ambient

impacts for compliance

with the Hazardous Ambient Air Standard

("HAAS")

or Stationary

Source Hazardous

Air Impact Standard ("SSHAIS"). The emission

of hazardous

air pollutants

("HAPs")

may also be regulated separately under to §112 of the Federal Clean Air Act. Any applicable

HAP regulations are discussed

under Section 4 above. 7.1 Quantification

of HAC Emissions Solid fuel burning equipment

(not including

incinerators)

installed

or constructed prior to January

1, 1993, and all fuel burning equipment

which combusts

virgin liquid or gaseous

fuel is exempted

from review pursuant

to §5-261(1)(b)(ii)

of the Regulations. Additionally,

fuel burning equipment

burning waste oil that comply with the requirements

of §5-221(2)

of the Regulations

are also not subject to the requirements of §5-261 of the Regulations.

Consequently,

no fuel burning equipment used at the Facility qualified

for review of HAC emissions

under §5- 261 of the Regulations. The production

of paper products

does result in the discharge

of HACs at the Facility. The Agency

has quantified

and compared

the HAC emissions

to the respective Action Levels (found in Appendix

C of the Regulations)

in order to determine if §5•261 of the Regulations

is applicable

to the Facility. As described

in the Technical

Analysis

prepared

for AOP-95-174

the Agency evaluated HAC emissions

and determined

that FiberMark's

emissions

of formaldehyde and benzyl alcohol were in excess of the respective

ALs. As a result, FiberMark

was subject to §5-261 of the Regulations,

and was required

to submit a HMSER

determination

to the Agency

for formaldehyde.and

benzyl alcohol.7.2 HMSER

Selection Pursuant to §5-261 of the Vermont

Air Pollution

Control Regulations (Regulations) any stationary

source whose current or proposed

actual emission rate of a hazardous

air contaminant

("HAC") is equal to or greater than the respective Action Level shall achieve the HMSER

for the respective

HAC. FiberMark submitted

an HMSER

report to the Agency in March 2003, pursuant

to a requirement

of the Initial Operating.

Permit (#AOP-95-174)

issued October

4, 2002. The permit required

that FiberMark

develop

HMSER

for two compounds, formaldehyde and benzyl alcohol, that were being emitted from the Facility at levels exceeding

their respective

Action Levels. The Agency's

review of the HMSER

report indicated

that subsequent

to issuance of AOP-95-174,

FiberMark

discontinued

the use of products

containing

benzyl alcohol. As a result, submittal

of an HMSER

determination

for benzyl alcohol was not required. Various control strategies

for controlling

formaldehyde

were explored

in FiberMark's HMSER

report. Two compounds

containing

formaldehyde

(Rhoplex HA-12 and Michem)

are used in FiberMark's

standard

clear coating and standard pigment coating.

As part of their research

FiberMark

reviewed

the chemistryFiberMark North America, Inc. Permit # TAOP-04•027 associated with these products,

and tested the hypothesis

that formaldehyde scavenging occurs during the paper-coating

process. Scavenging reactions

are based on the assumption

that certain materials

may react with (or scavenge)

free formaldehyde

to reduce formaldehyde

emissions. Common formaldehyde

scavengers

include ammonia

and urea. Approximately 95% of FiberMark's

coating process

utilizes the two form aldehyde-containing products (Rhoplex

HA-12 and Michem)

in combination

with a product Containing ammonia (Tamol).

To test the hypothesis

that formaldehyde

scavenging

was occurring in the coating processes,

FiberMark

had their vendor, RhomNova, perform analytical

tests that conservatively

replicated

the dwell times and oven temperatures of their coating processes. The two coatings

of interest were the standard

clear coating and the standard pigment coating.

Approximately

95% of the coating used at FiberMark

is the standard clear coating, the remainder

is pigment

coating.

The general composition of each coating is shown in Table 7-1: Table 7-1: Composition of Standard

Clear and Pigment

Coatinf] Coating Percent

Percent Michem

Percent Tamol Standard Coating (SC) Pigment Coating (PC) Compound of Interest

Rhoplex

HA-12

(% by weight)

165A (% by weight) (% by weight) 49.4% 1.1% (maximum)

49.4% 23.5% na

na formaldehyde formaldeh•/de

ammonia Two headspace

analyses

of each of the coatings

of interest were analyzed

by GC/MS using a full evaporation

technique.

The testing parameters

and results, as well as the operating

temperatures

used in FiberMark's

coating process,

are compared in Table 7-2. Based on the analytical

results it was assumed

that the maximum

concentration of formaldehyde

emitted from the standard

coating is equal to the method detection limit of 5 parts per million (ppm). Formaldehyde

emissions

from the pigment coating were estimated

to be 43 ppm, the maximum

concentration measured by analytical

testing. Table 7-2: Anal•,tical Conditions*

Standard Coating Headspace Test 1 Headspace Test 2 Pigment Coating Headspace Test

Oven

Dwell

Formaldehyde

Method Temperature Time

Emissions

Detection (minutes) (ppm)

Limit (ppm) 302 °F

4

Non-detect

5 302 °F

30

Non-detect

5 250 °F

2

36

5 Headspace Test2

250 °F

2

43

5 •c•alFacilityoperating conditions

are 180 • 220°F•r6-18

seconds.FiberMark North America, Inc. Permit # TAOP-04-027

In 2002 FiberMark

used approximately

805,887

pounds of standard

coating and 46,729 pounds of pigment

coating; yielding approximately

4 and 2 pounds per year of formaldehyde

emissions

from each coating, respectively.

Table 7-3 compares the annual formaldehyde

emissions

calculated

assuming

that all of the formaldehyde present in the coatings

is being released

(mass balance),

to the laboratory test results which measured

actual formaldehyde

emissions

from the coatings. Table .7.3: Comparison of Formaldehyde

Emissions

from Coatings Coating Type

Standard Coating Pigment Coating Total

Annual Emission Estimates, Ib/yr (based on 2002 annual usa•les) Mass Laboratory Balance Testing 194.75 4.03 10.25 2.01

TestingResults

Formaldehyde Emission Action Level, Rate, Ib/8-hr Ibl8-hr0.00370.0018 205 6.04

0.0055

0.0066 Because the analytical

results demonstrate

that formaldehyde

emissions

from the standard

and pigment

coatings

are significantly

lower then emissions estimated using a mass balance approach,

annual formaldehyde

emissions should be calculated

and reported

using the formulas

below: Standard Coating:5xC•Fa,• lxlO 6

Where: Fasc =Annual

Formaldehyde

Emiss ons, in Ibs/year,

from the standard clear coating. Cs Annual Standard

Coating Usage, in bs/year Pigment Coating:43 x CpFapc- lxlO 6

Where: Fapc= Annual Formaldehyde

Emissions,

in Ibs/year,

from the standard pigment

coating. Cp Annual Pigment

Coating Usage, in Ibs/year Despite the reduction

in emissions

resulting

from scavenging

reactions, formaldehyde emissions

from the Facility remain in excess of the current Action Level of 0.0064 pounds per 8 hour period. According

to 2003 registration information, formaldehyde

emissions

for the year were 17.7 pounds,

or 0.016 pounds per 8 hour period. To account for future increases

in coating usage, the Permittee has requested

an annual cap on formaldehyde

emissions

of 65 poundsFiberMark North America, Inc. Permit # TAOP-04-027 per year.Based on these results the Agency

has determined

HMSER

for formaldehyde to be 65 pounds

per year, which correlates

to an emission rate of 0.059 pounds

per 8 hour period, If any of the formaldehyde-containing products

utilized in these coatings

are changed (unless that change involves

only the reduction

of formaldehyde) FiberMark is required

to notify the Agency in writing of the change.

Use of any new. products

shall not begin until the Permittee

receives

written approval

from the Agency.

Additional

analysis

of any new products

may be required

prior to use of any new product.

Additional

analysis

of any. new products

may be. required before an adjusted

emission

factor (such as those presented

above) may be used for any new product. If in the future FiberMark

resumes

the use of products

containing

benzyl alcohol, the Facility shall report (through

annual registration)

actua benzyl alcohol emissions. Benzyl alcohol emissions

shall be based using mass balance methods, with the assumption

that all benzyl alcohol contained

in said products

is emitted, unless an alternative

method of calculating

emissions

is submitted

by the Facility and approved

by the Agency prior to submission

of the annual registration report. This HMSER

evaluation

shall be subject to re-evaluation

five (5) years from the date of its determination

and shall remain in effect until revised by the Agency. 8.0 REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the Agency has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility.

Therefore,

the source is currently

in compliance with this requirement.

The Agency will notify the source if any applicable RACT requirement

applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensure that the source complies

with such requirement at that time. 9,0 COMPLIANCE

PLAN Not applicable

to this Facility.FiberMark North America, Inc. Permit # TAOP-04-027 Appendix A Facility Location

MapVERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmenta'

Conservation Air Pollution

Control Division TECHNICAL SUPPORT

DOCUMENT

FOR PERMIT

TO CONSTRUCT AND OPERATE #AOP-03-024 January 18,2005 Prepared By: Evan Pilachowski

APPLICANT: Cersosimo

Lumber Company,

Inc, 1103 Vernon Street Brattleboro, Vermont

05301-8615 Tel: 802-254-4508 Fax: 802-254-5691

SOURCE: Cersosimo

Lumber Company,

Inc. Sawmill and Kiln Drying of Lumber 1103 Vernon Street Brattleboro, Vermont

05301-8615Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024

1.0 INTRODUCTION Cersosimo Lumber Company,

Inc. (also referred to herein as "Permittee"

and also as "Owner/Operator") owns and operates

the sawmill referred to as the Main Yard (also referred to herein as "Facility")

at 1103 Vernon Street in Brattleboro,

Vermont.

This is also Cersosimo Lumber's main corporate

office location.

The Facility saws hardwood

and softwood

logs into boards which are then kiln dried on site. The kiln dried boards are then planed, graded and stored for shipment.

The Permittee

has proposed

to increase

tlie annual fuel limit at the Facility from 18,000 to 20,000 tonsof wood fuel. In addition the Permittee

has proposed

to burn green wood waste exclusively

and separate

the dry wood waste from the wood fuel for sale. The dry wood waste particulate

emissions

will be controlled

with a new fabric filter. The existing pneumatic.wood conveying

system will be used as backup for the proposed

dry wood waste line with the associated

fabric filter. This Technical

Support

Document

details the Agency of Natural Resources,

Department

of Environmental Conservation,

Air Pollution

Control Division

(hereinafter

"Agency")

review for the combined Air Pollution

Control Permit to Construct

and Operate

the Facility.

The Agency has combined the applications

for the Permit to Construct

the current modifications

and the Permit to Operate

for the Facility (#AOP-03-024). The allowable

emissions

for the Facility are summarized

below:

150.8 2.2

19.4

52.8

35.4

>10

<10/25 PM/PM10 particulate matter and particulate matter of 10 micrometers

in size or smaller; SO2 sulfur dioxide; NOx oxides of nitrogen measured as NO2 equivalent; CO carbon monoxide; VOCs volatile organic compounds;

HAPs hazardous air pollutants
as defined in §112 of the federal Clean Air Act. Emissions of individual HAPs each < 10 tpy and emissions of total HAPs combined <25 tpy. Combined allowable HAP emissions equals 3.43 tpy. 2.0 FACILITY

DESCRIPTION

AND LOCATION 2.1 Facility Locations

and Surrounding

Area The Permittee

owns and operates

the sawmill located at 1103 Vernon Street (Route 142) in Brattleboro,

Vermont.

The area surrounding

the Facility is primarily

undeveloped or industrial.

The Facility is located less than 100 kilometers

from the Lye Brook Wilderness area in Manchester,

Vermont

and greater than 100 kilometers

from the Great Gulf and Dry River Wilderness

areas in New Hampshire. 2.2 Facility Description The Facility is a sawmil listed under the Standard

Industrial

Classification

("SIC") Code #2421, Sawmills

and Planing Mills. The sources of air contaminant

emissions

at the Facility are the wood waste handling

operations,

the dry kilns, and the wood fired boilers.

Page 2 of 13Cersosl mo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 The debarking

operation

removes

90% to 95% of the bark from the logs and is considered to have negligible

emissions

since the material

is conveyed

by auger rather than pneumatically.

The bark is then sold to landscapers

and is not burned in the boilers: Dried sawdust,

planer shavings,

and chipped wastes are pneumatically conveyed to the Torit fabric filter. The dried wood waste is then pneumatically

conveyed to the feed box of a trailer. Air from the trailers is ducted back to the fabric filter. Dried wood waste is no longer burned in the boilers and is sold instead.

A backup planer system has the ability to work with green or dried wood. Wood waste is collected

'n one of two cyclones

(6,144 cfm and 13,771 cfm) and is sent to one of two locations.

If dried wood is planed, an airlock will be used to duct the wood waste to the trailers.

If green wood is planed, the airlock will be disengaged,

and the waste will be pneumatically

fed into the indoor wood waste storage bin. Additional

green wood fuel will be delivered

to the outdoor fuel storage bin. The outdoor bin cyclone is used to transfer green woodchips delivered

by truck into the large indoor bin. This cyclone is used regularly since the facility does not generate

enough of wood wastes on its own and therefore must purchase

green woodchips

for fuel. Since this is green wood waste with a high- moisture content,

particulate

matter emissions

from this cyclone are considered negligible.The two 600 HP wood-fired

boilers, each rated at 32 MMBTU/hr

(input), are used for supplying steam heat to the kilns. The primary boiler is a 1985 Industrial

Boiler Company Model #3-3900-200

fire tube 32 MMBTU/hr

input (600 HP, 3,900 sq.ft.) wood waste boiler. The boiler is equipped

with a spreader

stoker and a single multiclone.

Fly ash from the multiclone

is automatically

reinjected.

The second boiler is a 1975 Dillon (manufactured by the Bigelow Company)

fire tube 32 MMBTU/hr

input (600 HP, 4,000 sq.ft.) wood waste boiler. The boiler also uses a spreader

stoker and. has a single multiclone. Both boilers also have primary fly ash reinjection,

which collects large fly ash that impacts the back of the boiler and reinjects

that into the fuel bed. The boilers are now proposed

to operate only on wet wood wastes with an assumed

heating value of 4,400 BTU/Ib.

By using only wet wood waste, the boilers should receive a consistent fuel source.

Slugs of wet and dry wood fuel being burned in the boilers makes controlling combustion

efficiency,

opacity, and particulate

emissions

more challenging. A consistent

fuel source should reduce the variability

in emissions

from the boilers, The maximum firing rate is estimated

at 7,270 Ibs/hour

for each boiler. Cersosimo

Lumber has proposed

to limit operation

of the wood boilers to a combined

20,000 tons per year of wet as-fired wood waste. 2.2.1 Description

of Existing

Equipment

Dillon Boiler

Description 32 MMBtu/hr,

wood fuel, multiclone,

installed 1975 32 MMBtu/hr,

wood fuel, multiclone,

installed 1985 26 kilns, 30 million board feet annual Capacity,

3 kilns installed after 1979 Two cyclones handle dry wood waste (6,144 cfm and 13,771 cfm).
Page 3 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 2.2.2 Description

of Compliance

Monitoring

Devices The stack used for the boilers is equipped

with a Cleveland

series 8000 opacity monitor. The opacity monitor is used to give the boiler operators

feedback

of how efficiently

the boilers are operating

and whether

the oxygen trim meters are operating correctly. The Dillon boiler is equipped

with an oxygen trim system and variable

speed fan. A computer

system uses the data from the oxygen trim system to automatically control variable

speed fan to maintain

the proper range of oxygen values in the exhaust gas. By maintaining

the proper oxygen range, tl•e combustion

efficiency and opacity are maintained

to acceptable

levels. This permit requires

that the IBC boiler be equipped

with an automatic

excess air system that operates

like the one on the Dillon boiler. 2.2.3 Proposed

Modifications

to Facility The Permittee

has proposed

to install a separate

dry wood waste handling system that will be controlled

by a fabric filter. This wood waste handling

system will allow the. Permittee

to separate

dry wood waste from green wood waste. The boilers will only burn the green wood waste, and the dry wood waste will be sold. Previously the Permittee

burned a combination

of wet and dry wood in the boilers with a heating value assumed

to be 4900 Btu/Ib. The green wood waste has an approximate heating value of 4400 Btu/Ib. Due to this decrease

in the heating value of the fuel, the Permittee

has requested

an increased

fuel limit. A new annual wood fuel limit of 20,000 tons is an increase

from 18,000 tons, but the heating value of these limits (taking into account the differences

in moisture content of the fuel) is very similar. Table2-2: Proposed

Facility Equipment 156 RAW10-AW

baghouse,

11,587 cfm, air to cloth ratio Fabric Filter

of 5:7:1, manufactured

2004 2.2.4 Proposed

Limitations The Permittee

has proposed

to limit the annual fuel usage to 20,000 tons of wood fuel. This limit keeps the emissions

of particulate

matter below the significance levels as defined in {}5-101 of the Regulations.

This eliminates

the requirement to do MSER for this permit. 3.0 QUANTIFICATION

OF POLLUTANTS The quantification

of emissions

from a stationary

source is necessary

in order to establish

the regulatory review process

necessary

for the operating

permit application

and to determine applicability with various air pollution

control requirements.

These determinations

are normally based upon allowable

emissions.

Allowable

emission

is defined as the emission

rate calculated using the maximum

rated capacity

of the source and, if applicable,

either: (a) the applicable emission standard

contained

in the Regulations,

if any, or (b) the emission

rate or design, operational or equipment

standard

specified

in any order or agreement

issued under the Regulations that is state and federally

enforceable.

An applicant

may impose in its application
an emission

rate or design, or an operational

or equipment

limitation

which may be incorporated in the Permit to restrict operation

to a lower level. Such limitations

may include fuel restrictions or production

limits. Page 4 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 3.1 Designation

of Proposed

Modification

for the Permit to Construct The designation

of the proposed

modification

is determined

by the designation

of the existing Facility and the allowable

emissions

associated

with the proposed

modification. The existing Facility, before construction

or installation

of the proposed

modification,

is designated as a major stationary

source of air contaminants,

as defined in §5-101 of the Regulations. The modification's

allowable

emissions

are calculated

according

to the following procedure. Step a: Calculate

the allowable

emissions

for each new piece of equipment

or process being added. Table 3-1: Dry Wood Waste Handling

System (Torit 156 RAW10-AW) Planer and wood A owab e nd n s •-m ss on •-ac•or g g Pm•ss•ons 11 587 cfm Conservative

emission rate determined 0.02 gr/dscf

by the Agency from the manufacturer's

8.7 specifications Step b: Calculate

the allowable

emissions

for all.existing

processes

that are affected

by the modification. Pneumatic Conveying

of Wood Waste Side Planer (#32) 6,144 cfm Hog-Planer cyclone (#38) 13,771 cfm Combined air flow rate 19,915 cfm Each cyclone is limited to 0.06 gr/dscf from §5-231 (1)(b) of the Regulations. Allowable PM emissions

44.9 ton/year assuming

maximum

operations

8760 hours per year. Total waste handling

allowable

PM emissions

after modification

44.9 + 8.7 tons per year 53.6 tons per year Pneumatic Conveying

of Wood Waste Indoor bin cyclone (#8) 059 cfm Outdoor bin cyclone (#18) 5,339 cfm Side Planer (#32) 6,144 cfm Hog-Planer cyclone (#38)- 13,771 cfm Combined air flow rate 26,313 cfm Each cyclone is limited to 0.06 gr/dscf from §5-231(1)(b)

of the Regulations. Allowable PM emiss•'ons

59.3 ton/year assuming

maximum

operations

8760 hours per year. Total waste handling

allowable

PM emissions

before modification

59.3 tons per year Since there is a net drop in PM emissions

as a result of the !nstallation

of the dry wood waste handling

system and associated

fabric filter, this is not considered

a modification. These emissions

are not included

in any of the further calculations

to determine

if the modification to the Facility will exceed a significance

level.

Page 5 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 Table 3-2: Dillon Wood Boiler 32 MMBtu/hr,

.

-

Emission Factor Allowable 20 000 tons/•ri.wood " '

.

Emissions 4400Btu/ b,.,,. I 550,000 dscf/hr,

Factor

Units Source tons per year 5500 hr/year at max I capac tyNOx

0.22

AP-42 Wood Residue Combustion

in

19.4 SO2PMPM10 • vocHAP

0.025

Lb/MMBtu 0.600.45 gr/dscf 0.200.017 Lb/MMBtu 0.039

Boilers, Table 1.6-2 (9/03) {}5-231(3)(b)(i) of the Regulations AP-42 Wood Residue Combustion

in Boilers, Table 1.6-1 (9/03) AP-42 Wood Residue Combustion

in Boilers, Table 1.6-3 (9/03) AP-42 Wood Residue Combustion

in Boilers, Table 1.6-3 and 1.6-4 (9/03)

2.252.897.217.61.53.4 calculations are based on burning the entire fuel limit in the Dillon Wood Boiler. Emission estimates from the.Dillon boiler of each pollutant are equal to or greater than emission estimates from the IBC Wood Beiler. Table 3-3: IBC Wood Boiler 32 MMBtu/hr,

• Emiss on Factor A owab e 20 000 tons/yr wood, Em ss ons 4400 Btu/Ib550,000 dscf/hr,

Factor

Units 5500 hr/year at max capacityNOx

0.22 SO2 0.025 CO 0.60 PM 0.20

gr/dscf PM10. :

0.20 VOC 0.017

Lb/MMBtu 0.039, Lb/MMBtu Source tons per year

AP-42 Wood Residue Combustion

in Boilersl Table 1.6-2 (9/03) §5-231 (3)(b)(ii) of.the Regulations AP-42 Wood Residue Combustion

in Boilers, Table 1.6-1 (9/03) AP-42 Wood Residue Combustion

in Boilers, Table 1.6-3 (9/03) AP-42 Wood Residue Combustion

in Boilers, Table 1.6-3 and 1.6-4 (9/03)

19.42.252.843.217.61.53.4 Step c: Calculate

the actual emissions

from all existing processes

that are affected

by the modification

(i.e., that were included

in Step b) that were installed

prior to 1979 or have already been reviewed

as being major under {}5-502 of the Regulations.

Page 6 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 Table 3-4: Boiler Emissions Column

2

3 Fuel Use (tpy)

14,400

18,000

20,000 Heating Value(Btullb)Source
PM/PM10SO2NOx

4900Actual fuel use during previous MSER review78.0/t4.11.815.5

4900PreviousPermit Limit #AOP-95-05697.5/17.62.219.4 42.3 52.9 -VOC 1.2

1.5 HAP 2.8

3.4

44OOProposedPermit Limit97.2/17.62.219.4
1.53.4

3-1

3-2

19.2/3.50.43.910.50.30.6 0.00.0-0.10.00.0 The actual emissions

are summarized

in Column 1. The increase

m emission

of pollutants from the boilers since the MSER review is summarized

in Column 3-1. This column contains

the emissions

entire allowable

emissions

from the boilers minus the emissions that have been a part of a MSER review. Step d: Calculate

the allowable

emissions

from all other equipment

or processes

at the facility modified

since 1979 that have not been reviewed

as being major in the past. Table 3-5: Total Wood Kiln Emissions 26 dry kilns, Em ss on Factor A owab e 30; MM board feet Em ss ons ' Units tons per year NCASI Emissions

From Lumber Drying: VOC 2.26 Lb/1000 BF Technical

Bulletin 718(7/1996) -33.9 Table 3-6: Emissions

from 3 dry kilns installed

after 1979 3 dry kilns,3.5 MM board feet.

NCASI Emissions

From Lumber Drying: 2.26 Lb/1000 BF Technical

Bulletin 718 (7/1996)

3.9 Step e: Calculate

the size of the modification

on a pollutant-by-pollutant basis using the following formula: Results of[step a + step b step c + step d] size of modification

Page 7 of 13Cersosimo Lumber Corn pany, Inc. Main Yard Permit #AOP-03-024 Table 3-7: Emissions

increases

(tpy) from 1979 and since prior MSER deterr Source PM/PM10

SO2 KilnsBoilersWood Waste TotalSignificance LevelExceedSignificance Level?

19.2/3.5

0.4 19.2/3.5 0.4 25/15 40 No No

3.9NOx

CO 0 010.5 0 0 3.9 10.5 40 50 No • No

ninationVOCs3.90.304ONo

The proposed

modification's

allowable

emissions

plus all other modifications

that have occurred since 1979 and not undergone

MSER review are summarized

in Table 3-7. The proposed

modification's

allowable

emissions

are estimated

to result in an emissions •ncrease less than significant

levels for each air contaminant.

Therefore,

the proposed modification is designated

as a non-major

modification. In the past the wood kilns had not been considered

a source of emissions.

Emission factors from NCASI for lumber drying were found and are now being applied to the Facility. Only three of the lumber kilns were constructed

prior to 1979, and therefore these are the only kilns considered

for determining

if the modification

exceeds

the significance level. 4.0 APPLICABLE

REQUIREMENTS The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions

regarding the compliance

status contained

herein are not binding against the state of Vermont

in any future legal or administrative

proceedings. 4.1 Vermont

Air Pollution

Control

Regulations

and Statutes §5-201 Open Burning

Prohibited

and Permissible

Opening

Burning Open burning of materials

is prohibited

except in conformance

with the requirements of this section.

Based on the application

submittal

and information available to the Agency,

the Facility is in compliance

with this requirement.

The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. §5-211(2) Prohibition

of Visible Air Contaminants

Installations constructed subsequent

to April 30, 1970 This emission

standard

applies to all installations

at the Facility including

the two wood fired boilers and the wood waste handling

operations.

The Agency will assess compliance

with these emission

standards

in the future during any inspections of the Facility.

The inspections

will include confirmation

of the proper operation and maintenance

of equipment

and visual observations

of emission points.

Page 8 of 13Cersosimo Lumber Company,

Inc.- Main Yard Permit #AOP-03-024 §5-221(1) Prohibition

of Potentially

Polluting

Materials

in Fuel; Sulfur Limitation in Fuel This prohibition

applies to all stationary

fuel burning equipment

used on-site, which is limited to the two wood fired boilers.

Based on the application

submittal, the applicant

is expected

to comply with this regulation

based on the use of wood fuel, which is inherently

low in sulfur. The Agency will assess compliance

with this regulation

in the future during any inspections of the Facility.

The inspections

will include confirmation

of the use of the proper fuels and review of fuel delivery certifications. §5-231(1)(b) Prohibition

of Particulate

Matter; Industrial

Process Emissions This emission

standard

applies to the pneumatically

conveyed

dry wood waste handling operations.

Green wood wastes, such as sawdust,

are not considered a source of emissions

even when pneumatically

conveyed.

This regulation applies to the two cyclone used on the backup planer system and the fabric filter used in the primary dry wood waste handling

system.

The applicant

is expected to comply with the particulate

matter emission

limit of this section based on the large particle size of the material

and the use of cyclone collectors

and the fabric filter, which are considered

adequate

for control of this size particle. The Agency will assess compliance

with this standard

in the future during any inspections of the Facility.

The inspections

Will include confirmation

of the proper operation and maintenance

of the required

air pollution

control devices and visual observations of the stack exhaust. §5-231(3)(b) Prohibition

of Particulate

Matter; Combustion

Contaminants Based on the application

submitted

and information

available

to the Agency,

this Facility currently

has applicable

fuel burning equipment

subject to this regulation. The allowable

particulate

emissions

from the subject equipment

is shown in Table 4-1.

Table 4-1: Equipment

Subjectto

§5-231(3)(b) Equipment ID

Size/Capacity Emission

Allowable Standard Emissions Dillon Boiler

32 MMBtu/hr

0.45 9r/dscf

78.0 tpy IBC Boiler

32 MMBtu/hr

0.20 gr/dscf

34.7 tpv These boilers were tested in 1995. Emissions

from the Dillon boiler were 0.17 gr/dscf and emissions

from the IBC boiler were 0.10 gr/dscf.

This permit requires additional periodic

particulate

matter testing.to

verify thatthe boilers remain •n compliance with this regulation.

Based on these emission

test results, the boilers are considered

to be in compliance

at this time. The Agency will assess compliance

with this standard

in the future during any inspections of the Facility.

The inspections

will include confirmation

of the proper operation and maintenance

of the fuel burning equipment

and the required multiclone control devices and visual observations

of the stack exhaust. Page 9 Of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 §5-231(4) Prohibition

of Particulate

Matter; Fugitive

Particulate

Matter This section requires

the use of fugitive PM control equipment

on all process operations and the application

of reasonable

precautions

to prevent PM from becoming airborne

during the handling,

transportation,

and storage of materials, or use of roads. This requirement

applies to the entire Facility, and the Facility is therefore expected

to comply with the fugitive emission

limitations

of this section. Based on the application

submittal

and information

available

to the Agency,

the Facility currently

is considered

a source of fugitive particulate

matter subject to this regulation.

The Facility •s required

to take reasonable

precautions

at all times to control and minimize

emissions

of fugitive particulate

matter from the operations at the Facility.

This includes

taking precautions

to prevent the release of fugitive particulate

matter during the handling

and disposal of the wood waste material collected

from the wood processing

operations. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility.

The inspections

will include confirmation

of the proper operation of any fugitive particulate

matter control measures

and visual observations of any emission

points. §5-241(1) & (2) Prohibition

of Nuisance

and Odor This requirement

applies to the entire Facility and prohibits

the discharge

of air contaminants that would be a nuisance

to the public or the discharge

of objectionable odors beyond the property-line

of the Facility. Based on the application

submittal

and information

available

to the Agency,

the Facility currently

is in compliance

with this regulation.

The Agency will verify compliance with this requirement

in the future during any inspections

of the Facility. Additionally,

the Agency investigates

all complaints

that it receives

in order to determine

whether

or not there is a violation

of this requirement. §5-251 Control

of Nitrogen

Oxide Emissions Based on the application

submittal

and information

available

tothe Agency,

this Facility currently

has no applicable

fuel burning equipment

subject to this regulation, nor does the Facility have allowable

emissions

of NOx n excessof 100 tons per year. §5-252. Control

of Sulfur Dioxide

Emissions Based on the application

submittal

and information

available

to the Agency,

this Facility currently

has no applicable

fuel burning equipment

subject to this regulation.§5-253.1- 5-253.20-

Control

of Volatile

Organic

Compounds Based on the application

submittal

and information

available

to the Agency,

this Facility currently

has no applicable

operations

subject to this regulation. §5-261 Control

of Hazardous

Air Contaminants See Section 7.0 below.

Page 10 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024

4.2 §5-402

Written Reports

When Required This section gives the Agency authority

to require the Facility to submit reports summarizing records required

to be maintained

by the Agency. §5-403- Circumvention This section prohibits

the dilution or concealment

of an air discharge

in order to avoid air pollution

control requirements.

The Agency wil assess compliance

with this regulation

in the future during any inspections

of the Facility. Federal Air Pollution

Control

Regulations

and the Clean Air Act 40 C.F.R. Part 60 Subpart

Dc -Standards

of Performance

for Small Industrial-Commercial-Institutional Steam Generating

Units "The affected

facility to which this Subpart applies is each steam generating

unit for which construction,

modification,

or reconstruction

is commenced

after June 9, 1989 and that has a maximum

design heat input capacity

of 20 megawatts (MW) (100 million BTU per hour (BTU/hr))

or less, but greater than or equal to 2.9 MW (10 million BTU/hr)."

Theregulation

limits fuel oil sulfur content to a maximum of 0.5 weight percent. The Facility does not have any steam generating

unit that has been constructed, modified, or reconstructed

after 1989. No equipment

at the Facility is subject to this regulation. Clean Air Act §§114(a)(3),

502(b), and 504(a)-(c);

40 CFR Part 70 .6§70.6(a)(3)(i)(B) and 70.6(c)(1);

and 40 CFR Part 64 Compliance Assurance Monitoring Upon renewal of a Title V Permit to Operate,

a facility must comply w.ith enhanced monitoring

and compliance

assurance

monitoring

requirements

for any emission controlled

unit subject to an emission

standard

with uncontrolled emissions from the unit in excess of the Title V major source thresholds.

The uncontrolled emissions

of PM from the boilers and the uncontrolled

(cyclone instead of a fabric filter) emissions

from the dry wood waste handling

system are each less than the Title V major source threshold

for PM. Uncontrolled emissions from a boiler were calculated

assuming

the entire fuel limit was burned in one boiler, a 4400 Btu/Ib heating value of the wood fuel, and an emission factor of 0.33 Ib/MMBtu

according

to AP-42 Table 1.6-1 (9/03) wet wood fuel combustion with no control device. The uncontrolled

emissions

equal 29.0 tons per year under these assumptions,

which is significantly

below the 100 ton per year CAM applicability

threshold.

Therefore

there is no equipment

at theFacility that is subject to this regulation. Section 112 of the Clean Air Act National

Emission

Standards

for Hazardous Air Pollutants

(NESHAPs). NESHAPs are promulgated

under 40 C.F.R. Part 61 and 63. No promulgated NESHAPs in 40 CFR Part 61 or 63 currently

are applicable

to the Facility

Page 11 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 4.3 Non-Applicable

Requirements

for Which a Permit Shield Provision

Has Been Requested Pursuant to §5•1015(a)(14)

of the Regulations,

an owner/operator

may request to be shielded from potentially

applicable

state or federal requirements.

The Facility has not requested a permit shield from any. specific,

potentially

applicable

requirement. Accordingly, the Agency has not granted any permit shields for the Facility. 5.0 CONTROL

TECHNOLOGY

REVIEW

FOR MAJOR

SOURCES

AND MAJOR MODIFICATIONS Pursuant to §5-261 of the Regulations

each new major source and major modification

must apply control technology

adequate

to achieve the Most Stringent

Emission

Rate ("MSER")

with respect to those air contaminants

for which there would be a major or significant

emission increase, respectively.

The proposed

project is designated

as a non-major

modification

of a stationary source and therefore

is not subject to MSER review under §5-502 of the Regulations. 6.0 AMBIENT

AIR QUALITY

IMPACT

EVALUATION An ambient

air quality impact evaluation

is performed

todemonstrate

whether

or not a proposed project will cause or contribute

to violations

of the ambient

air quality standards

and/or significantly deteriorate

existing air quality. The Agency's

implementation

proceaures concerning the need for an ambient

air quality impact evaluation

under §5-406(1

of the Regu/ations, specifies

that such analyses

may be required

when a project results in an allowable emissions

increase

of ten (10) tons per year or more of any air contaminant,

excluding VOCs. Additionally,

the Agency may require an air quality impact evaluation

where theshortterm allowable

emission

rates will significantly

increase

as a result of a project. The emissions resulting from the increase

in fuel cap and change to heating value of the fuel is summarized

in Table 3-4 above. Column 3-2 of the table shows that the increase

in allowable

emissions resulting from this project will not be large enough to require the Permittee

to perform an ambient air quality impact evaluation. 7.0 HAZARDOUS

AIR CONTAMINANTS The emissions

of hazardous

air contaminants

("HACs")

are regulated

under to §5-261 of the Regu/ations. The Owner/Operator

of a source must quantify

its emissions

of HACs regulated

by this rule. Any Facility whose emission

rate of a HAC exceeds

its respective

Action Level ("AL") =s subject to the rule for the HAC, and the Owner/Operator

must then demonstrate

that the emissions of the HAC are minimized

to.the greatest

extent practicable

by achieving

the Hazardous Most Stringent

Emission

Rate ("HMSER")

for that HAC. If the emission

rate of any HAC after achieving

HMSER

is still estimated

to,exceed

it's action level after achieving

HMSER, an air quality impact evaluation

may be required

to further assess the ambient

impacts for compliance with the Hazardous

Ambient

Air Standard

("HAAS")or

Stationary

Source Hazardous Air Impact Standard

("SSHAIS").

The emission

of hazardous

air pollutants

("HAPs")

may also be regulated

separately

under to §112 of the Federal Clean Air Act. Any applicable

HAP regulations are discussed

under Section 4 above. 7.1 Applicability

of HAC Emissions The sources of HAC emissions

at the Facility are limited to the combustion

related emissions associated

with the wood fired boilers and the dry lumber kilns. The wood waste handling

operations

are not considered

to be a source of HAC emissions. Pursuant to §5-261(1)(b)(ii)

of the Regu/ations,

fuel burning equipment

that combusts virgin liquid or gaseous

fuels as well as wood fuel burning equipment

installed

prior to
Page 12 of 13Cersosimo Lumber Company,

Inc. Main Yard Permit #AOP-03-024 January 1, 1993 are exempt from the requirements

of {}5-261.

Table 345 has the total allowable VOC emissions

from the dry lumber kilns. To be conservative

the VOC emissions from the lumber kilns uses the highest emission

factor of a species of wood that is processed

at the Facility: white pine. Turpentine

comprises

some of the VOC emissions, but an emission

factor for turpentine

is not given. A conservative

estimate

is shown below assuming

the entire allowable

emission

of VOCs from the lumber kilns is in the form of turpentine. Turpentine emissions

(2.26 Ib/1000 board feet) x (30,000,000

board feet/year)

x (1 year/8760 hr) 8hr 61.9 Ib/8 hr The action level for turpentine

is 69 Ib/8 hr, and therefore

the emissions

of turpentine

do not exceed the action level of {}5-261 of the.Regulations. 8.0 REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY Pursuant to 10 VSA {}556a(d)

and {}5-1010

of the Regulations

the Agency may establish

and include within any Permit to Operate

emission

control requirements

based on Reasonably Available Control Technology

("RACT").

RACT for the wood fired boilers has been determined to be periodic

combustion

efficiency

tests, annual boiler tune-up,

and the development

and implementation of an operation

and maintenance

plan (O&M plan). These RACT requirements were determined

by the Agency to be reasonable

procedures

to ensure that the boilers are maintained to minimize

emissions.

Additional

RACT requirements

may be imposed

in the future upon the renewal of this or any future operating

permit for the Facility.

Page 13 of 13VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division Operating Permit Program TECHNICAL ANALYSIS

OF AN AIR CONTAMINANT

SOURCE FOR A PERMIT TO OPERATE #AOP-95-031 PIN# SJ95-0114 May 29, 1997 Updated: July 2, 1997 Prepared By: John L. Perreault,

P.E.

APPLICANT:

SOURCE:

RESPONSIBLE OFFICIAL:
APPLICATION CONTACT:

COUNTY:AREA DESIGNATION:

UTM COORDINATES: Ryegate Associates,

Incorporated RR 1, Box 4, U.S. Route 5 East Ryegate,

Vermont

05042 Ryegate Power Station U.S. Route 5 East Ryegate,

Vermont

05042 Eric Heggeseth,

Vice President Ryegate Associates,

Incorporated Robert Blanchard Ryegate Associates,

Incorporated Tel. (802) 633-3500 Fax (802) 633-3504 CaledoniaAttainment for PMlo, SO2, NO×, CO, and Pb Unclassified for O3 4899580. m N, z35149 m E, Zone 18 (Main Boiler Stack)Ryegate Associates,

Incorporated I. INTRODUCTION A. Administrative

Milestones #AOP-95-031

Date Application Received: 11/03/95 Date Administratively

Complete: Date & Location Receipt of App!ication Noticed: Date Technically Complete: Date Draft Decision: Date & Location Draft Decision/Comment

Period Noticed: Date & Location Public Meeting Noticed: Date & Location of Public Meeting: Deadline for Public Comments: Date Proposed Decision: Classification of Source Under §5-401:

Classification of Application: New Source Review Designation

of Source: Facility SIC Code(s): 02/05/96 02/08/96 The Caledonian Record 05/29/97 05/29/97 Approved 04/24/97 The Caledonian Record None requested
None requeste d06/30/9707/02/97 §5-401(3): Electric power generation facilities T e V Subject Source Major Stationary Source 4911 Facility SIC Code Description(s)i Electrical Services

22 25

197

394

39

N/A

<5* ""All individual HAP emissions

10 tpy. Basis of Review Ryegate Associates,

Incorporated

(hereinafter

"Ryegate

Associates"

and also referred to herein as "Owner/Operator")

owns and operates

a twenty (2(:}) megawatt

(net)woodfired power plant in East Ryegate,

Vermont

(hereinafter

"Ryegate

Power Station" and also referred to herein as "Facility").

Operations

performed

at the Ryegate

Power Station are classified

within the Standard

Industrial

Classification

Code 4911 (Electrical Services). The Ryegate

Power Station is listed as a stationary

source of air contaminants under §5-401(3),

Electrical

power generation

facilities

of the Vermont Air Pollution Control Regulations

("Regulations").

Prior to commencing

the construction

and operation of the stationary

source, Ryegate Associates

was required to obtain approval from the Agency of Natural Resources,

Department

of Environmental

Conservation,

Air Pollution Control Division (hereinafter

"Agency").

Agency approval

was granted, in the form of an air pollution control permit to construct,

pursuant

to the requirements

of Title 10 Vermont

Statutes

Annotated

("10 V.S.A.") §556 and §§5-501

and 5-502 of the 2Ryegate Associates,

Incorporated #AOP-95-031 Regulations on January

11, 1988. Since this date, the Agency has issued seven (7) amendments to the original permit to construct.

The most recent amendment

was issued on February

25, 1997. These amendments

have primarily been required in order to administratively

modify the conditions

of the permit. Based upon its permit, allowable

emissions

of all air contaminants

from the Ryegate Power Station are greater than 10 tons per year ("tpy"). Pursuant

to §§5-1002,

5-1003, and 5-1005 of the Regulations,

the Facility is classified

as a "Title V Subject Source" and is subject to the requirement

to obtain an air pollution

control permit to operate consistent with the requirements

of Subchapter

X of the Regulations

and Title 40 Code of Federal Regulations

('40 CFR") Part 70. The applicable

requirements

for the Facility are contained

in the Regulations,

its existing permit, and 40 CFR Part 60 Subparts

A and Db. Currently,

the Facility is in compliance with these applicable

requirements. II. FACILITY

DESCRIPTION

AND LOCATION A. Description

of Plant Layout and Surrounding

Area The Facility is located off U.S. Route 5 just north of the village of East Ryegate, Vermont..The area surrounding

the Facility property is rural and Consists of primarily agricultural and residential

uses. The Connecticut

River borders the property to the East and U.S. Route 5 to the West. CPM, Incorporated,

a paper manufacturing

facility, is located within 500 meters to southeast

of the Facility. The geographical

area is complex terrain in all directions

surrounding

the site. Figure

in Appendix

A of this Technical Analysis depicts the location of the Facility. B. Explanation

of Process (Including

SIC Codes) The operations

performed

at the Facility are described

using the Standard

Industrial Classification Code 4911 (Electrical

Services).

The Ryegate

Power Station is equipped with a wood-fired

boiler (hereinafter

"Main Boiler"), which is fired with whole wood tree chips delivered

in standard

chip vans. The fuel is primarily

mixed hardwood and softwood,

with some lesser amounts

of sawdust,

mill chips, and bark. The fuel chips ar stored in two (2) silos and an uncovered

outside storage pile before being mechanically conveyed

to the Main Boiler. Wood fuel is fed at a rate of approximately thirty-five (35) tons per hour into a single, high-pressure,

boiler designed

to burn green fuel. The Facility is operated

as a base load plant at or close to 100% capacity at all times, excluding

plant outages.

The Main Boiler is fitted with with a propane

(LPG) auxiliary burner having a maximum

rated heat input of 50 million British Thermal Units per hour ("MMBTU/hr").

This burner is used primarily

for plant start-up and for supplemental fuel. Steam produced

by the Main Boiler is passed through a condensing turbine generator

set with extraction

steam utilized for feedwater

heating.

Condenser heat is removed

via a closed loop circulating

water system to a cooling tower structure. The Ryegate Power Station is also equipped

with a 430 horsepower

("HP")/300

kilowatt ("kW") propane-fired

engine generator

set (hereinafter

"Emergency

Generator")

for use during electric power outages,

and an auxiliary

propane-fired

boiler rated at five (5) MMBTU/hr (hereinafter

"Auxiliary

Boiler").

The Auxiliary

Boiler supplies steam for space heating purposes

during plant outages. Air contaminant

emissions

produced

by the Main Boiler are controlled

as follows: multicyclones in series with an electrostatic

precipitator,

flue gas reinjection,

selectiveRyegate Associates,

Incorporated #AOP-95-031 non-catalytic reduction

system (urea injection),

and combustion

air control with oxygen trim and underfire/overfire

air ratio. A diagram of the Facility layout may be found in Appendix

A of this Technical

Analysis. C. Process Equipment

and Stack Information 1. Description

of Equipment See Table 2-1 Equipment

Information. 2. Description

of Compliance

Monitoring

Devices The Main Boiler is equipped

with devices to continuously

monitor the following air contaminants

andoperating

parameters: Visible emissions

as opacity, Oxides of nitrogen ("NO×"), Carbon monoxide

("CO!'), Carbon dioxide ("CO2"), Ammonia ("NH3"), Volumetric air flow rate; and Miscellaneous boiler and steam turbine operational

information

in the control room. Up until recently,

the Main Boiler was required

to continuously

monitor emissions of volatile organic compounds

("VOCs")

measured

as totalnonmethane hydrocarbons.

However,

as part of the recent permit amendment

for this Facility, the Agency eliminated

this requirement

based upon the minimal quantity of VOC emissions

measured

over a period of greater than three years of Facility operation

and data collection. In addition,

the Auxiliary

Boiler and Emergency

Generator

are equipped

with hourly timers to track hours of operation

of this equipment.II1. QUANTIFICATION

OF POLLUTANTS A. Emission

Related Information Allowable emissions

from the Ryegate Power Station have been estimated

for the Main Boiler, Auxiliary

Boiler, and Emergency

Generator.

Emissions

produced

from this fuel burning equipment

include: particulate

matter ("PM/PM10"),

sulfur dioxide ("SO2"), NOx, CO, and VOCs. VOCs from fuel burning equipment

are also commonly

referred to as non-methane hydrocarbons

("NMHCs")

or total organic compounds

("TOCs"). The Facility also has the potential to generate

emissions

from the following

list of other air contaminant

generating

equipment

or processes: 1. VOCs from the cooling tower drift and boiler water deaerator

vent; 2. Combustion

contaminants

from a diesel fire pump, Fuel Yard Maintenance Building Heater, Main Maintenance

Building

Heater, and propane

system vaporizer;Fugitive emissions

of VOCs from chemical

and fuel storage tanks, and two (2) degreasing/solvent tanks; and Fugitive emissions

of PM/PM10

from activities

associated

with the handling

and storage of wood fuel .and ash; and the use of haul roads on-site. Individual constituents

that makeup

the categories

of PM/PM•0

and VOCs are also regulated by state and federal regulations,

and must therefore

be quantified.

These individual constituents

are referred to as hazardous

air contaminants

("HACs")

and/or hazardous air pollutants

("HAPs").

HAPs are defined as those chemicals

listed in the -Section 112(b) of the federal Clean AirAct, of which there are 189 chemicals.

HACs are defined as those chemicals

which are listed in Appendix

B of the Regulations.

All of the 189 HAPs are included as HACs. Further information

concerning

the derivation

of allowable

emissions

•s contained

in Appendix B of this Technical

Analysis. B. Enforceable

Operating

Restrictions The Facility presently

operates

under the limitations

imposed by a permit to construct. Ryegate Associates

proposes

to maintain these limitations.

Below are summarized

the limitations on the operation

of this Facility.

2.3.4. Annual usage of propane fuel in the Main Boiler is restricted

to 20 million cubic feet per year ("ft3/yr") based on any rolling twelve (12) calendar month period; Propane fuel sulfur content restricted

to 10 grains per 100 ft 3 or less; Annual hours of operation

for the Auxiliary

Boiler may not exceed 720 hours during any rolling twelve (12) calendar month period; and Annual hours of operation

for the Emergency

Generator

may not exceed 720 hours during any rolling twelve (12) calendar

month periodand

may not operate simultaneously with the Main Boiler, except for periods of regularly

scheduled Emergency Generator

operation

necessary

for maintenance

and testing of the performance of the emergency

system. C. Identification

of Insignificant

and Exempt Activities Activities which qualify as an "insignificant

activity" pursuant

to §5-1002(h)

of the Regulations need not be considered

when determining

the applicability

of Subchapter X of the Regulations

and must only be listed as such within the Operating

Permit Application. In its application,

Ryegate Associates

has identified

the below listed fuel burning equipment

as having a heat input rating less than 3 MMBTU/hr,

and thus beingRyegate Associates,

Incorporated #AOP-95-031 classified as.an "insignificant

activitiy" pursuant

to 5-1002(h)(1

)(i):

2.3.4. diesel fire pump; Fuel Yard Maintenance

Building Heater; Main Maintenance

Building Heater; and propane system vaporizer. Allowable Emissions

from Each Emission

Point, Including

Quantifiable

Fugitive Emissions, As Necessary

to Determine

Applicable

Requirements Summarized in Table 3-1 below are the allowable

emissions

from each potential emission point at the Facility. Table 3-1: Summary

of Source Allowable

Emissions

Main Boiler

0.007gr/dscf@12%CO2 Auxiliary Boiler

0.005 Emergency Generator

negligible Cooling Towers & Deaerator Vents Chemical and Fuel Storage Tanks Degreasing/Solvent Tanks

N/Q*** Fugitive Dust from Wood Handling/Storage and Haul Roads 5.0

0.03neg.

30.0

0.050.28

45.0

0.758.1

90.0

0.1126.5

9.0

<1
0.028 N/D•*

neg. neg. neg. neg. neg. neg.

Units in Ibs/MMBTU

of heat input unless otherwise noted. N/D No data available, however, not anticipated to be a significant source of hazardous air pollutants. N/Q Not quantified, however, not anticipated to be a s•gnificant source of particulate matter, due to use of reasonable precautions to minimize the generation of fugitive dusL IV. APPLICABLE

REQUIREMENTS A; Citation and Description

of all Applicable

Requirements §5-1006(e)(4) of the Regulations

requires

the Owner/Operator

of a stationary

air contaminant source to submit a complete

application

including,

but not limited to a demonstration of compliance

with all applicable

air pollution

control requirements. These requirements

include state and federal regulations,

and the requirements

of any construction permit issued under 10 V.S.A. §556. Note that compliance

relative to §5- 261 and §5-1010 of the Regulations

will be discussed

separately

under paragraphs

V. and VI. below. The compliance

analysis and determinations

in this technical

analysis rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions
7Ryegate Associates,

Incorporated #AOP-95-031 regarding the compliance

status contained

herein are not binding against the state of Vermont in any future legal or administrative

proceedings. Vermont Air Pollution

Control Regulations §5-211(2) and (3) Prohibition

of Visible Air Contaminants

Installations

Constructed Subsequent to April 30, 1970. This standard

applies to each emission

point at the Facility and specifies

that visible emissions

("V.E.") may not exceed 20% opacity for a period of six (6) minutes or more in any hour, and at no time may they exceed 60% opacity. Primarily

this standard

would affect any source of particulate

matter including all fuel burning equipment

on-site and the wood handling

systems

(e.g., conveyor

belts and transfer points). An exception

from this standard

exists in §5-211(3)

of the Regu/ations for the.Main

Boiler when burning wood fuel during normal start-up and soot blowing. During norma start-up and soot blowing V.E.s may not exceed 80% opacity. Compliance with this standard

is based on Proposed

Reference

Method F-1 (51 Federa/ Register, Page 31076, August 29, 1986). Ryegate Associates

has stated that it complies

with the standard

based on their continuous opacity monitoring

system for the Main Boiler exhaust,

and their visual observation of equipment

in use on-site. The Agency wil verify compliance

with this standard

in the future during any inspections of the Facility, and its receipt and review of quarterly

excess emission

reports from the opacity monitoring

system installed on the Main Boiler exhaust. §5-221(1)(a) Prohibition

of Potentially

Polluting

Materials

in Fuel, This section prohibits the use of any fuel, in stationary

fuel burning equipment,

with a sulfur content more than 2.0% by weight.

This prohibition

applies to all stationary

fuel burning equipment used on-site.

Compliance

with this standard

is based on fuel analyses following the procedures

prescribed

by the American

Society of Testing Materials ("ASTM").Ryegate Associates

has stated that it complies

with this standard

based on the useof wood, propane,

or No. 2 fuel oil in its fuel burning equipment

(Each fuel type has a maximum sulfur content below the 2.0 % by weight restriction.),

and its contract with the fuel suppliers. The continued

use of these fuels in the stationary

fuel burning equipment

is sufficient

to ensure compliance

with this limitation

in the future. §5-231(3)(a)(i)- Prohibition

of PM; Combustion

Contaminants.

This standard applies to the Auxiliary

Boiler, Emergency

Generator,

Diesel Fire Pump, Fuel Yard Maintenance Building Heater, Main Maintenance

Building Heater, and Propane System Vaporizer

and specifies that PM emissions

may not exceed 0.5 Ibs/hr/MMBTU

of heat input where the heat input is 10 MMBTU/hr

or less. Compliance

with this standard

is based on the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). Ryegate Associates

has stated that it complies

with standard

based on their emission estimates and their scheduled

maintenance

of the stationary

fuel burning equ•pment; The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain

it stationary

fuel burning equipment,

(2) visual observations

of each exhaust will be conducted

duringRyegate Associates,

Incorporated #AOP-95-031 any Agency •nspections

of the Facility, and (3) if.V.E.s are determined

to be in excess of the limits specified

in §5-211(2)

of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standard.§5-231(3)(a)(ii) Prohibition

of PM; Combustion

Contaminants,

The PM standard

in this section is applicable

to fuel burning equipment

with a heat input greater than 10 MMBTU/hr but equal to or less than 250 MMBTU/hr.

This PM standard

is in units of Ibs/hr/MMBTU and varies based upon the heat input of the individual

unit. The actual value of the standard

is derived using a formula.

This standard

applies to the Main Boiler when burning propane fuel, and specifies

that PM emissions

may not exceed 0.23 Ibs/hr/MMBTU of heat input. Compliance

with this standard

is based on the use of ReferenCe Method 5 (40 CFR Part 60 Appendix

A). Ryegate Associates

has stated that it complies

with standard

based on their emission estimates, their PM control equipment,

and the scheduled

maintenance

of the Main Boiler.The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be requiredto

properly operate and maintain its Main Boiler and associated PM control devices,

(2) perform visual observations

of the exhaust during any Agency inspections

of the Facility, (3) review quarterly

excess emission

reports for opacity, and (4) if V.E.s are determined

to be in excess of the limits specified

in §5- 211(2) of the Regulations,

the Agency may require the performance

of a stack test to verify compliance

with the above referenced

PM standard. §5-231 (3)(b)(iii)

Prohibition

of PM; Combustion

Contaminants,

This standard applies to the Main Boiler when burning wood fuel and specifies

that PM emissions

may not exceed 0.10 gr/dscf corrected

to 12% CO2 where the rated output is 1300 horsepower (H.P.) or greater and the installation

commences

operation

after December

5, 1997. Additionally, this standard

applies when fossil fuel is burned in combination

with wood fuel, and the fossil fuel contributes

less than 50% of the total heat input. If the fossil fuel contributes greater than 50% of the total heat input, then the requirements

of §5- 231(3)(a) apply. Compliance

with this standard

is based upon the use of. Reference Method 5 (40 CFR Part 60, Appendix

A). Ryegate Associates

has stated that it complies

with standard

based on their emission estimates and their scheduled

maintenance

of the Main Boiler and its associated

PM control equipment. The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain its Main Boiler and associated PM control equipment,

(2) visual observations

of each exhaust will be conducted during any Agency inspections

of the FaCility, (3) review quarterly

excess emission reports of opacity, and (4) if V.E.s are determined

to be in excess of the limits specified in §5-211(2)

of the Regulations,

the Agency may require the performance

of a stack test to verify compliance

with the above referenced

PM standard. §5-231(4) Prohibition

of PM; Fugitive PM. This section requires the use of fugitive PM control equipment

on all process

operations

and the application

of reasonable precautions to prevent PM from becoming

airborne during the handling,

transportation, and storage of materials,

or use of roads. This requirement

applies to the entire Facility and is particular

concern with the wood fuel handling and storage activities,

and the useRyegate Associates

Incorporated #AOP-95-031 of haul roads on-site. Ryegate Associates

has stated that it complies

with this requirement

based on the use of the fuel management

plan and wet suppression

(if found necessary). The Agency will verify compliance

with this requirement

in the future as follows:

(1) require the application

of water or surfactants

to the plant haul roads and yard as necessary, (2) assess compliance

with this requirement

during any inspections

of the Facility, and (3) require the use of additional

measures

if found necessary

during a compliance inspection. §5-241 Prohibition

of Nuisance

and Odor. This requirement

applies to the entire Facility and prohibits the discharge

of air contaminants

that would be a nuisance

to the public or be source of objectionable

odors beyond the property-line

of the Facility. Ryegate Associates

has stated that it complies

with this requirement

due to the remoteness of the Facility and their observation

of dust and odors from their operations. The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all complaints

that it receives in order to determine

whether or not there is a violation of this requirement. Subchapter VIII Registration

of Air Contaminant

Source.

Thi• Subchapter

requires the registration

of a stationary

source, with the Agency,

if it produces

five (5) tons per year or greater of actua emissions

during the preceding

calendar

year. Sources are required to submit information

regarding

their operations

and pay a fee based on the quantity of emissions

they produce and the fuels that they use. Ryegate Associates

has stated that it complies

with this requirement

based on the information they have submitted

and the fees they have paid for calendar

year 1996. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Air Pollution

Control Permit to Construct Condition (1) Construct

and operate the Facility in accordance

with plans and specifications submitted

to the Agency. Ryegate Associates

has stated that it complies

with requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (2) Limitations

on wood fuel. Specifies

the type and quality of wood fuel that may be used to feed the Main Boiler. Ryegate Associates

has stated that it complies

with requirement

based upon their daily monitoring and record keeping of delivered

wood chips, and utilization

of site forester for the procurement

of wood fuel. The Agency will verify compliance

with this standard

in the future during any •nspections of the Facility.
10Ryegate Associates,

Incorporated #AOP-95-031 Condition (3) Limitations

on propane fuel. Specifies

the amount and quality (i.e., sulfur content) of propane fuel that may be used at the Facility. Ryegate Associates

has stated that it complies

with requirement

based upon their daily monitoring and record keeping of propane usage, the design of the propane burner, and delivery tickets from the propane fuel supplier. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (4) Air pollution control equipment

requirements.

Specifies

the systems that will be equipped

and used to control air contaminant

emissions

from the Main Boiler. Ryegate Associates

has stated that it complies

with requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (5)- Particulate

matter emissions

limitations.

Specifies

the PM standard applicable to the Main Boiler. Ryegate Associates

has stated that it complies

with requirement

based upon their biennial compliance

testing, opacity monitoring

system, and operator training. The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain

its Main Boiler and associated PM control equipment,

(2) biennial emission

testing will be performed

to ensure continuing

compliance,

(3) the quarterly

excess emission

reports of opacity will be reviewed,

and (4) if V.E.s are determined

to be in excess of the limits specified

in §5- 211(2) of {he Regulations,

the Agency may require the performance

of additional

stack testing to verify compliance

with the permitted

PM standard. Condition (6) Visible air contaminant

emissions

limitations.

This specifies

the opacity limits that apply to Facility.

This standard

is based on the limits of §5-211(2)

of the Regulations.Ryegate Associates

has stated that it complies

with this requirement

based upon their continuous opacity monitoring

system. The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain all air contaminant generating equipment

and pollution

control systems,

(2) visual observations

of each exhaust will be conducted

during any Agency inspections

of the Facility, and (3) the Agency will review the quarterly

excess emission

reports of opacity for the Main Boiler. Condition (7) NOx emission

limitations.

Specifies

the NO emission

standard

that applies to the Main Boiler. Ryegate Associates

has stated that it complies

with ths requirement

based upon NOx control system and continuous

emission

monitoring

system. The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain

its Main Boiler and 11Ryegate Associates,

Incorporated #AOP-95-031 associated NOx control system, and (2) the Agency will review the quarterly

excess emission reports of NOx from the Main Boiler. Condition (8) Limitations

on other air contaminants.

Specifies

emission

limitations

for CO, VOCs, Benzo(a)pyrene,

and ammonia

that applies to the Main Boiler. Ryegate Associates

has stated that it complies

with this requirement

based on their initial performance

testing and continuous

monitoring

systems

for CO, VOCs, and ammonia.The Agency will assess compliance

with this standard

in the future as follows:

(1) Ryegate Associates

will be required to properly operate and maintain its Main Boiler and associated control equipment,

(2) biennial emission

testing for VOCs, and (3) the Agency will review the quarterly

excess emission

reports of CO for the Main Boiler. Condition (9) Continuous

emissions

monitoring

requirements

for the Main Boiler. Requires the use of devices for the continuous

measurement

and determination

of emission rates of visible air contaminants,

NOx, CO, CO 2, VOCs, and ammonia. Ryegate Associates

has stated that it complies

with this requirement

based upon their system design and Quality Assurance

Plan. The Agency will verify compliance

with this standard

in the future during any •nspections of the Facility. Condition (11)) Compliance

testing and determination

of continuing

compliance. Specifies the initial performance

testing requirements,

as well as requirements

for the determination of continuing

compliance

using emission

testing and continuous emissions monitoring

systems. Ryegate Associates

has stated that it complies with this requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (11) Limitations

on Auxiliary

Boiler and Emergency

Generator.

Specifies

the limitations on design and use of the Auxiliary

Boiler and Emergency

Generator. Ryegate Associates

has stated that it complies

with this requirement

based upon their hour meters on the boiler and generator,

observation

of the exhausts

serving each unit, and operator training. The Agency will verify compliance

with these requirements

in the future during any inspections of the Facility. Condition (12) Requirements

for the control of fugitive PM. Specifies

the precautions that will be used by the Owner/Operator

to minimize

the generation

of fugitive PM at the Facility.Ryegate Associates

has stated that it complies

with this requirement

based upon their yard maintenance

plan. The Agency will verify compliance

with this requirement

in the future as follows:

(1)
12Ryegate Associates,

Incorporated #AOP-95-031 require the application

of water or surfactants

to the plant haul roads and yard as necessary, (2) assess compliance

with this requirement

during any •nspections

of the Facility, and (3) require the use of additional

measures

if found necessary

during a compliance inspection. Condition (13) Requirements

for the control of odors. Requires

the Owner/Operator to submit a plan for the control of air contaminants

released

by the Facilityand

that may be a source of odors or nuisance

to the general public. Ryegate Associates

has stated that it complies

with this requirement

based upon their wood chip management

plan. The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all complaints

that it receives in order to determine

whether or not there is a violation of this requirement. Condition (14) Requirements

for start-up, shutdown,

and upset conditions.

Requires the submittal

of a plan to deal with start-up, shutdown,

and upset conditions

during the operation of stationary

fuel burning equipment

at the Facility. Ryegate Associates

has stated that it complies

with this requirement

based upon their start-up, shutdown,

and malfunction

plan. The Agency will verify compliance

with these requirements

in the future during any inspections of the Facility. Condition (15) Requirements

for operation,

inspection,

and maintenance.

Requires the Owner/Operator

to properly

train individuals

responsible

for the operation

and maintenance of fuel burning equipment

and associated

air pollution

control equipment at the Facility. Ryegate Associates

has stated that it complies

with this requirement

based upon their inspection and maintenance

plan. The Agency will verify compliance

with these requirements

in the future during any nspections of the Facility: Condition (16) Record keeping and reporting

requirements.

Specifies

the records that will be maintained

by the Owner/Operator

for the Facility, and when such records will be made available

for Agency inspection. Ryegate Associates

has stated that it complies with these requirements. The Agency will verify compliance

with these requirements

in the future during any inspections of the Facility. Conditions (17) throug h (23) Standard

conditions. Ryegate Associates

has stated that it complies with these requirements. The Agency will verify compliance

with these requirements

in the future during any inspections of the Facility.

13Ryegate Associates,

Incorporated #AOP-95-031 Federal Air Pollution

Control Regulations Section 111 of the Clean Air Act. The Ryegate Power Station is subject to requirements within 40 CFR Part 60, Subpart

Db, Standards

of Performance

forIndustrialCommercial-Institutional Steam Generating

Units. As a consequence

of being subject to Subpart Db, the Facility is also subject to requirements

within the General Provisions of 40 CFR Part 60 Subpart A. 40 CFR Part 60 Subpart A §60.7 Notification

and record keeping.

Requires

the written submittal of (or. copies of such submittals

to state/local

agency) notifications

of the commencement of construction,

start-up, etc. to the Administrator;

the maintenance

of records related to start-up, shutdown,

or malfunction

of the affected facility, malfunction of an air pollution

control system, or periods during which a continuous

emissions monitoring system ("CEMS")

is inoperative;

the submittal

of excess emission

reports for those facilities

equipped

with a CEMS; and the maintenance

of files of all measurements, etc. for a minimum

of two (2) years following

the date of such measurements. §60.8 Peformance

tests. Requires

a performance

test and the submittal

of a written report of the results of such testing; sampling

ports and stack or duct free of cyclonic flow, a safe sampling

platform,

safe access to the platform,

and utilities for the sampling/testing equipment. §60.11 Compliance

with standards

and maintenance

requirements.

Specifies

methods to be used to determine

compliance

with standards

within 40 CFR Part 60. Requires

the owner or operator of a source to maintain

and operate any affected facility, including associated air pollution control equipment,

in a manner consistent

with good air pollution control practice. §60.12 Circumvention.

Prohibits

the concealing

of an emission

which would otherwise constitute a violation of an applicable

standard. §60.13 Monitoring

requirements.

Specifies

that continuous

monitoring

systems ("CMS") required by an NSPS is subject to §60.13 upon promulgation

of a performance specification under 40 CFR Part 60 Appendix

B and, if the CMS is used to demonstrate compliance with emission

limits on a continuous

basis, Appendix

F, unless otherwise noted in an NSPS or by the Administrator.

All CMS must be installed and operational prior to conducting

performance

testing under §60.8. Requirements

if continuous opacity monitoring

system ("COMS")

data are used for documenting

compliance

with opacity as provided

in §60.11 (e)(5). Requires

daily checks of zero and s pan calibration drifts and adjustments,

record and quantify, whenever

specified,

the amount of excess zero and span drift measured

at the 24-hour interval checks; cleaning of optical surfaces exposed to effluent gases; all CMS will be in continuous

operation

and meet minimum frequency of operation

requirements;

all CMS will be installed such that representative measurements of emission

or process parameters

from the affected facility are obtained (procedures for locating CMS in 40 CFR Part 60 Appendix

B); reduction

of data for opacity monitoring;

Adminstrator

may approve alternative

to monitoring

procedures

or requirements upon written application;

alternative

to relative accuracy,

testing specified in performance

specification

2 of 40 CFR Part 60 may be requested

if satisfy specific conditions.§60.19 General notification

and reporting

requirements.

14Ryegate AssOciates,

Incorporated #AOP-95-031 Ryegate Associates

has satisified

the requirements

of 40 CFR Part Subpart A based upon the requirements

of its existing permit to construcl

performance

testing that has been conducted

in the past, the design and construction

of the affected facility, and the CEMS quality assurance

plan required by existing permit. 41) CFR Part 61) Subpart

Db §60.43b(c)(1)

Standard

for particulate

matter.

PM emissions may not exceed 0.10 Ibs/MMBTU

of heat input if the affected facility has an annual capacity factor greater than 30% for wood. Per §60.43b(e),

the annual capacity factor is determined

by dividing the actual heat input to the steam generating

unit during the calendar year from the combustion

of wood, and any other fuels by the potential heat input to the steam generating

unit if the steam generating

unit has been operated

8,760 hours at the maximum

design heat input capacity.

§60.43b(f)

Standards

for particulate matter. Visible emissions

may not exceed 20% opacity (6-minute

average),

except for one 6-minute

period per hour of not more than 27% opacity. Note: Per §60.43b(g),

the particulate matter and opacity standards

apply at all times, except during periods of startu p, shutdown

or malfunction. §60.44b(a) Standard

for nitrogen oxides. Not applicable,

since annual capacity factor for LPG usage restricted

to 10 percent or less and the LPG rated heat input is less than 250 MMBTU/hr. §60.46b Compliance

and performance

testing for particulate

matter.

§60.46b(a) specifies that the PM and opacity limits apply at all times except, periods of startup, shutdown, or malfunction.

§60.46b(b)

and §60.46b(d)

requires an initial performance test to be conducted

to determine

compliance

with PM and opacity standards

as required by 860.8 and procedures

listed within §60.46b(d).

The requirements

of this section were incorporated

into the permit to construct

and initial performance

testing was performed

in May of 1993. Therefo.re,

Ryegate Associates

has complied

with this requirement.§60.48b Emission

monitoring

for particulate

matter. §60.48b(a)

requires the owner or operator subject to the opacity standard

in §60.43b to install, calibrate,

maintain,

and operate a CMS for opacity and record the output of the system.

§60.46b(e)

specifies that the procedures

in 860.13 shall be followed for installation,

evaluation,

and operation of CMS. Also, for facilities combusting

wood the span value for the opacity CMS shall be between 60 and 80 percent. §60.49b Reporting

and recordkeeping

requirements.

This section requires

the Owner/Operator to record and submit the following

information:

§60.49b(a)

notification of initial startup as provided

in 860.7 including:

design heat input of affected facility and fuels to be burned, copy of federally enforceable

restrictions,

and annual capacity factors on various fuels and of the affected facility itself; §60.49b(b)

provide the Administrator with test data from the initial performance

test and performance

evaluation

of the CEMS using the applicable

performance

specifications

in 40 CFR Part 60 Appendix

B; §60.49b(d) maintain

and record amounts

of each fuel burned during each day and calculate the annual capacity

factor for each fuel and calendar

quarter; §60.49b(f) maintain records of opacity;

§60.49b(h)

submit quarterly

excess emission

reports opacity; and §60.49b(o)

maintain

records for a period of two (2) years following

the date of such record. Ryegate Associates

has satisified

the requirements

of 40 CFR Part Subpart Db based upon the requirements

of its existing permit to construct,

performance

testing that has been conducted

in the past, the design and construction

of the affected facility, and the
15Ryegate Associates,

Incorporated #AOP-95-031 CEMS quality assurance

plan required by the permit to construct. Section 504(b) and 114(a)(3)

of the Clean Air Act. Applicability

is undetermined

at this time, since U.S. EPA has not finalized

regulations

implementing

these requirements. If the Agency determines

that Ryegate Associates

is subject to any requirements

within these regulations,

the Agency will reopen the permit to incorporate

any new applicable requirements. B. Equivalency

ans Streamlining Particulate Matter Emission

Standards There are three applicable

PM emission

limits that apply to the Main Boiler: a federal standard of 0.10 Ibs/MMBTU

contained

in 40 CFR Part 60, Subpart Db, Section 60.43b(b)(i), a state standard

of 0.10 gr/dscf corrected

to 12% CO2 contained

in §5- 231(3)(b)(iii) of the Regulations,

and an MSER limit of 0.007 gr/dscf corrected

to 12% CO2. The PM/PM10

limit specified

by MSER is the most stringent,

since it is equivalent to approximately

0.02 Ibs/MMBTU

of heat input. Ryegate

Associates

will be required to comply with the MSER emission

limit. Compliance

with the MSER emission

limit shall be determined

consistent

with the procedures

idehtified

within 40 CFR Part 60 Subpart Db for determining

compliance

with the federal emission

standard.

§5- 231(3)(b)(iii) of the Regulations,

and 40 CFR Part 60 Section 60.43b(b)(i)

are subsumed by MSER as set forth in this subsection. Visible Air Contaminants There are two limits which regulate visible air contaminant

emissions

for the Main Boiler. The state limit is contained

in §5-211(2)

of the Regulations

prohibits visible emissions

of 20% opacity for a period or period(s)

aggregating

to six (6) minutes or more in any hour and at no time may visible emissions

exceed 60% opacity. There is an exception

in §5- 211(3) of the Regulations

which allows visible, emissions

to exceed the 20% and 60% limits during for periods of start-up and Soot blowing for the wood-fired

boiler. However, at no time may visible emissions

during periods of startup and soot blowing exceed 80% opacity. The federal limit in 40 CFR Part 60, Subpart Db, Section 60.43b(e)

limits visible emissions to 20% opacity or less, except for one 6-minute

period in any hour where emissions may not exceed 27% opacity. The federal opacity limits do not apply during periods of startup, shutdown,

or malfunction.

Compliance

with the state and federal limit are measured

differently.

The federal standard

is based upon the use of Reference Method 9 (40 CFR Part 60 Appendix

A), while the state limit is assessed

using proposed Reference Method F-1 (51 Federal Register,

page 31076, August 29, 1986). The Agency considers

the state limit as more stringent that it subsumes

the federal limit. Therefore, Ryegate Associates

will be required to comply with the state opacity limit. This determination

is based upon the following:

(1) all periods of source operation

are covered by the state opacity limits, and (2) the six-minute

averaging

technique

in federal Reference Method 9 results in underenforcement

of an opacity regulation

(see Page 31076 of the proposed

Method F-1 ),

Description of Alternative

Operating

Scenarios

and Related Applicable

Requirements Not Previously

Identified

16Ryegate Associates,

Incorporated #AO P-95-031 Ryegate Associates

has not requested

any alternative

operating

scenarios

as part of its application for a Permit to Operate. V. HAZARDOUS

AIR CONTAMINANTS §5-261 of the Regulations

addresses

the release of HACs into the ambient

air. Unless specifically exempted

from §5-261, a source must quantify its emissions

of HACs regulated

by this rule. Any source whose actual emission

rate of a HAC exceeds its respective

Action Level ("AL") is subject to the rule for that HAC, and the source must then demonstrate

that the emissions of the HAC are minimized

to the greatest extent practicable.

This process is termed the "Hazardous

Most Stringent

Emission

Rate" or HMSER.

An air quality impact evaluation

may also be required to further assess the ambient impacts that may be attributable

to the source. The evaluation

of the air quality impacts is performed

using the Hazardous

Ambient

Air Standards ("HAAS")

or Stationary

Source Hazardous

Air Impact Standard

("SSHAIS")

contained in the Regulations. A. Quantification

of Hazardous

Air Contaminant

("HAC") Emissions Solid fuel burning equipment

(not including

incinerators)

installed or constructed

prior to January

1, 1993, and all fuel burning equipment

which combusts

virgin.liquid

or gasesous fuel is exempted

from review pursuant

to §5-261(1)(b)(ii)

of the Regulations. Based on this exemption,

no fuel burning equipment

used at the Facility qualified

for review of its HAC emissions. Nevertheless, the Ryegate

Power Station may produce emissions

of HACs from the usage of chemicals

associated

with its cooling tower. These emissions

have been quantified and compared

to their respective

ALs in order to determine

if review under §5-261 of the Regulations

was warranted. Emissions of these HACs are summarized

in Table 5-1 below. Calculations

supporting these emission

rates may be found in Appendix

B of this Technical

Analysis.

17Ryegate Associates,

Incorporated

Table 5-1: Hazardous

Air Contaminant

Emissions

#AOP-95-031

Chlorine Dodecylguanidine hydrochloride

(DGH) Ethyl alcohol Ethylene glycol Hydroquinone Isopropyl alcohol Morpho!ine

7782-50-513590-97-164-17-5107-21-1123-31-967-63-0110-91-8

0.036

1.3 0.026 0.025 0.005 2,330 0.090.01 530.2 0.019 4,120 0.006 30 Potassium hydroxide 1310-58-2

0.04

0.84 Sodium h•,droxide 1310-73-2

0.024

0.84

VI.

VII. Note EPA HAP identified in italicized font. Based.upon the emissions

summarized

above, the Ryegate Power Station is not subject to §5-261 of the Regulations.

ao Federal Hazardous

Air Pollutants Although exempt from §5-261 of the Regulations,

the U.S. EPA has identified

fuel burning equipment

as a potential

source that will be regulated

by a "Maximum Achievable Control Technology"

("MACT")

standard

in the future. Emissions

of federally regulated HAPs have been estimated

for the.fuel burning equipment

(see Table 1 in the Appendix B of this Technical

Analysis).

Total HAP emissions

from the Ryegate Power Station are estimated

to be less than 5 tons per year. Therefore,

this Facility does not satisfy the criteria for a major HAP source pursuant

to the federal thresholds

of 10 tpy (individual HAP) and 25. tpy (total HAPs). A listing of federally

regulated

HAPs can be found in §112(b) of the federal Clean AirAct. REASONABLY AVAILABLE

CONTROLTECHNOLOGY At this time, the Agency has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility.

Therefore,

the source is currently

in compliance with this requirement.

The Agency will notify Ryegate Associates

if any applicable RACT requirement

applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensure that Ryegate Associates

complies

with such requirement at that time. COMPLIANCE PLAN & CERTIFICATION A. Description

of the Compliance

Status for Each Applicable

Requirement See paragraph

IV. above.

B. Description

of Corn pliance Certification18Ryegate Associates,

Incorporated #AOP-95-031 Ryegate Associates

will certify compliance

with applicable

requirements

on an annual basis. Annual certification

will be required

as part of the annual registration

of the Facility with the Agency pursuant

to Subchapter

VIII of the Regulations.

Additionally, quarterly reports will be submitted

based upon the requirements

of the existing construction permit conditions

and QA Plan for the CEMS. Compliance Schedule

For Each Applicable

Requirement

for Which the Source is Not in Compliance Not applicable

for this Facility. VIII. PUBLIC PARTICIPATION The Ryegate

Power Station is classified

as a "Title V Subject Source,"

and consequently

any application for a Permit to Operate

for this source is subject to the public participation requirements of §5-1007 of the Regulations. The Agency published

noticed on February

28, 1996, in the Caledonian

Record that it had received an administratively

complete

application

from Ryegate Associates.

The affected state of New Hampshire

was also notified in writing of the receipt of this application

on February

16, 1996. On May 29, 1997, the Agency published

notice in the Caledonian

Record that it received a technically

complete

application

from Ryegate

Associates.

This notice also informed

the public of the Agency'sdraft

decision to issue a Permit to Operate,

and solicited comments

and requests for an informational

meeting.

The affected state of New Hampshire

and U.S. EPA were also notified of the draft decision.

The public comment

period closed at 4:30 p.m. on June 30, 1997. The Agency received no written request for an informational

meeting,

but written were received from U.S. EPA. IX. CONCLUSIONSRyegate

Associates

has demonstrated

the Facility •s in compliance

with all applicable air pollution control requirements. Recommended Draft Permit Conditions

(Air Pollution

Control Division

comments italicized.)Consistent with 10 V.S.A. §556(e) and for the purposes

of reducing

the administrative burden of enforcing

two separate permits, the Agency proposes

to issue the Air Pollution Control Permit to Operate in conjuction

with an administrative

amendment

of Air Pollution Control Permit to Construct

#AP-90-O29g.

The result will be a combined

Air Pollution Control Permit to Construct

and Operate ("Combined

Permit".).

All conditions

of the existing Air Pollution Control Permit to Construct

#AP-90-O29g

will carry over into the new Combined Permit. As part of the administrative

amendment

of the construction

permit, the Agency will update some of the conditions

to.correct

errors or insert text that was inadvertly

left out of the final document.

None of these revisions

will significantly

alter the requirements

of the construction permit. Note the list of standard conditions

will be updated to include the most recent list of standard conditions

prepared

for the operating

permit program.

Revisions

are noted as follows: additional

text is noted in underlined

and italicized font, while deletions

are noted using strikeout

font. NOTE: Some conditions

were changed

as a result of comments during the public comment

period.

See the attached

response

to comments for further detail regarding

the changes.

19Ryegate Associates,

Incorporated #AOP-95-031 CHANGES TO CONSTRUCTION PERMIT

CONDITIONS

0 Continuous

Emission

Monitoring

("CEM") Visible...All systems,

except the NH3 CEMS, shall be installed,

calibrated,

maintained and operated

in such a manner as to meet the requirements

of 40 CFR Part 60, Appendix B, Performance

Specifications

1, 2, 3, 4 and 6 Section ("TSS"). .The NH• CEMS shall meet the TSS CEM Requirements.

Ryegate Associates

shall operate... Correction to replace inadvertent

deletion of reference

to PS 4 while processing

last amendment of construction

permit. Additional

reference

to CEM requirements

for ammonia monitoring

system. (b)(c) ...shall ifttc•dded include at a... Correction of a typographical

mistake. Corn pliance Testing and Monitoring (a) Continuing

compliance

with the particulate

matter,

thereafter. Ryegate Associates

shall conduct such testing and furnish the Agency with a written report of the results of such testing within L-%"-e 9...•0 days after the 7th of Sepetmber

for those years when re-testing

is required. At least... Reduction in the allowable

quantity of time for the completion

and submittal

ofbiennial compliance

test results. Operation, Inspection,

and Maintenance

Procedures (a) All operators

of the Facility shall be trained in the operation

and maintenance of both the fuel burning and air pollution control equipment by qualified personnel Revision of the condition

in order to allow the training of personnel

using qualified persons at the Facility as well as the manufacturer's

of the equipment. NEW OPERATING

PERMIT

CONDITIONS Operating Conditions

and Limitations The Owner/Operator

shall operate the Ryegate

Power Station in accordance with the plans and specifications

submitted

to the Agency on November

3, 1995, and January 29, 1996 and in accordance

with the conditions

set forth herein. Requires applicant

to operate their facility as described

inthe operating

permit application and the terms and conditions

of the Operating

Permit. 20Ryegate Associates,

Incorporated #AOP-95-031 Record Keeping

and Reporting The Owner/Operator

shal notify the Agency in writing of any proposed

physical or operational

change at the Facility which may •ncrease the emission

rate of any air contaminant

to the ambient air. If the Agency determines

that a permit amendment is required,

a new application

and the appropriate

application

fee shall be submitted.

The permit amendment

shall be obtained

prior to commencing any such change. Requirements of Subchapter

V of the Regulations. () All records reports, and notifications

that are required to be submitted

to the Agency by this Permit shall be submitted

to: Air Pollution

Control Division Agency of Natural Resources Building 3 South 103 South Main Street Waterbury, Vermont

05671-0402. Purpose is the identify the appropriate

contact for all reports and etc. that must be sent to the Agency for the permit. The Owner/Operator

shall notify the Agency in writing within five (5) days of any violation, of which it Is aware, of any condition

of this Permit. Requires the Owner

to keep the Agency informed if ff determines

that an emission standard is being violated. Enhanced Monitoring/Compliance Assurance

Monitoring Based upon the applicability

of regulations

promulgated

under authority

granted to the U.S. Environmental

Protection

Agency pursuant

to Sections

504(b) and/or 114(a)(3) of the federal Clean Air Act, the Agency reserves

the right to reopen this Permit to include any necessary

requirements

contained

in said regulations. Notifies the Owner

that the Agency will take action to amend the requirements of the permit in order to incorporate

any applicable

enhanced monitoring or compliance

assurance

monitoring

requirements. Certification of Compliance Ryegate Associates

shall submit a compliance

cetification

at east annually,

or more frequently

if specified

in the applicable

requirement,

which states the Ryegate Associates

was n compliance

with all terms and conditions

of the Permit, including

emission

limitations,

standards,

and work practices.

Such compliance certification

shall include the following: (a)(b)(c)(d) Identification

of each term or condition

of the permit that is the basis of the certification; The compliance

status; Whether compliance

was continuous

or intermittent; The methods

used for determining

the compliance

status of Ryegate
21Ryegate Associates,

Incorporated

Associates

over the re porting period. [§ 5-1015(a)(8)

of the Regulations] #AOP-95-031

22APPENDICESAppendix A Figure Plant Location

(USGS Map) Figure 2 Schematic

of Process Flow Appendix B ALL Support Calculations Appendix C Response to Comments[This. Page Intentionally

Left Blank]

24Determination of Allowable

Emissions

for the Ryeflate

Power Station Allowable emissions is defined under Section 5-101 (11) of the Regulations

as "...the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a)(b) The applicable emission standard contained in the regulations,

if any, or The emission rate or design, operational or equipment standard specified in any order or agreement issued under these regulations that is state and federally enforceable." Determination of Existing Allowable

Emissions:

Pursuant to Section 5-101(11), allowable emissions must be based upon the limitations contained in Air Pollution Control Permit to Construct #AP-90-029g

(issued February 25, 1997 and hereinafter "Permit"). Permit allowable emissions for the fuel burning equipment are defined by the worst case emissions scenano produced when evaluating the combination

of fuel, operating load, and equipment being employed.

For most combustion

air contaminants,

the peak em=ssion rate will be produced when the Main Boiler is operating on a continuous operation (i.e., 8,760 hrs/yr) at full load (i.e., 100% of capacity). It is important to note that Condition (11) of existing Permit prohibits the simultaneous

operation of the Main Boiler with the Emergency Generator. Facility Restrictions

and Assumptions Wood Fuel BTU Content 4,250 BTU/Ib (green wood fuel) Propane BTU Content 2,507 BTU/cubic foot (90,625 BTU/gal) Main Boiler Auxiliary. Boiler

Emergency Generator Maximum Rated Heat Input: 300 MMBTU/hr 5 MMBTU/hr

3.7 MMBTU/hr 50 MMBTU/hr.(Propane) 300 kW; 430 bliP Fuel: Wood'and/or

Propane

Propane Propane Fuel Maximum Firing Rate: 35.3 tons/hr wood

33 ft3/min

25 ft3/min. Operational Restrictions:

None on wood fuel

720 hrs/yr •Note 1)

720 hrs/yr (Note 1) propane limited to 20 million ft3/yr (N°•e 2) [per Condition [per Condition (11) of Permit to Construct] (3)(b) of Permit to Construct] Main Boiler Full load and continuous

operation Particulate Matter (PMIPMI0):

Maximum PM Discharge Rate 0.0070 grains/dscf corrected to 12%C% and 5.0 Ibs/hr [per Condition (5)(a) of Permit to Construct]. Applies at all times regardless of fuel(s) being fired in the Main Boiler. PM/PM10 (5.0 Ibs/hr)(8760

hrs/yr)(ton/2000

Ibs) 22 tons/yr Sulfur Dioxide (SO2): Maximum S% discharge rate based on fuel sulfur content limitations: wood 0.07% by weight [per Findings of Fact (10)(d) and Condition (2) of APC Permit]; propane 10 grains/100 ft [per Condition (3)(c) of Permit to Construct]; Worst case allowable emissions produced while Main Boiler is firing propane to its maximum firing rate of 50 MMBTU/hr and 20 million ft•/yr, and the remaining heat input (i.e., 250 MMBTU/hr)

coming from wood. Usage limits of 50 MMBTU/hr and 20 million ft3/yr are equivalent to 1000 hrs/yr operation on propane. SO2(wood) 0.07 Ibs/ton wood SO2(propane) 0.0014 Ibs/ft propane SO TotalSO2(wood)

[SO2(wood + SO2(prepane)](1000

hrs/yr) + [SO2(wood)](7,760

hrs/yr) [(0.07 Ibs/ton)(250

MMBTU/hr)(Ibs/4250

BTU)(106 BTU/MMBTU)(ton/2000 Ibs/ton)(300 MMBTU/hr)(Ibs/4250

BTU)(106 BTU/MMBTU)(ton/2000

Ibs)(7760 hrs/yr)] (2100 Ibs/yr + 19,000 Ibs/yr)(ton/2000

Ibs) 11 tons/yr Ibs)(1000 hrs/yr)] +[(0.07
SO2(propane) (0.0014 Ibs/ft•)(50 MMBTU/hr)(ft3/2507

BTU)(106 BTU/MMBTU)(1000

hrs/yr) (27,922 Ibs/yr)(ton/2000

Ibs) 14 tons/yr SO• Total

11 tons/yr + 14 tons/yr 25 tons/yr Oxides of Nitrogen (NOx): Maximum NOx Discharge Rate 0.15 Ibs/MMBTU

and 45.0 Ibs/hr [per Condition (7) of Permit to Construct]. Applies whenever wood fuel is contributing

more than 30% of the BTU input to the Main Boiler. Worst case emissions assume wood fuel at maximum capacity and at continuous operation. NOx (45.0 Ibs/hr)(8760

hrs/yr)(ton/2000

Ibs) 197 tons/yr Carbon Monoxide

(CO): Maximum CO Discharge Rate 0.30 Ibs/MMBTU

and 90.0 Ibs/hr [per Condition (8)(a) of Permit to Construct]. Applies whenever wood fuel is contributing

more than 30% of the BTU input to the Main Boiler. Worst case emissions assume wood fuel at maximum capacity and at continuous operation. CO (90.0 Ibs/hr)(8760

hrs/yr)(ton/2000

Ibs) 394 tons/yr
B-1Volatile Organic Compounds

(VOCs): Maximum VOC Discharge Rate 0.03 Ibs/MMBTU

and 9.0 Ibs/hr [per Condition (8)(a) of Permit to Construct].

Applies whenever wood fuel is contributing

more than 30% of the BTU input to the Main Boiler, Worst case emissions assume wood fuel at maximum capacity and at continuous operation VOC (9.0 Ibs/hr)(8760

hrs/yr)(ton/2000

Ibs)

39 tons/yr Auxilia• Boiler Contribution:

Emission Rates based on Table 1.5-1; Section 1.5 of AP-42, Compilation

of Air Polluant Emission Factors, Volume I: Stationary Point and Area Sources, 4th Edition and summarized

in Application for Amendment

to the Air Pollution Permit for Ryegate Power Station, April 1991-.

PM/PMI0

SO

NOx

CO

VOCs Emission Eactor (Ibs/MMBTU)

0.005

0.01

0.15

0.021

0.0055 Emission Rate (Ibs/hr)

0.025

0.05

0.75

0.11

0.028 (tpy) 0.009

0.02

0.27

0.04

0.01

Emission Unit

Main Boiler

Auxiliary Boiler

Total Facility Allowable Emissions (Main Boiler w/Auxiliary Boiler) Air Contaminant PM/pMlo SO

NOx

CO

VOCs Emission Rate(tPY) Fuel Combination Emission Rate(tPY)Emission Rate

22
Wood0.009

22

25Wood+Propane.0.02

25

197
Wood0.27
197

394

39•

Wood wood 0.04 0.01 394 39

Determination of Hazardous

Air Pollutant Emission Rates: No HAP data available for propane fuel, Wood fuel HAP emissions based on AP-42 emission factors published in Table 1.6-4 of Section 1.6 Wood Waste Combustion

in Boilers. Maximum Wood Fuel Firing Rate in Main Boiler 35.3 tons/hr Main Boiler Operation 100% Load and Continuous Emission Factor Contaminant (Ibs/ton) Phenol 1.47 E-05 Polychlorinated dibenzo-p-dioxins

1.2 E-08 Polychlorinated dibenzo-p-furans

5.3 E-08 Acrolein 4.0 E-06 Formaldehyde 8.2 E-03 Acetaldehyde 1.92 E-03 Benzene 9.95 E-03 Naphthlene 3.39 E-03 2,3,7,8-Tetrachlorodibenzo-p-dioxin 3.6 E-11 4-Nitrophenol 2.97 E-06

Emission Rate (Ibs/hr) (tpy) <0.01 0.0023 <0.01 1.8 E-06 <0.01 8.2 E-06 <0.01 0.0006 0.29 1.3 0.07 0.3 0.35 1.5 0.12 0.5 <0.01 5.6 E-09 <0.01 0.0005 Total HAPs from Main Boiler <1 <4

B-2Determination of Emissions From Other Air Contaminant

Sources: Release of Chemical Additives From Cooling Towers and Boiler Water Deaerator Vents: The Ryegate Power Station uses a mechanical

draft cooling tower. Boiler blowdown water is transferred

to the ccoling tower/circulating water. Chemical additives are applied tothe boiler water and circulating water. Some of these additives may be emitted to the ambient air in the cooling tower drift. These same chemical additives may be released via the boiler deaerator vent. VOC emissions from these points are negligible.

See Section E of the application for additional information regarding the derivation of potential HAC/HAP emission rates. Other fuel burning equipment (including:

Diesel Fire Pump, Fuel Yard Maintenance

Building Heater, Main Maintenance Building Heater, Propane Vaporizer Heater). Each of these units are rated less than 3 MMBTU/hr of heat input, and are consequently

classified as insignificant

activities. Emissions need not be considered from this equipment for the purposes of determining

the classification

of the source or modification. Release of VOCs from Chemical and Fuel Storage Tanks: The Ryegate Power Station uses tanks for chemical storage. Each tank is equipped with a static vent. The tanks function in a draw-down capacity to providemakeup to other systems for water treatment. Emissions from this activity are considered negligible. Release of VOCs from Degreasing/Solvent

Tanks: As part of its maintenance

activities, Ryegate Power Station utilizes .two (2) parts cleaning stations of 10 and 15 gallons i• capacity, respectively.

The solvent used drains to a catch sump and is periodically

replaced with a new solution. Emissions from this activity are considered negligible.Release of Fugitive Emissions from Wood Fuel/Ash Handling and Storage, and Haul Roads: Emissions of dust and VOCs from the wood chips are considered unquantifiable

Rather than estimating the emissions, the Agency has focused on the application of reasonable

measures to minimize these emissions.

These measures are prescribed in the Facility's "Wood Chip Management

Plan." Additionally,

transfer of wood fuel to the Main Boiler is conducted via enclosed conveyors

Emissions of dust from vehicular traffic on-site are considered negligible, based on the use of wet suppression

techniques. Ash- Two sources of wood ash: bottom and fly ash. The bottom ash from the furnace grates empties directly into a submerged •(water trough) bottom ash conveyor and is transported

directly to an enclosed ash bunker for storage. The fly ash is conveyed to an ash mixer and conditioner which wets and cools the ash •rior to discharging to the ash bunker. Emissions from this activity are considered negligible due to the use of wet suppression and containment

of the ash material.

B-3VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division
TECHNICAL ANALYSIS

OF AN AIR CONTAMINANT

SOURCE FOR A TITLE V OPERATING

PERMIT #OP-95-032 PIN# SJ95-0113 December 1, 2000 Prepared By: Jennifer

Bryan, Environmental

Engineer

APPLICANT:

SOURCE:

RESPONSIBLE OFFICIAL: APPLICATION CONTACT:

COUNTY:AREA DESIGNATION:

UTM COORDINATES: American

Paper Mills of Vermont,

Inc. Riverside Avenue Gilman, VT 05904 Paper Making, Zurn Boiler American Paper Mills of Vermont,

Inc. Riverside Avenue Gilman, Vermont Jennifer Cusick, Plant Manager Donald Hallee American Paper Mills of Vermont

Inc. Riverside Avenue Gilman, Vermont

05904 (802) 892-5515 EssexAttainment for PM10, SO2, NOx, CO, and Pb Unclassified for O3 49209°° m N°283600 m E Zone 19American Paper Mills of Vermont, Inc. I. INTRODUCTION A. Administrative

MilestonesTable

1: Administrative

Summary #0P-95-032

Date application

received Date application

declared administratively

complete Location where receipt of application

was noticed (date) Affected State(s) noticed of application

receipt (date) Date application

declared technically

complete Date of proposed decision. Location where proposed decision and public comment period were noticed (date) Affected State(s) noticed of draft decision (date)
Location where public meeting was noticed (date) Location of public meeting (date) Deadline for public comments Date application

was submitted

to U.S. EPA Classification of source under §5-401
Classification of operating

permit Facility SIC code(s) Facility SIC code description(s) 11/1/9511/14/95 The Caledonian

Record (11/16/95) New Hampshire

(2/16/96) September 29, 2000 October 5, 2000 (approved) The Caledonian

Record (October 5. 2000)

New Hampshire

New York and Massachusetts!i(October 6, 2000)

none requested.

none requested November 6, 2000 November 7, 2000 §5-401(6)(b): Wood fuel burning equip.>90 Horsepower Title V source2621Paper Mill

414 251

2366

69 9

B. Basis of Review American Paper Mills of Vermont,

Inc. (hereinafter

"APMV")

operates

a paper mill in the village of Gilman, Vermont.

Emission

sources at the mill include the wood fired boiler and the paper machine. The mill is classified

as an air contaminant

source under §5-401 (6)(b) of the Vermont

Air Pollution Control Regulations

("Regulations").

Under this section, a facility is classified

as an air contaminantAmerican Paper Mills of Vermont, Inc. #0P-95-032

source if it operates

wood fuel burning equipment,

larger than 90 Horsepower

("H.P.").

The mill is classified

as a Title V subject source pursuant

to §5-1002

of the Regulations

because its allowable

emissions

of nitrogen

oxides, particulates

and carbon monoxide

exceed 100 tons per year. As a result, APMV is required

to obtain a state and federal operating

permit. The mill was in operation

prior to 1979, and has not undergone

any significant

modifications.

An ammended Nitrogen

Oxide ReasonablyAvailable Control Technology

("NO× RACT") Administrative Order ("AO") was issued on January

9, 1996. The order requires

the facility to limit and monitor emissions from the Zurn wood fired boiler. Therefore,

the mill's allowable

emissions

are based on its administrative

order emission

limits, proposed

operating

restrictions,

and the applicable requirements of the Regulations

and the Code of Federal Regulations

("CFR").

II. FACILITY

DESCRIPTION

AND LOCATION A. Description

of Plant Layout and Surrounding

Area The mill is located in the village of Gilman, Vermont

(see Appendix

A for a site diagram).

The mill complex consists

of approximately

20 buildings,

including

the main building,

various storage buildings, maintenance/garage

building,

boiler house, and a sludge building that serves the facility's wastewater treatment

plant. B. Explanation

of Process The mill is categorized

under Standard

Industrial

Classification

Code 2621 (Paper Mill). It produces a variety of specialty

grade papers from both virgin and recycled

fiber. The mill does not perform any primary pulping;

it produces

paper from fiber produced

.at other facilities rather than converting wood to pulp onsite. Types of paper produced

include commodity

bonds, security base papers, diazo (blueprint)

paper, wallpaper,

label papers, packaging

tapes, latex specialty

papers, text and cover papers, inkjet papers and indigo press papers. C. Process

Equipment

and Stack Information All of the process

equipment

at the mill have the potential

to run continuously

(i.e., 8,760 hours per year). The equipment

parameters

for significant

emission

points are summarized

in Table 2. Other stacks and vents at the facility are listed in Table 3. Insignificant

sources of emissions,

as defined in §5-1002(h)

of the Regulations,

are listed in Table 4. Boilers: The mill operates

five boilers: a primary 180 Million British thermal units per hour heat in put ("MMBtu/hr") Zurn wood fired boiler (installed

in 1977) and four supplemental

Babcock

& Wilcox boilers. The Babcock

& Wilcox boilers fire No. 6 fuel oil with a maximum

sulfur content of 2.0% by weight. All boilers exhaust through a single stack (stack #1 having an outlet 225 feet above its base and 180 feet above the roofline.

The operation

of the boilers results in emissions

of sulfur dioxide ("SO2"), nitrogen

oxides ("NOx"), carbon monoxide

("CO"), particulate

matter ("PM/PM10.),

volatileAmerican Paper Mills of Vermont, Inc. #0P-95-032 organic com pounds ("VOCs"),

and federal Hazardous

Air Pollutants*

("HAPs")

to the ambient

air. The wood fired boiler is supported

by a wood chip storage,

processing

and conveyance

facility. Wood chips and bark are delivered

to the facility and stockpiled

prior to processing.

The wood chips and barkare processed

by a hammer

mill (wood hog), reducing

the size of the chips and bark. The hogged fuel is conveyed

pneumatically,

from the wood hog to the cyclones.

The wood fuel is then stored prior to combustion

in the boiler. The cyclones

and the wood hog are a source of PM emissions.Pulp Processes:

The Pulp process

begins in the Pulp Shed area where both virgin pulp and recycled paper are stored. The pulp purchased

may be either hardwood

or softwood

pulp. The pulp enters the process at the pulpers.

Virgin pulp enters the HILO Pulpers where pulp bales are mixed with water (hydrated),

converting

the pulp to a slurry. Two Morden Pulpers (2000 lb. capacity)

are used to slurry the recycled

paper. The pulp slurry is then pumped

to the Blend Chest where the hydrated pulp is mixed with various additives,

as needed,

depending

the type of paper being produced. The mixed pulp slurry is then. fed into a senes of centrifugal

cleaners

where heavier particles are removed.

Sources

of emissions

in the pulp process

are bleaches

used to whiten recycled paper and chemicals

added in the Blend Chest, resulting

in the release of VOCs, HAPs and Hazardous

Air Contaminants

("HACs")

to the ambient air Paper Machine

Processes:

The cleaned,

blended

pulp slurry enters the paper machine

at the headbox. From the headbox,

the pulp is distributed

onto the forming wire ("fourdrinier")

where the paper sheet begins to form. The fourdriner

is a single layer, 166.75 inches wide, synthetic

fabric that provides

for water drainage

and sheet formation.

The fourdriner

moves at speeds ranging from 500 to 1800 feet per minute.

The moisture

content of the sheet exceeds

99% at this stage of the process.The paper sheet then passes into the press section where the formed sheet is pressed

and smoothed. The first two presses are felted and remove water from the sheet. They are followed by an unfelted

smoothing

press which increases

the smoothness

of the sheet without removing water.The pressed

sheet then enters the main dryer section consisting

of thirty 60 inch diameter

rollers. The rollers are steam heated and range in temperature

from 250 to 350 degrees

F. Steam for the rollers is generated

by the plant boiler. As the sheet passes through the rollers, the moisture content is reduced

to 1.5 to 2.5%. Following the dryers, the sheet enters the size press where various sizes and/or coatings

can be applied to the sheet to enhance

its strength

and overall surface characteristics.

The sizes and/or coatings may contain dyes, chemicals,starch,

latex and clays.

The sheet is then further dried in the after dryer. This process

removes

moisture

added in the

A "hazardous

air pollutant" is defined as any air pollutant listed in Sec. 112(b) of the Clean AirAct, as amended in 1990. 4American Paper Mills of Vermont, Inc. #0P-95-032 coating process.

The after dryer section is similar to the main dryer section and consists

of ten steam heated rollers. The first two rollers are coated with an anti-stick

material to prevent the sheet from sticking to the rollers. The sheet then travels through the-calendar

stack where it passes through two to four rollers under pressure (500 to 1000 psi) to control the thickness

of the final sheet. Finally, the sheets are wound onto individual

size rolls for distribution

to the customer. Sources of emissions

in the paper machine

are the sizings and/or coatings

applied which may contain VOCs, HAPs and/or Hazardous

Air Contaminants

(HACs). Wastewater Treatment

Plant: APMV operates

a wastewater

treatment

plant on site to treat the wastewater generated

by the paper making process.

The treatment

plant includes

one aeration basin, a clarifier,

an emergency

settling basin and a 0.4 MMBtu/hr

space heater.

Sources

of emissions at the treatment

plant are volatile compounds

(VOCs, HACs and HAPs) in the papermaking wastewater

and the space heater combustion

emissions.

Volatile compounds

in the wastewater are included

in the emissions

from the papermaking

process and therefore

do not need to be quantified

again for the wastewater

treatment

plant. As the space heater is considered

an insignificant emission

source, the emissions

are not quantified.

Table 2. Equipment

Specifications

DESCRIPTION AND' STACK SIZEOR CAPACITY

-FUEL -' DATE

PoLL•'•'I•N-

•FLOw RATg' MODEL NUMBER

#

(MAX ALLOWED

TYPE(S)OR'

NSTALLED PROCESSNPUT Main Boiler: Wood

1977

Multiclone

170,000 Zurn acfm Watertube Boiler

180 MMBTU/hr (input) 4500 Btu/Ib Wood as Fired.1,190 HP 4 @ 42.5 MMBTU/hr

# 6 Fuel Oil Babcock & Wilcox each Watertube BoilersPaper Machine

various

350 tons per day of vents finished paper SeineD Starch Silo Starch

210 tons

starch Silo Vent

Jeffrey Wood Hog

56 tons/hour

wood chipsahd bark
Safety-Kleen 30 gallon Solvent

SK 150 Basin Type Degreasers Basin

Solvent Model #34 1920

1920

1997

1978

1994

Uncontrolled

Uncontrolled

Scientific Dust Collector: ModelSP-JX4B82 Radar Long Cone DesignCyclonesUncontrolled 50,000 acfm

482 acfm

5720 acfmeach HE GriT (FT •TEMP. ("F) -•:Grade) •-r

225 ft.(Stack Dia. 9.17ft.)

see Table 3

55.1 feet

50feeteach

450oF

350°F

ambient

ambient

ambientAmerican Paper Miffs of Vermont, Inc. #0P-95-032 oEscRIPTION•ND':• ,•sTACK -sIZEoRCAPACITY

FUEL

, -OATE

POLLUTION

FLOW RATE STACK

EXIt-" MODELNUM•E•:'•r': #• :•'1 o(MAX.ALLO•ED)•

'1- TYPE(sioRr

I-INSTALLED

"1" CON•'ROI.="

(ACFM)

HEIGHT (F'• TEMP. (°F) • •"."•, :'• / • PROCESS-"

•:• -• :•-•EQUI•MENT - Above I -•'• I INPUT •1

I

I

I-Grade)

30 gallon Solvent

SK 150

1994

Uncontrolled ambient Safety-Kleen Basin

Solvent Basin Type Degreaser Model #23In addition to the equipment

listed in Table 2, APMV has identified

a number of other stacks and vents (see Table 3). These stacks and vents emit air contaminants

from the paper making process in addition to the steam driven off as the paper is produced.

These stacks and vents emit negligible quantities of air contaminants.

Any VOCs, HAPs, or HACs emitted from these vents and stacks are quantified

by the process source (ie. paper machine),

on a mass balance basis, rather than by emission point.

Table 3: Other stacks and vents.

Heatex UnitPaper Machine Dryer 1- Section Paper Machine Dryer 2- Main Section Paper Machine Dryer 4 -Section 3 50 Paper Machine Dryer 3- Main Section 505O Room Vent -Section Room Vent Section 2 (1) Room Vent Section 2 (2) Room Vent Section 3 Winder Vent (1) Winder Vent (2) 505050 120,00030,00030,00030,00030,00020,00017,00017,000 50 17,000 50 12,0008,00020,00020,0006,0007,000 5050505O Sky Vent (1)Sky Vent (2) Exhaust Fan Room Vent PM Vacuum Pump 505O 18,OOO

6American Paper Mills of Vermom, Inc. #0P-95-032 D. Description

of Air Pollution

Control

Equipment There are currently

four air pollution

control devices at the mill: three cyclones,

one multiclone

and one baghouse.

Two of the cyclones

control particulate

emissions

from the wood chip handling system. The multicyclone

controls particlulate

emissions

from the exhaust of the Zurn boiler. The baghouse controls

emissions

from the starch silo. E. Description

of Compliance

Monitoring

Devices The NOx RACT Administrative

Order requires the Facility to operate compliance

monitoring

devices on the Zurn boiler. The continuous

emission

monitoring

system ("CEMS")

measures

both exhaust flow rate and concentrations

of CO, NOx, and oxygen in the flue gas exiting the boiler. III. QUANTIFICATION

OF POLLUTANTS A. Operating

Restrictions 1. Proposed

in Permit Application APMV has proposed

to limit the mill's allowable

emission

of VOCs from the wet end of the paper machine to 49 tons per year in order to not be subject to §5-253.20

of the Regulations:

VOC RACT. The applicant

divided the paper machine

into two sections,

the wet end, where the paper manufacturing begins, and the dry end, where the finish coatings

are applied. The permit application also stated that the dry end of the paper machine

was subject to §5-253.10

of the Regulations: Paper Coating.

The Agency

has determined

that APMV is not subject to §5-253.10

of the Regulations, Paper Coating,

as this regulation

applies to coating units that apply coatings

to finished paper products.

As APMV applies coatings

as part of the paper making process,

the Facility is not subject to this regulation.

Consequently,

the paper machine

will be regulated

as a single unit, not in two parts, the wet and dry ends. The Agency proposes

to limit the paper machine

to 49 tons per year of VOCs. This VOC limit will be complied

with by using the following

reporting

and.recordkeeping

procedures: The mill would maintain

a spreadsheet

for each dye or process chemical

containing

VOCs. These spreadsheets

would contain the VOC content and usage rate of each dye or chemical.The mill would maintain

an inventory

of all process

chemicals

that could emit HACs. This inventory would contain the name of each process

chemical,

its HAC constituents,

and the emission rate of each HAC. The mill's environmental

engineer

would review the Material Safety Data Sheet (MSDS) for all new chemicals

entering

the mill. Any chemical

containing

VOCs or HACs would be evaluated for use and placed in the appropriate

inventory

(see (1) and (2) above).

An estimate of hourly use would be given to determine

the potential

for an emissions

violation.American Paper Mills of Vermont, Inc. #0P-95-032 4. The mill would maintain

a 12-month

rolling sum of emissions,

and submit this information to the state by February

1 each year as a part of the annual emissions

inventory

submittal. As long as APMV complies

with the recordkeeping

and reporting

procedures

proposed

in its application, the proposed

VOC limit will be practically

enforceable.

These recordkeeping

and reporting procedures

will be required

under the Title V permit (however,

the permit will require semiannual, rather than annual, reporting).

It should be noted that the VOC emissions

from the mill's boiler and degreasers

will not count towards the 49 ton per year limit. The approval

of this VOC limit does not exempt APMV from the provisions

of Subchapter

V of the Regulations. In other words, any physical

change or change in the method of operation

of the mill that increases

actual emissions

of VOCs will continue

to require Agency review in accordance

with Subchapter V. 2. Existing

Operating

Restrictions:

Administrative

Order The Administrative

Order (AO) issued January 9, 1.996 contains

operating

restrictions

for the Zurn boiler and the four Babcock

and Wilcox boilers. The AO limits NOx emissions

from the Zurn boiler to 0.3 Ibs/MMBtu

and a mass discharge

rate of 54 Ibs/hr, based on a twenty four hour rolling average (except during startup or shutdown).

During start-up and shutdown

the nitrogen

oxide emissions from the Zurn wood-fired

boiler are limited to 54 Ibs/hr based on a one hou r averaging

time. The CO emissions from the boiler are limited to 3 Ibs/MMBtu

and 540 Ibs/hr, based on a twenty four hour averaging time, except for start-u p.and shutdown.

During startup and shutdown

the CO emissions are limited to 1100 Ibs/hr based on a one hour averaging

time. Operation

of the four Babcock

and Wilcox boilers is limited to 5% of capacity

(495,900

gallons).

APMV is required

to maintain

records of fuel use in the Babcock

and Wilcox boilers to demonstrate

compliance

with the 5% limit. The AO required APMV to install, calibrate

and operate a CEMS on the exhaust from the wood-fired boiler. APMV was required

to develop,

submit and follow a Quality Assurance

Plan (QA Plan)for the CEMS. Data collected

by the CEMS is submitted

to the Air Pollution

Control Division quarterly.

The AO required

APMV to develop,

submit and follow a Malfunction

Abatement

Plan to prevent, detect, and correct malfunctions

or equipment

failures that could result in excess emissions

from the wood-fired

boiler. APMV is also required

to minimize

the generation

of air contaminants

through good operating

practices

and optimization

of overfire and underfire

air.American Paper Miffs of Vermont, Inc. #0P-95-032 B. Identification

of Insignificant

and Exempt

Activities Activities which qualify as "insignificant

activities"

under §5-1001 (h) of the Regulations

must be listed in the operating

permit application,

but the emissions

from such activities

need not be considered for determining

the applicabilityofSubchapterX. The gasoline,

diesel fuel, No. 6 fuel oil and propane tanks at the facility qua!ify as insignificant

activities.

In addition,

the three distillate

fuel space heaters, the mill analytic

lab, screw press furnace,

propane

forklifts,

vehicle storage

and a maintenance areas and diesel tractors

are also insignificant

activities.

Table 4 lists the specifications of the insignificant

emission

sources. Table 4: Insignificant

Emission

Sources

Peerless Space Heater Powermatic Space Heater (WWTP) No. 6 Fuel Oil Storage Tank Fixed Roof Type w/vent Ecovault Diesel Fuel Storage Tank Fixed Roof Type w/vent Propane Storage Tank w/pressure release vent

0.12 MMBtu/hr 0.4 MMBtu/hr

combined 150,000 gallons 10,000 gallons 1,163 gallons

Ecovault Gasoline

Storage Tank

1,000 gallons Fixed Roof Type w/vent Mill Analytical

Lab Propane Forklifts Vehicle Maintenance

and Storage AreaDiesel Tractors No. 2 Fuel Oil

1968i975 .No. 2 Fuel Oil No. 6 Fuel Oil Diesel Fuel

19671993 Pmpane 1979 Gasoline 1993

It should be noted that a finding that a process or piece of equipment

is an "insignificant

activity" does not relieve the owner or operator

from the responsibility

of complying

with any applicable requirements associated

with said process

or equipment.

9American Paper Mills of Vermont, Inc. #0P-95-032 C. Allowable

Emissions

from Facility Allowable emissions

of SO2, NOx, CO, PM/PM10,

and HAPs generated

by the mill's boilers, have been estimated

using emission

factors published

by the EPA in its Compilation

of Air Pollutant Emission Factors.

Volume h Stationary

Point and Area Sources,

5th Edition, AP-42, NOx RACT Administrative Order and the Regulations.

The emissions

estimates

for the mill are summarized in Table 5, and all supporting

calculations

are provided

in Appendix

B of this document.
Table 5: Summary

of allowable

emissions

from all processes.

Boiler: W(•od Boilers: No 6 Fuel OilFuel Wood Cyclones Starch Silo

778

DegreasersPaper Machine Totals

85

23713.6

251 366

19

4 t.2 9.6

0.1

0.03 26

2366 1.1

414

49-69

10American Paper Mills of Vermont, Inc. #0P-95-032 IV. APPLICABLE

REQUIREMENTS A. Citation

and Description

of all Applicable

Requirements Section 5-1006(e)(4)

of the Regulations

requires the owner/operator

of a stationary

air contaminant source to submit a demonstration

of compliance

with all applicable

air pollution

control requirements. These requirements

include state and federal regulations

and the requirements

of any construction

permit issued under 10 V.S.A. §556 and §5-501 of the Regulations. Each applicable

requirement

(except §§ 5-261 and 5-1010 of the Regulations)

is discussed

below, including its test method and current compliance

status. Compliance

with §5-261 and §5-1010

of the Regulations

is discussed

separately

in sections

V and VI of this document,

respectively. The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the owner/operator.

Any statements

and conclusions

regarding

the compliance status contained

herein are not binding against the state of Vermont

in any future legal or administrative

proceedings.

1. VermontAir

Pollution

Control

Regulations §5-201 Open Burning

Prohibited:

This regulation

prohibits

open burning of combustible materials except in conformity

with Subchapter

II of the Regulations. APMV has stated that the mill is in compliance

with this regulation,

and will continue

to comply in the future. APMV •has a policy prohibiting

onsite open burning.

The Agency willverifycompliancewith this requirement

in the future during its own inspections

of the mill. Additionally, the Agency investigates

all open burning complaints

that it receives

to determine

if there is a violation.§5-211(1) Prohibition

of Visible Air Contaminants

Installations

constructed

prior to April 30, 1970: This regulation

applies to the four Babcock

and Wilcox oil fired boilers. It states that APMV shall not emit any visible air contaminants

for more than a period or periods aggregating six minutes

in any hour having a shade, density, or appearance

greater than 40% opacity. At no time shall visible air contaminants

have a shade, density, or ap oearance

greater than 60% opacity. The test method used to determine

compliance

with this standard

is Method F,1 (proposed)

of Title 40 CFR, Part 52 (51 FR 31076; 8/28/86). Compliance with this regulation

will be determined

the Continuous

Opacity Monitoring

System ("COMS") to be installed

and operating

within 180 days of Permit issuance.

11American Paper Mills of Vermont, Inc. #0P-95-032 §5-211 (2)- Prohibition

of Visible Air Contaminants

-Installations

constructed

subsequent to April 30, 1970: This regulation

applies to the Zum wood fired boiler, cyclones

and starch silo. It states that APMV shall not emit any visible air contaminants

for more than a period or periods aggregating six minutes in any hour having a shade, density, or appearance

greater than 20% opacity. At no time shall visible air contaminants

have a shade, density, or appearance

greater than 60% opacity. Compliance with the opacity limit for the Zurn wood-boiler

will be determined

by the Continuous Opacity Monitor System ("COMS")

that APMV is required to install and operate within 180 days of Permit issuance.

Compliance

for the cyclones

and starch silo will be determined

by weekly observations using Method F'I, (pr6posed)

of Title 40 CFR, Part 52 (51 FR 31076; 8/28/86). §5-211(3) Prohibition

of Visible

Air Contaminants

Installations

constructed subsequent to April 30, 1970. Exceptions

Wood Fuel Burning

Equipment.

(a) During normal startup operations,

emissions

of visible air contaminants

in excess ofthelimits

specified above may be allowed for a period not to exceed one (1) hour; (b) During normal soot blowing operations, emissions

of visible air contaminants

in excess of the limits specified

above may be allowed for a period not toexceed

30 minutes during any 24 hour period; (c) At no time shall the visible air contaminants

allowed under this subsection

have a shade, density, or appearance greater than 80% opacity (No. 4 of the Ringelmann

Chart).; and (d) Any wood fuel burning equipment that has a rated output of 40 I-I.P. or less shall not be subject to this regulation. Compliance with these opacity standards

shall be determined

by the COMS to be installed within 180 days of Permit issuance. §5-221(1)(a) Prohibition

of Potentially

Polluting

Materials

in Fuel, Sulfur Limitation:

This regulation applies to the fuel combusted

in the Babcock

and Wilcox boilers and the propane forklifts. It prohibits

the combustion

of any fuel containing

more than 2.0% sulfur by weight. The test method

used to determine

compliance

with this standard

is a fuel analysis

using procedures prescribed

by the American

Society for Testing and Materials. APMV has stated that it complies

with this standard

by purchasing

No. 6 fuel oil containing

less than 2.0% sulfur, and will continue

to do so in the future. The propane

combusted

at the mill has a negligible

sulfur content.

APMV has stated that it can demonstrate

compliance

with this standard by maintaining

records of fuel vendor certificates. The continued

use of these fuels, in conjunction

with proper recordkeeping,

is sufficient

to ensure compliance

with this regulation

in the future. §5-221(2) Waste Oil. "No person shall cause or permit the use, purchase,

sale or exchange in trade for use as a fuel in fuel burning equipment

in Vermont

of any waste oil unless: (i) (ii) The waste oil has properties

and constituents

within the allowable

limits set forth in Table A prior to blending;

and (iii) ...(iv) ...(v) ... and(vi) The seller and user comply with the requirements

of (the waste oil section) of the Vermont

Hazardous

Waste Management

Regulations." APMV does not burn waste oil and therefore

is not currently

subject to this regulation.

All waste oil generated

at the facility is recycled

forrerefinement.

12American Paper Mills of Vermont, Inc. #0P-95-032 §5-231(1)(b) Prohibition

of Particulate

Matter; Industrial

Process

Emissions.

"In cases where process

weight is not applicable

as determined

by the Air Pollution

Control Officer, the concentration of particulate

matter in the effluent gas stream shall not exceed 0.14 grams per cubic meter (0.06 grains per cubic foot) of undiluted

exhaust gas atstandard

conditions

on a dry basis. In the case ofwood processing

operations,process

weightis

not applicable,

and instead, the concentration

standard

specified

in this subsection

shall apply."

Compliance

with this emission standard

shall be determined

in accordance

with Title 40 CFR Part 60, Appendix

A, Reference Method 5 or an alternative

method approved

in writing by the Agency. This emission

standard

applies to starch silo and the two wood chip .cyclones. The Agency will assess compliance

with this sectiOn in the future as follows:

(1) APMV will be required to properly

operate

and maintain

its dust collection

systems

including

fabric filter collector and cyclones;

(2) visual observations

of each exhaust will be conducted

during Agency inspections of the Facility, and (3)weekly

observation

of the starch silo, and cyclones

exhausts by staff at the Facility. §5-231(3) Prohibition

of Particulate

Matter (Combustion

Contaminants):

Section 5- 231 (3)(a)(ii) applies to the four (4) Babcock

and Wilcox boilers rated at 42.5 MMBtu/hr

each. It states that particulate

emissions

from fuel burning equipment

having a rated heat input of greater than 10 MMBtu/hr

but less than 250 MMBtu/hr

may not exceed the limit determined

using the following

formula:
Ib

10 {130"47039(1°g

10 HOB 0.16936] EpM [hr.•-MBt•/I

[•

Based on the formula,

the boiler is limited to 0.25 pounds per hour per MMBtu and 11 pounds per hour per boiler. The test method used to determine

compliance

with this standard

is Reference

Method 5 (40 CFR Part 60, App. A). Compliance determinations

will be based on the following: (1) The Agency will conduct visual observations

of the opacity of the exhaust during its own inspections of the mill in the future. If visible emissions

are observed

to be in excess of the limits specified

in §5-211 (2) of the Regulations,

the Agency may require APMV to perform a stack test to verify compliance

with the particulate

emission

standard

or take other corrective

measures.

§5-231(3)(b) Prohibition

of Particulate

Matter; Combustion

Contaminants.

"A person

13American Paper Mills of Vermont, Inc. #0P-95-032 shall not discharge,

cause, suffer, allow, or permit the emission

of particulate

matter caused by the combustion

of wood fuel in fuel burning equipment

from any stack or chimney: In excess of 0.45 grains per dry standard

cubic foot (gr/DSCF)

of exhaust gas corrected to 12% CO2 in any combustion

installation

that has a rated output of greater than 90 H.P. which commenced

operation

prior to December

5, 1977. In excess of 0.20 gr/DSCF

corrected

to 12% CO2 in any combustion

installation

that has a rated output of greater than 90 H.P., but less than 1300 H.P., which commences operation after December

5, 1977." Compliance with this emission

standard

shall be determined

in accordance

with Title 40 Code of Federal Regulations

Part 60, Appendix

A, Reference

Method 5 or an alternative

method approved in writing by the Agency. This emission

standard

applies.to

the Zurn wood-fired

boiler which is rated at 1,190 H.P. Pursuant to {}5-101 of the Regulations,

H.P. is defined as a unit that is equal to 10 square feet of boiler heating surface.

Therefore,

the emission

standard

of 0.20 gr/DSCF

applies to this unit. The calculated

permit allowable

particulate

emissions

from the wood boiler is 0!20 gr/DSCF. The Agency will assess compliance

with this standard

in the future during any inspections

of the Facility. The inspections

will include confirmation

of the proper operation

and maintenance

of the fuel burning equipment

and the multicyclone

in addition to visual observations

of thestack exhaust. AMPV will be required to perform a stack test within 180 days of Permit issuance

and then retest every three years. §5-231(4) Prohibition

of Particulate

Matter; Fugitive

Particulate

Matter.

"Aperson

shall not cause, suffer, allow, or permit any process operation

to operate that is not equipped

with a fugitiveparticu/ate matter control system.

Aperson

shall not.cause,

suffer, allow, or permit any materials to be handled,

trans ported, or stored; or a building,

its appurtenances,

or a road to be used, .constructed,

altered, repaired

or demolished

without taking reasonable

precautions

to prevent particulate

matter from becoming

airborne.

Public roads will not be subject to this section unless a public nuisance

is created." This regulation

applies to plant yard at the Facility.

Based on the application

submittal

and information available

to the Agency,

the Facility is currently

in com pliance with this regulation. The Agency will require the use of reasonable

precautions

such as the application

of wateror surfactants to the plant yard as necessary.

The Agency will assess compliance

with this requirement during any inspections

of the Facility,

and will require the use of additional measures if found necessary

during a compliance

inspection.

§5-241 (1) and (2) Prohibition

of Nuisance

and Odor: These regulations

apply to the entire

14American Paper Mills of Vermont, Inc. #0P-95-032 mill. Section 5-241 (1) prohibits

the emission

of air contaminants

in quantities

which would cause injury, detriment,

nuisance,

or annoyance

to any considerable

number of people or to the public. Section 5-241 (2) prohibits

the discharge

of objectionable

odors beyond the property

line of a premises. APMV has stated that it complies

with these regulations

and will continue

to comply in the future. APMV based this compliancedetermination on ongoing monitoring

by mill personnel. The Agency will verify compliance

with this requirement

in the future during its own inspections of the mill. Additionally,

the Agency investigates

all nuisance

and odor complaints

that it receives to determine

if there is a violation. §5-253.5 Stage Vapor Recovery

Controls

at Gasoline

Dispensing

Facilities.

The owner or operator

of a gasoline

dispensing

facility which receives

deliveries

from account trucks shall fill tanks by submerged

fill only. The gasoline

storage tank at the facility is subject to this regulation.

As the gasoline

storage tank is filled by a submerged

fill pipe, the facility is in compliance

with this regulation. §5-253.10 Paper Coating:

This regulation

limits emissions

of VOCs from paper coating units. It appears

that it was intended

to address

coating units that apply coatings

to finished paper products. Since APMV uses coatings

as a part of its paper making process,

this regulation does not apply to the mill. §5-253.14 Solvent

Metal Cleaning:

This regulation

applies to the three Safety-Kleen

Model degreasing units at the Facility.

The degreasers

are subject to the following

work practice standards set forth in §§5-253.14(c)(1

)(iv)-(x) of the Regulations. (a) Provide

a permanent,

legible,

conspicuous

label, summarizing

the operating requirements; (b) Store waste solvent in covered

containers; (c) Close the cover whenever

parts are not being handled

in the cleaner; (d) Drain the cleaned

parts until dripping

ceases; (e) Supply a solvent spray, if used, that.ensures

a solid fluid stream at a pressure

that does not exceed 10 pounds per square inch gauge; (f) Degrease

only materials

that are neither porous nor absorbent;

and (g) Cease operation

of the unit upon the detection

of any visible solvent leak until such solvent leak is repaired. APMV has stated that it is in compliance

with all of the requirements

of §5-253.14

of the Regulations

15American Paper Mills of Vermont, Inc. #0P-95-032 Subcha pter VIII Registration

of Air Contaminant

Source:

This Subchapter

requires

the operator of a stationary

source to register it with the Agency if it emits more than 5 tons of any and all air contaminants

per year. The operator

of a source subject to registration

is required to submit information

regarding

its operations

by February

of each year, and pay a fee based on its quantity

of emissions. APMV currently

participates

in the registratioh

program

and has stated that it will continue

to com ply in the future. 2. Administrative

Order Issued January

9, 1996 1 ) AMPV shall properly operate and maintain

its fuel burning equipment

in order to minimize

the generation of air contaminants. a) The use of good operating

practices

for fuel fed into the wood boiler (including

burning only uncontaminated

wood with a moisture

content not to exceed 60% by weight and with a size not to exceed two (2) inches by five (5) inches). b) Optimization

of overfire and underfire

air system to minimize

the generation

of CO and NOx. APMV submitted

a report to the Agency determining

operating

parameters

fo.r this requirement on November

15, 1995 and March 7, 1996. The reports determined

that the proper operating

parameters

for the Zurn wood-fired

boiler at steam loads between

60,000 Ib/hr and 90,000 Ib/hr are: OxygenOverfire/Underfire Air Ratio:

6.5 to 8.0% 40/60 to 70/30 2) Emission

Limitations

Table 6: NOx RACT Emission

Limitations

CO 0.3 Ibs/MMBtu

and 54 Ibs/hr
54 Ibs/hr

3.0 Ibs/MMBtu

and 540 Ibs/hr

Rolling 24 hour

Continuous EmissionMonitoring 1 hour average

System Rolling 24 hour

Continuous EmissionMonitoringsystem

At all timesexcept start up and shutdown Start up and shutdownAt all timesexcept.start up and shutdown

16American Paper Mills of Vermont, Inc. 1100 Ibs/hr

1 hour average 3) Continuous

Emission

Monitoring

("CEM") #0P-95-032 Start up and shutdown a) APMV shall equip he Zurn wood fired boiler with continuous

emission

monitoring

equipment which will measure

and record the concentrations

of CO, NOx,and

CO2 or 02 in-the flue gas exiting the Zurn boiler. b) All CEMS shall be operated

and maintained

as specified

below: i) All CEMs shall be installed,

calibrated,

maintained

and operated

in accordance

with 40 CFR Part 60, Appendix

B, Performance

Specifications

2,3,and 4; 40 CFR Part 60 Appendix F Quality Assurance

Procedures

and the Air Pollution

Control Division Technical

Services Section's ("TSS")"Continuous

Emission

Monitoring

Requirements",

as amended. ii) All CEMS shall be installed

according

to manufacturer's

specifications

and shall be operational on before January

15, 1995. The CEMS shall successfully

complete

the. initial Performance Specification

Test Procedures

by May 1, 1995. iii) All CEMS must record valid data during all source operating

times except for periods of established quality assurance

and quality control procedures,

preventive

maintainance,

or unavoidable malfunction.

Nevertheless,

the CEMS must record valid data for at least 90% of the source operating

time within any quarter of the calendar

year. iv) APMV shall develop,

implement

and maintain

for the CEMS a Quality Assurance

Plan which satisfactorily

documents

operations

pursuant

to state and federal requirements. APMV shall review the Plan annually. v) AMPV shall submit summary

reports for each calendar

quarter within 30 days after the close of the quarter. CEMS data for NOx and CO shall be reported

in units of Ibs/MMBtu

and Ibs/hr, as 24 hour rolling averages

calculated

on an hourly basis; 4) AMPV shall not operate its four oil-fired boilers in excess of five (5) percent of their total capacity on a rolling twelve (12) calendar

month basis. 5) AMPV shall develop and utilize a malfunction

abatement

plan for those systems/operations

that affect regulated

emissions

for its Zurn wood-fired

boiler.

Federal Air Pollution

Control

Regulations NSPS and NESHAPs:

No National

Emissions

Standards

for Hazardous

Air Pollutants (NESHAPs) or New Source Performance

Standards

(NSPS) apply to the mill.

17American Paper Mills of Vermont, Inc. #0P-95-032

EPA has proposed

three MACT standards

(also known as NESHAPs)

for the pulp and paper industry. MACT

and MACT III were combined

into one standard

and signed into law in November 1997. This standard,

known as the National

Emission

Standards

for Hazardous

Air Pollutants from the Pulp and Paper lndustry

(40 CFR, Part 63, Sub part S), regulates

emissions from processes

such as chemical

and semichemical

pulping, bleaching,

wastewater

treatment, mechanical pulping,

secondary

fiber deinking,

nonwood

pulping, and paper making.

Subpart S applies to pulp, paper, and paperboard

mills that are major hazardous

a•r pollutant

(HAP) sources. Although

some of the activities

at APMV's

facility fall into the regulated

categories,

it is not subject to the regulation

because

it is not a major HAP source. MACT II, which has not yet been finalized,

will address

combustion

sources at pulp and paper mills (other than virgin fuel combustion).

Sincethis

facility does not have any such sources, MACT II will not apply to the mill. 40 CFR Part 64 Compliance

Assurance

Monitoring:

Pursuant

to requirements

concerning enhanced monitoring

and compliance

certification

under the C/ean Air Act (•'CAA,),

EPA promulgated new regulations

and revised regulations

on October

22, 1997. These new requirements implemented

compliance

assurance

monitoring

("CAM")

for major stationary sources of air pollution

that are required

to obtain operating

permits under Title V of the CAA. Subject to certain exemptions,

the new regulations

require owners or operators

of such sources to conduct

monitoring

that satisfies

particular

criteria established

in the rule to provide a reasonable assurance

of compliance

with applicable

requirements

under the CAA. Monitoring is proposed

to focus on emissions

units that rely on pollution

control device equipment

to achieve compliance

with applicable

standards.

The regulations

also provide procedures

for coordinating these new requirements

with the operating

permits program

regulations. As a result of comments

received

during the rule making process and the lengthy delay in the adoption of the CAM rule, U.S. EPA provided

an extended

implementation

schedule

for this rule. Facilities which had submitted

a complete

operating

permit application

prior to April 20, 1998, were not required

to address CAM as part of their initial operating

permit application

unless they proposed to make significant

changes

to the facility subsequent

to this date and the facility operated "large" pollutant

specific emission

units ("PSEU").

A "large PSEU" is defined as a unit with post control emissions

greater than or equal to the major source threshold,

APMV was not required to address

CAM as it had submitted

an administratively

complete

operating

permit application prior to April 20, 1998. §64.2 in 40 CFR Part 64 specifies

that each pollutant

specific emission

unit at a facility that meets a three-part

test is subject to the requirements

for CAM. An emission

unit must: (A)(B)(C) be subject to an emission

limitation

or standard, use a control device to achieve compliance,

and have pre-control

emissions

that exceed or are equivalent

to the major source threshold in 40 CFR Part 70 (i.e., 10 tpy individual

HAP, 25 tpy total HAPs, 50 tpy VOCs, or 100 tpy for any other air contaminant).

18American Paper Mills of Vermom, Inc. #0P-95-032 Note that the term "control device" means equipment,

other than inherent process equipment, that is used to destroy or remove air pollutant(s)

prior to discharge

to the atmosphere.

The term "control device" does not include passive methods

such as lids or seals, use of low-polluting fuels or inherent

process equipment

provided

for safety or material recovery.

Additionally,

the CAM rule provides

some exemptions,

such as an exemption

for any affected

facility subject to an NSPS or NESHAP

promulgated

after November

15, 1990. The Zurn wood-fired

boiler meets the three part test for CAM. APMVwill

need to address CAM for the Zurn wood-fired

boiler upon operating

permit renewal. B. Citation

and Identification

of Requirements

For Which a Permit Shield Provision

Has Been Requested Pursuant to §5-1015(a)(11

of the Regulations,

an owner/operator

may request to be shielded from specific state or federal requirements

which do not apply to the subject source.

If the applicability of a regulatory

requirement

is unclear to the applicant,

when appropriate,

the Agency may grant a permit shield stating that the requirement

does not apply to the source.

Once a permit shield is granted,

the Agency may not initiate any enforcement

action against the Facility based upon a regulation

or standard

covered

by the permit shield. The Agency would be required to amend the Permit to Operate

and incorporate

the applicable

requirement

prior to initiating any enforcement

action for non-compliance

with the applicable

requirement.

The Agency's permit shield determinations

are based upon the information

submitted

by the owner/operator in its operating

permit application.

The resulting

permit shield shall be effective only with respect to activities

disclosed

in the application. It is the Agency's

procedure

to grant permit shields only for those requirements

or standards which conceivably

could apply to the Facility, and the Agency has made a determination

that such requirement

does not in fact apply. The Agency does not intend to grant permit shields for those requirements

that clearly do not apply to the Facility.

For example,

an asphalt plant will not be granted

a permit shield from a regulation

applying

to a dry cleaning

operation. Additionally, the Agency and the U.S. EPA do not favor granting

permit shields from broad requirements such as a section of the Clean Air Act or an entire Subpart

of the federal regulations in 40 CFR. In the words of the U.S. EPA, "... the intended

purpose

of a negative applicability determination

is to memorialize

a decision

where applicability

of a certain regulation is somewhat

unclear without extensive

knowledge

of the regulations

and investigation

of the relevant facts." APMV has requested

to be shielded

from several potentially

applicable

requirements.

The Agency will grant a permit shield for the state and federal regulations

listed in Table 7 below as granted. The permit shields shall be binding only with respect to the activities

disclosed

in APMV's application.

19American Paper Mills of Vermont, Inc. #0P-95-032 Table 7:

40 CFR, Pad 60.40 et seq. NSPS, Subpa• D

40 CFR, Part 60.40 et seq. NSPS, Subpart Da 40 CFR, Part 60.40a et seq. NSPS, Subpart Db

40 CFR, Part 60.40a et seq. NSPS, Subpart Dc

40 CFR, Part 60.280 et seq NSPS Subpart BB

40 CFR, Part 60.110et seq NSPS Subpart K

40 CFR, Part 60.110a et seq NSPS, Subpart Ka

40 CFR, Part 60.110b et seq NSPS Subpart Kb

40 CFR, Pai't 60.150, et seq. NSPS Subpart O

40 CFR• Part 60, et seq. NSPS Subparts B through VVV

40 CFR, Part 61 NESHAPS Subparts A through. FF

Permit Shield Determinations

Standards for Performance

for Fossil Fuel-Fires Steam Generators

(>250 MMBtu/hr)standards for Performance

for Electric Utility Steam Generators

(>250 MMBtu/hr) Standards of PerfOrmance

forIndustrialCommemial Steam Generating Units (>100 MMBtu/hr and constructed

or modified after June 19, 1984) Standards of Performance

for Small Industriai-C0mmercial-institutional Steam Generating Units (10<MMBtu/hr<100

and constructed, reconstructed

or modified after June 9, 1989) Kraft Pulp Mills. This subpart applies {o specific process in kraft pulp mills that were constructed,

reconstructed

or modified after September 24, 1976. Petroleum Storage Vessels. (Capacity >40,000 gal and constructed

on or after June 11, 1973) Petroleum Storage Vessels. (Capacity >40,000 and constructed,

or installed and or after May 18, 1978) Volatile. Organic Liquid Storage Vessels. (Capacity >40 rn and constructed

on or after July 23, 1984) Sewage Treatment Plants (Applies to incinerators at sewage treatment facilities)Facility specific New Source Performance Standards applying to sources of specific air emissions. National Emission Standards for Hazardous Air Pollutants. This subpart applies to emission of specific hazardous air pollutants from seven specifi c source types.

Granted

Granted

Granted

Granted

Granted

Granted

Granted

Granted

Denied

Denied

Denied

No boilers >250 MMBtu/hr

All Boilers were installed prior to June 19, 1984 and have not been modified.All Boilers were installed prior to June 9, 1989No modifications

have taken place. APMV is a non integrated paper mill which does not utilize these processes and
was constructed

prior to the effective date.

The 150,000 gallon No. 6 Fuel Oil tank was installed in 1967.

There are noincinerators at the FacilityThis is too broad a request.*

This is too broad a request.*

20American Paper Mills of Vermont, Inc. #0P-95-032 40 CFR, Part 63 et seq

40 CFR Parts 72 through 78

40 CFR Part 82, et seq. §5-201 to 5-203 of the Regulations§5-222 of the Regulations §5-231 (2) of the Regulations §5-231 (5) of the Regulations §5-241(3)(a) to (e) of the Regulations§5-251 of the Regulations §5-252 of the Regulations §5-253.1 of the Regulations

§5-253.2 to 253.4 and 253.6 of the Regulations

§5-253.13 of the Regulations

§5-253.15 of the Regulations

MACT Standards

Acid Rain Program Stratospheric Ozone Protection. Open Burning Prohibition

Prohibition of Potentially Polluting Materials in Fuel: Waste Oil Combustion Prohibition of Particulate Matter: Incinerator EmissionsProhibition of Particulate Matter: Asphalt Concrete Plants Pro, hibition of Nuisance and Odor: Control of Odor from Industrial Processes
control of Nitrogen Dioxide Emissions
Control of Sulfur Dioxide Emissions Control of Volatile Organic Compounds: Petroleum Liquid Storage in Fixed Roof Tanks: Tanks > 40,000 gallon and Vapor Pressure >=1.52 psi. Control of Volatile Organic Compounds: Bulk Gasoline Terminals, Bulk Gasoline Plants, Gasoline Tank Trucks
Coating of Miscellaneous

Metal Parts

Cutback and Emulsified Asphalt

Denied

Denied

Denied

Denied

Denied

Denied

Denied

Denied

GrantedGrantedGranted

Denied

Granted

Denied

This is too broad a request.*

This is too broad a request.*This is too broad a request.*•he facility is capable of open burning. The facility is capable of burning waste oil. The facility does not have an incinerator. The facility is not an asphalt concrete plant. The facility is capable of producing odors from the industrial processes. The facility has no fuel burning equipment with a heat input >=250 MMBtu

The facility does not store liquids with vapor pressure >= 1.52 psi in tanks> 40,000 gallons. The facility does not meet the definition of Bulk Gasoline Terminals, Bulk Gasoline Plants, or Gasoline Tank Trucl•s Metal parts coating at the facility is limited to maintenance operations. The facility does not mix, store or manufacture cutback or emulsified asphalt.

21American Paper Mills •)f Vermont, Inc. #0P-95-032 §5-253.20 of the Regulations

Other Sources that Emit Volatile Organic

.§5-405 of the Regulations

Compounds

(VOC RACT): Applies to Operations or processes with allowable emissions of VOCs >=50 tpy, except for fuel burning or processes regulated under other subsectionsof

§5-253 of the Regulations.

§5-901 of the Regulations

Required Air Monitoring: Requires air monitoring, recordkeeping

and reporting.

Denied

Denied
§5-406 Of the Regulations

Required Air Modeling DeniedDenied Control of Ozone Depleting Chemicals: Definitions Control of Ozone Depleting Chemicals: Motor Vehicle Air Conditioning

Control of Ozone Depleting Chemicals: Regulation of Ozone Depleting Products §5-911 of the Regulations

§5-921 of the Regulations Denied

Denied

The paper machine is capable of being subject to this regulation.

The current permit limits the machine 49 tpy however, the facility will be subject if the emissions exceed the current 49 tpy limit. The facility is required to perform recodkeeping and reporting. The facility is capable of being subject to this regulation.

.The facility does not service or repair motor vehicle air conditioners The facility does not engage in the sale of ozone-depleting products.
*In light of a recent letter from U. S. EPA to the Agency on broad permit shields (dated March 31, 1999), the Agency is denying a shield from .these requirements. C. Description

of Alternative

Operating

Scenarios APMV has not requested

approval

for any alternative

operating

scenarios.

V. HAZARDOUS

AIR CONTAMINANTS Section 5-261 oftheRegulations

addresses

emissions

of hazardous

air contaminants

(HACs). The applicability of this section to an air contaminant

source is determined

by comparing

the actual emissions of each HAC to its Action Level. If the actual emissions

of any contaminant

exceed its Action Level, the source must demonstrate

compliance

with §5-261.

To calculate

the emissions of a HAC, all sources of that contaminant

at the facility must be aggregated. Pursuant to §5-261(1

)(b)(i) of the Regulations,

all fuel burning equipment

which combusts

virgin liquid fuel is exempt from the requirements

of §5-261.

In addition,

the Zurn wood-fired

boiler is exempt based on §5-261(1)(b)(ii),

as it was installed

prior to January

1, 1993. Therefore,

all ofthe mill's boilers are exempt from this section. A. Hazardous

Air Contaminant

Emission

Estimates The mill uses several process chemicals

and dyes that contain volatile HACs that are emitted to the 22American Paper Mills of Vermont, Inc. #0P-95-032 ambient air. The actual 1999 emission

rates, scaled up to full time operation,

of these HACs are listed and compared

to their Action Levels in Table 8. The emission

calculations

are contained

in Appendix B of this document. Table 8: Emissions

of HACs and comparisons

to Action Levels.

SodiumHypochlorite Blue GDFSaf-T-Brite II

Sodium Hydroxide
Diethanolamine D-Limonene

0.17

hydroquinone 0.100.09 Scriptset 720

Styrene Monomer

0.004 Elvanol 71-30

Methanol 6.8 C0rtrol OS7780 0.12

0.84

5.4

NO

60 NO 42.5 No 322 No 0.2 NO As shown in Table 8 above, APMV does not currently

generate

emissions

of any HAC in exceed of its respective

Action Level. Therefore,

APMV is not subject to §5-261 of the Regulations. Vl. REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the Agency has not established

an Operating

Permit Reasonably

Available

Control Technology (RACT) (§5-1010

of the Regulations)

applicable

to the mill. The Agencywill

notifyAPMV if any applicable

RACT requirement

is developed

in the future. VIII. COMPLIANCE

PLAN A. Description

of the Compliance

Status for Each Applicable

Requirement A• Description

of the Compliance

Status for Each Applicable

Requirement See Part IV above. B. Compliance

Schedule

for Each Applicable

Requirement

for Which the Source is Not in Compliance Not applicable

to this Facility.

IX. PUBLIC

PARTICIPATION The mill is classified

as a Title V subject source, and consequently

any operating

permit application submitted for this facility is subject to the public participation

requirements

found in §5-1007

of the Regulations. The Agency published

a notice in The Caledonian

Record on November

16, 1995
23American Paper Mills of Vermont, Inc. #0P-95-032 stating that an administratively

complete

operating

permit application

had been received

from APMV.

A second notice was published

in The Caledonian

Record on October

5, 2000 announcing

that the Agency had declared

the application

technically

complete

and had issued a draft operating

permit. This second notice also solicited

comments

regarding

the draft permit and requests

for an informational meeting.

The deadline

to request an informational

meeting was October 30, 2000. The Agency did not receive a request for a public meeting.

The public comment

period closed on November 6, 2000. The agency received

some minor comments

from APMV and has incorporated them into the final permit. On October

5, 2000 the Agency notified the U. S. EPAand

the states of New Hampshire,

New York and Massachusetts

of the draft permit and requested

comments.

The states of New Hampshire, New York and Massachusetts

were given a deadlineof

November

6, 2000 for comments

on the draft permit.

No comments

were received

from the states of New Hampshire,

New York or Massachusetts. On November

7, 2000 the proposed

permit was forwarded

to the EPA for a 45 day review and comment period. The EPA completed

their review of the permit on November

14, 2000 and notified the Agency that they had no comments

on the permit.

X. CONCLUSIONS Based on the foregoing

technical

analysis,

the following

conclusions

are made: 1. The Agency has determined

that the Facility, subject to the recommended

permit conditions, will meet all the applicable

air pollution

control requirements. 2. Pursuant

to 10 V.S.A. §556a and SubchapterX

of the Regulations,

the Facility is designated as a Subchapter

X Major Source and as a Title V Subject Source. 3. Draft Permit Conditions

(see draft permit)

24American Paper Mills of Vermont, Inc. #0P-95-032

This page was intentionally

left blank.

25American Paper Mills of Vermont, Inc. #0P-95-032 APPENDIX A
Site MapPlot Plan Process Flow Diagram

APPENDIX B Emissions CalculationsAmerican Paper Mills of Vermont, Inc. #0P-95-032 APPENDIX B Emissions Calculations I. Allowable

Emissions

from Boilers Allowable emissions

is defined under Section 5-101 (11 ) of the Regulations

as "...the emission

rate calculated using the maximum

rated capacity

of the source and, if applicable,

either: (a) The applicable

emission

standard

contained

in the regulations,

if any, or (b) The emission

rate or design, operational

or equipment

standard

specified

in any order or agreement issued under these regulations

that is state and federally

enforceable." A. Zurn Wood Boiler Pursuant to the NOx RACT order issued January

9, 1996, the Zurn Boiler exhaust emissions

of nitrogen oxides and carbon monoxide

are restricted.

The emission

limits forthe boiler are listed in Table B.1 For most combustion

air contaminants,

the peak emission

rate will be produced

when the Zurn Boiler is operating

on a continuous

operation

(i.e., 8,760 hrs/yr) at full load (i.e., 100% of capacity).

Start-Up/Shutdown 54 Ibs/hr

1hour average Normal Operation

54 Ibs/hr &

24 hour rolling 0.3 Ibs/MMBtu

average Table B.1: Zurn Emission

Limitations

from NOx RACT

• •i •,'. •!!,:';i;i,•- "•;;••:• •:•'.•-'•" •:•i:i,i;',•,i";•,•"•::•;•;•q

•';""•":•;•:::.!!•;!i'.•ii.i':

1100 Ibs/hr

1 hour average 540 Ibs/hr &

24 hour rolling 3.0 Ibs/MMBtu

average The particulate

(PM) emissions

from the Zurn boiler are limited to 0.20 grains/dscf,

corrected

to 12% CO•, by §5-231 (3)(b)(ii) of the Regulations. Allowable Emissions

of sulfur oxides (SOx), volatile organic compounds

(VOCs), and Hazardous Air Pollutants

(HAPs) for the-Zurn

boiler were calculated

based on emission

factors from AP-42 published by the EPA in its Compilation

of Air Pollutant

Emission

Factors.

Volume I'. Stationary Point and Area Sources,

5th Edition, Section 1.6 (2/99). Wood Fuel BTU Content:

4,500 BTU/Ib (green wood fuel) Maximum Rated Heat Input: 180 MMBTU/hr

(Wood) Fuel Maximum

Firing Rate: 480 tons/day

175,200 tpy) CO2% at Maximum

Capacity

5.6% @ 104,865 dscfm (3/11/93

Source Test, Average

of Runs 1L 4)

B-1American Paper Mills of Vermont, Inc. #0P-95-032

NOxCOSO× Table B.2: Zurn Boiler Wood Firin

54 Ibs/hr540 Ibs/hr NO RACT Administrative

Order, 1/9/96 NOx PACT Administrative

Order, 1/9/96

2372,365 0.075 Ib/ton AP-42, Table 1.6-2, 2/99 7 VOC 0.22 Ib/ton AP-42, Table 1.6-3, 2/99 19 PM 0.2 grains/dcsf

at 12% CO §5-231 of the Regulations 366* HAPs 4.52 x 10 -2 Ib/ton

AP-42, Tables 1.6-4&5, 2/99 4 The allowable

emissions

of PM were based on 0.2 grains/dscf

converted

to 12% CO2 using the results of a source test performed

at maximum

capacity on 3/11/93 (5.6% CO at a flow rate of 104,865 dscfm). C.•,a• 9 C• 9 0

• 90.093gr/dscf ? 12% ? Babcock and Wilcox Boilers (4) APMV operates

four Babcock

and Wilcox boilers having a rated heat input of 42.5 MMBtu/hr

each. The Babcock

and Wilcox burn No. 6 fuel oil with a maximum

sulfur content of 2.0% by weight. These boilers are limited to 5% of capacity

by the NOx RACT. Each boiler has a maximum

fuel rate of 283 gal/hr, resulting

a total maximum

annual fuel use of 9.9 million gallons per year. 5% of 9.9 million gallons results in a fuel cap of 495,900

gallons per year, for the four boilers combined. Emissions of SO2, NOx, CO, VOCs, and HAPs are based on emission

factors for fuel oil combustion in boilers less than 100MMBtu/hr

published

in EPA's Compilation

of Air Pollutant Emission Factors:

Volume I: Stationary

Point and Area Sources,

AP-42, 1995. According to AP-42, the SO2 emission

factors can be calculated

according

to the following formulas (where %S is the sulfur content by weight percent): Fso 2 (157 x %S) Ib/103 gal.= (157 x 2.0%) Ib/103 gal 314 Ib/10 • gal Allowable PM emissions

were based on §5-231 (3)(a)(ii) of the Regulations.

B-2American Paper Miffs of Vermont, Inc. #0P-95-032 Table B.3: Allowable

emissions

from Babcock

and Wilcox Boilers.

NOxCOSOxVOC 55 Ibs/lO • gallons 5 Ibs/10Sgallons 13.6 AP-42, Table 1.3-1, 9/98 1.24 314 Ibs/10 • gallons

AP-42, Table 1.3L1, 9/98 780.07 0.28 Ibs/10 • gallons

AP-42, Table 1.3-3, 9/98 PM 0.25 Ib/hr/MMBtu

per Boiler §5-231 of the Regulations 9.6 (11 Ib/hr per boiler) x 5% HAPs 0.138 Ib/10 • gallons

AP-42, Table 1.3-9,10,&11,

9/98

0.03

II. Allowable

Emissions

from Starch Silo The maximum

capacity

of the starch silo baghouse

is 482 cfm. The starch silo generates

PM emissions.

Allowable

emissions

are calculated

based on §5, 231 (1)(b) of the Regulations

and are limited to 0.06 grains/cf. Allowable PM emissions

from the starch silo are 1.32 tons/year. 482 cfm x 0.06 gr/dscf x 8760 hr/yr x 60 min/hr x (7.14 x 10 -e ton/gr)

1.1 tpy

III. Allowable

Emissions

from Wood Chip Handling

System The wood handling

system generates

PM emissions.

Allowable

emissions

are calculated

based on §5-231 (1)(b) of the Regulations

and are limited to 0.06 grains/cf. The two cyclones

have a maximum

capacity

of 5720 cfm each. Allowable PM emissions

from the wood chip handling

system are 26 tons/year. 11,440 cfm.x 0.06 gr/dscf x 8760 hr/yr x 60 min/hr x (7.14 x 10 6 ton/gr)

26 tpy IV. Allowable

Emissions

from Begreasers APMV operates

3 Safety-Kleen

degreasers

(2 Model 34 and 1 Model 23). Solvent used is SK Premium

150, which contains

solvent naphtha.

Solvent naphtha

is a VOC but not a HAP or HAC. Estimated annual solvent loss based on letter from Safety-Kleen

(April 7, 1994) is approximately 604 Ibs/year

0.30 tpy).

E} 3American Paper Mills of Vermont, Inc. V. Allowable

Emissions

from Paper Machine #0P-95-032

APMV uses various chemical

dyes, additives,

sizings and coatings,

in the paper making process. These compounds

emit VOCs, HACs, and HAPs into the ambient

air. VOC emissions

from the paper machine

are limited to 49 tons per year. If the facility exceeds

this limit APMV will be subject to §5-253.20

of the Regulations

(VOC RACT). The potential

VOC emissions

are estimated

for comparison

to the 49 tpy limit. The estimate

was based on the 1999 Registration

information

submitted

to the Agency.

The 1999 usage amounts were scaled up to full time, year round operation

(9 Months operation

x 1.33 12 months operation, 12 months operation

x 1.39 full time 12 month operation).

Factor to scale up from 12 month operation

to full time 12 month was developed

with APMV. Estimated potential

emissions

of VOCs from the paper machine

are listed below in Table B.4. Table B.4: Potential

Emissions

of VOCs from Paper Machine

Blue GDFElvanol 71-30 Protocol WB 8000 Caratarex FL Yorksize 1030 Latex DL 233NA Yellow Rw Liq Blue 2AL 251323,66323,32126,943223,43634,984713 10.9520.3 2716,1834,734566

5,971 6 Leucophor B302 272,630 0.4 1,091 Perform PC 8138

64,074 30 19,222 2,18 17,875 0.05 17.5 3.2 23358

18,798 44 8,271 354 10 35 2,882 5 144 WSM-935Spectrum RX 8700 Saf-t-BriteTotal (34 tpy) 68547

B-4American Paper Mills of Vermont, Inc. #0P-95-032 VI. Allowable

Emissions

of Federal

Hazardous

Air Pollutants

from Paper Machin e Sources of Hazardous

Air Pollutants

(HAP•;) at the facility are the chemicals

added to the paper making process. Emission Data based on 1999 actual emissions

reported

to the Agency through the Registration Program.Actual emission

data was scaled up from 9 months to 12 (multiplied

by 1.33) and then scaled up to potential

emissions

(multiplied

by 1.39). Table B.5 shows potential

HAP emissions

from process

chemicals

and dyes used at the facility. Table B.5: Allowable

HAP Emissions

from Process

Chemicals.
Styrene 617 0.003 Methanol 10,357 5.20 Totals 10363.7 5.20

VII. Actual Emissions

of Hazardous

Air Contaminants The mill uses several process

chemicals

and dyes that contain volatile HACs. The •ctual emissions of these HACs are estimated

by assuming

that 100% of each volatile HAC is emitted to the ambient

air, HAC emission

data based on 1999 Registration

Data scaled up from 9 months to twelve x 1.33). Boiler water conditioners

were not included

as they would not be released

to the air. No compounds

exceed their respective

Action Level.

Table B.6: Emissions

of hazardous

air contaminants. Process HAC

Actual Use Rate

% HAC

Emission Rate Act on Leve Chemica (Iblyr) (Ib/8hr)

, (b/ehr) SodiumHypochlorite Blue GDF Saf-T-Brite II Scripset 720 Elvanol 71-30 Sodium Hydroxide

9,310

2

0.17

0.84 Diethanolamine 180

6

0.01

5:4 D-Limonene 2,059

5

0.94

60 StyreneMethanol 9,573231,193

.O53.2

0.0046.8

42.5322

B-5VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division TECHNICAL ANALYSIS

OF AN AIR CONTAMINANT

SOURCE FOR A PERMIT

TO OPERATE #AOP-00-024 DEC# SJ75-0002 November.6, 2000 (Revised: December

18, 2000) Prepared By: John L. Perreault,

P.E.

APPLICANT:

SOURCE:

RESPONSIBLE OFFICIAL:

APPLICATION CONTACT:

COUNTY:AREA DESIGNATION:

UTM COORDINATES: EHV Weidmann

Industries,

Incorporated P.O. Box 903 St. Johnsbury,

VT 05819-0903 Transformer Board Manufacturing

and Assembly

Facility EHV Weidmann

Industries,

Incorporated One Gordon Mills Way St. Johnsbury,

VT 05819 Kenneth R. Linsley, VP of Manufacturing EHV Weidmann

Industries,

Inc. Larry Corrow Environmental

& Safety Director EHV-Weidmann Industries,

Inc. Tel. (802) 751-3407 Fax (802) 751-3431 Michael F. Morin, P.E. Consultant Neill and Gunter, Inc. 482 Payne Road Scarborough, ME 04103 Tel.Fax CaledoniaAttainment for PM10, SO2, NO,, CO, and Pb Unclassified for O3 737275 m E, 4929725 m N, Zone 18 (Center of Main Manufacturing

Building)EHV Weidmann

Industries,

Inc. #AOP-O0-024 1.0 INTRODUCTION On October

19, 2000, EHV Weidmann

Industries,

Incorporated

(hereinafter

"EHV Weidmann" also referred to herein as "Owner/Operator")

submitted

an application

and $585.00 base application

review fee to the Agency of Natural Resources,

Department

of Environmental Conservation,

Air Pollution

Control Division

("Agency").

EHV Weidmann's application requested

an amendment

of its existing Air Pollution

Control Permit to Construct and Operate

(#AOP-95-075)

issued on May 19, 1999. EHV Weidmann proposed to install a new 500 horsepower

("HP") residual oil-fired boiler to replace its existing Boiler #2 located in the Main Building. This Technical

Analysis

documents

the Agency's

review of the proposed

project with respect to the Vermont

Air Pollution

Control Regulations

("Regulations"). 1.1 Administrative

MilestonesTable

1-1: Administrative

Summary

Date Application

Received: Date Fee Received and Amount: Date Administratively

Complete: Date & Location Receipt of Application

Noticed: Date Technically

Complete: Date Proposed Decision: Date & Location Proposed Decision & Public Comment Period Noticed: Date & Location Public Meeting Noticed: Date & Location of Public Meeting: Deadline for Public Comments: Date Supplemental

Fees Rec'd and Amount Rec'd: Breakdown of Supplemental

Fees

Classification of Sourde Under §5-401: 10/19/2000 10/19/2000 $585.00 10/20/2000 10/31/2000 The Caledonian

Record 11/06/2000 11/06/2000 Approved 11/09/2000 The Caledonian

Record

No request rec'd on or before 12/04/2000 No request rec'd on or before 12/04/2000 12/08/2000 12/18/2000 $3,210.00 Engineering Review Fee

$1,460.00 Observe & Review Emissions Testinq • Total Fees $3,210.00 §5-401(6)(a) Fossil fuel burning equipment of greater than 10 million BTU's per hour rated heat input; §5- 401(111 Manufacturing,

processing,

application of chemicals, including the processing or application of plastics, rubbers, or resins; §5-401(12)

Operations involving the handling or transferring

of sand and dust producing materials of the Regulations.EHV Weidmann

Industries,

Inc.

Classification of Operating Permit Application: New Source Review Designation

of Source: #AOP-O0-024

Title V Subject Source Major Stationary Source Designation of Modification Non-Major Modification Facility SIC C0de(s): 2631 Facility SIC Code Descr pt on(s) Paperboard

Mills
• AilowableAirCont•minantEmissions(tbnsiyea•;)* '";,,•:,- •,--: • -•- NO, CO; -_- Acetone • -:Total HAP

1.2 • PM/PM10 particulate mattei" and particulate matter of 10 micrometers

in size or smaller, SO2 sulfur dioxide, NO× oxides of nitrogen, CO carbon monoxide; VOCs volatile organic compounds,

Pb lead, HAPs hazardous air pollutants as defined in §112 of the federal Clean Air Act. Actual emissions have been estimated to be approximately

9, 25, and •7 tons per.year for VOCs, Acetone, and Total HAPs, respectively. Basis of Review EHV Weidmann

owns and operates

a transformer

board manufacturing

and assembly facility located off U.S. Route 5 in St. Johnsbury,

Vermont

(hereinafter

"Facility"). Operations performed

at the Facility are classified

within the Standard

Industrial Classification Code 2631 (Paperboard

Mills). The operations

performed

by EHV Weidmann at the Facility are classified

as a source of air contaminants

under §5-401 of the Regulations,

as follows:

§5-401 (6)(a) Fossil fuel burning equipment

of greater than 10 million BTU's per hour rated heat input; §5-401(11)

Manufacturing,

processing, application of chemicals,

including

the processing

or application

of plastics,

rubbers,

or resins; and §5-401 (12) Operations

involving

the handling

or transferring

of sand and dust producing

materials. The Agency.granted

approval

for the modifications

to the Facility pursuant

to the requirements of §556 of Title 10 Vermont

Statutes

Annotated

("10 V.S.A.")and

§5-501 of the Vermont

Air Pollution

Control Regulations

("Regulations")

on June 3, 1985. This Air Pollution Control Permit to Construct

("Permit to Construct")

was amended

on August 21, 1996, in order to allow the installation

of a new fabric filter collector

and increased exhaust air flow rates through two existing collectors.

The fabric filter collectors

control emissions of particulate

matter ("PM/PMlo")

generated

by the board processing

activities. On December

30, 1998, the Agency once again amended

its approval

to allow the installation of a fabric filtercollector

and make-up

air heater in the Recycle

Building. Additionally, allowable

emissions

of all air contaminants

from EHV Weidmann's operations have been estimated

to be greater than ten (10) tons per year ("tpy") and allowable emissions

of PM/PM10

and sulfur dioxide ("SO2") greater than 100 tpy. Therefore, pursuant

to §§5-1002,

5-1003, and 5-1005 of the Regulations,

the Facility is classified as a "Title V Subject Source"

and is subject to the requirement

to secure an Air Pollution Control Permit to Operate

("Permit to Operate")

consistent

with the requirements of Subchapter

X of the Regulations

and Title V of the Clean AirAct.

EHV Weidmann was granted its initial Permit to Operate,

pursuant

to these regulations,

onEHV Weidmann

Industries,

Inc. #AOP-O0-024 May 19, 1999. The Permit to Operate

was issued simultaneously

with an administrative amendment of EHV Weidmann's

existing Permit to Construct

in order to facilitate

the issuance of one combined

permit for the same Facility.

The Air Pollution

Control Permit to Construct

and Operate

("Permit to Construct

and Operate")

was issued consistent with 10 V.S.A. §556(e)for

the purposes

of reducing

the administrative

burden of enforcing two separate

permits for the same Facility. As was stated previously,

EHV Weidmann

proposes

to install and operate a new residual oil-fired boiler at its Facility.

The proposed

installation

of this replacement

boiler satisfies the definition

of modification

within §5-101 of the Regulations,

since the project involves a physical change of the stationary

source which would result •n an actual emissions increase. Consequently,

the proposed

project is subject to Agency review anda pproval pursuant to 10 V.S.A. §556 and Subchapter

V of the Regulations.

Additionally,

any modification of a Title V subject source is subject to review and approval

pursuant

to the requirements of 10 V.S.A. §556a and Subchapter

X of the Regulations,

as well as the federal operating

permit regulations

in Title 40 Code of Federal Regulations

("40 CFR") Part 70. The Agency proposes

to combine

its review for approval

of the project under both the construction

and operating

permit requirements

consistent

with the authority

in 10 V.S.A. §556(e). 1:3 Project Description EHV Weidmann

proposes

to replace its existing Boiler #2 used to produce

hot water for the board manufacturing

line identified

as BM2 at the Facility. Additionally,

EHV Weidmar•n proposes

to make other process

changes

to improve

press operation,

steam use, and boiler performance.

Process

changes

will include the installation

of a hot water accumulator. This device is intended

to reduce boiler swings during periods when the BM2 has very high heat demands.

EHV Weidmann

is also proposing

other process changes to reduce the heat load on Boiler #1 (i.e., switching

"white water heating demands" to the replacement

boiler). The new boiler will be a 500 HP fire-tube

boiler manufactured

by Johnston

(Model PFTA500-4). The new boiler will produce

steam instead of hot water. According

to EHV Weidmann, this will give them more flexibility

in meeting the overall heating requirements of the Facility, since the new boiler will be Connected

to the mill-wide

steam header.

Hot water for the BM2 will be produced

using a steam/water

heat exchanger.

The new boiler is proposed

to have the below listed specifications: Maximum Rated Heat Input: Maximum Oil Firing Rate: Fuel:Steam Pressure: Maximum Steam Production: Combustion Information:

19.4 million British Thermal

Units per hour ("MMBTU/hr") 130 gallons per hour ("gph"); No. 6 Fuel Oil with a maximum

sulfur content not to exceed 0.5 % by weight; 200 psig (maximum) 150 psig (design); 17,250 pounds per hour ("lbs/hr"); One Low-NOx

burner, compressed

air atomization

of fuel, forced draft, staged air combustion.

4EHV Weidmann

Industries,

Inc. #AOP-O0-024 The replacement

boiler will be installed

inthe boiler room next to existing Boiler #2. EHV Weidmann proposes

to continue

to operate existing Boiler #2 until the replacement

boiler is on-line.

Once the new boiler is operational,

EHV Weidmann

proposes

to shutdown and dismantle

the old unit. The existing Boiler #2 operated

6,384 hours and burned 266,264

gallons of No. 6 fuel oil (maximum sulfur content of 2% by weight) in 1999. With the proposed

improvements, EHV Weidmann

projects that the replacement

boiler will pick up an additional

heat load equivalent to 158,700 gallons of fuel oil per year.

2.2 FACILITY

DESCRIPTION

AND LOCATION Description of Plant Layout and Surrounding

Area The Facility is located off U.S. Route 5 just north of St. Johnsbury,

Vermont.

The area surrounding the Facility property

is rural and consists

of primarily

agricultural

and residential uses. U.S. Route 5 and the Passumpsic

River provide the eastern boundary for the plant property,

while Interstate

91 provides

the western

boundary.

The geographical area is complex

terrain in all directions

surrounding

the site. Figures 1 and 2 in Appendix

A of this Technical

Analysis

depict the location/property

of the Facility. Explanation of Process

(Including

SIC Codes) The operations

performed

at the Facility are described

using the Standard

Industrial Classification Code 2631 (Paperboard

Mills). EHV Weidmann

manufacturers transformer board and transformer

board assemblies.

The transformer

boards are sold to businesses

involved

in the manufacturing

and/or repa=ring

of transformers,

and are available in standard

or special sizes. The transformer

board is manufactured

from unbleached

kraft pulp and/or recycled transformer board materials.

A specialty

transformer

board, known as Nomex board, is also manufactured

at the Facility.

The Nomex board is produced

using a synthetic

fiber manufactured by DuPont. The process

begins by re-pulping

material

using a combination

of water and "proprietary recipes" for the formulation

of the pulp-type

needed.

A large "pulper" is used in this process (driven by an electric motor acting much like a large blender).

The resulting mixture of water and fibers is then cleaned

by centrifugal

treatment

of the fiber-water suspension. Next, it is applied via a screenroll

to a felt belt in a manner conventional

in paper-making. The wet material

is accumulated

in thin plies on an accumulating

roll to thicknesses that vary between

0.25 to 1.25 inches. When the desired amount has been laid, the wet material

is parted within the "making roll," and the flat sheet (approximately 20 feet by 10 feet) is conveyed

to a drying station. One of two methods

is employed

to dry the material,

either by convection

in an oven, or by pressing

it between

heated plates. When the end user needs transformer

board that is thicker than what can be manufactured using the "making roll", individual

board sheets are laminated

together

toEHV Weidmann

Industries,

Inc. #AOP-O0-024 reach the required

thickness.

The laminating

process utilizes polyester

resin between layers of material.

Sheets are cut and fed through a machine

that applies a thin layer of polyester resin to the top surface.

The sheets accumulate

to a height of about 24 inches, and are then passed into a hydraulic

press where they remain until the resin has cured. Subsequently, the pressed

sheets are removed

and cut to the required

size and sent either to the external

customer

or internal for further processing. Boardmakincj: EHV Weidmann

has two "boardmaking"

lines referred to as BM1 and BM2. Figures 4 and 5 in Appendix

A of this Technical

Analysis

depict the process flow diagrams for thetwo boardmaking

lines. Steam and particulatesare

the only emissions produced in the boardmaking

process.

Nearly all of the particulates

are captured pneumatically through a duct connected

to a fabric filter collector

(#M41). Recently EHV Weidmann

has begun recycling

ground laminated

transformer

board material in the pulping process.

The recycling

of this material

is expected

to produce emissions of styrene from the pulping activities.

Emissions

have been projected

to be 0.03 Ibs/hr and 207 Ibs/yr from the recycling

of this material

(emissions

increase

of 1.6% above actual emissions

from the existing lamination

line). Lamination Line: The lamination

line is used to laminate

boards produced

from either BM1 or BM2 to produce

thicker board. The board is laminated

by means of a curtain coater. In the past, EHV Weidmann

also utilized a reciprocator

to laminate

sheets. However, this device was eliminated

from the production

process

in 1997. The majority of the laminating

material

(adhesive)

used is a polyester

resin which requires

the addition of a hardener.

Water-based

adhesives

(Casein glue and Dextrin glue) are also used. Figure 6 in Appendix

A of this Technical

Analysis

depicts the process flow for the lamination line. The curtain coater applies the adhesive

similar to a shower.

The adhesive

is premixed with a hardener

and then poured over the board. Once the board has gone through the adhesive application

step, another board is placed on top and this continues

until the desired board thickness

has been achieved.

The stack of boards is then compressed

in a press for approximately

four (4) hours. While the boards are being pressed,

the adhesive applicator

is cleaned.

Acetone

is used to clean the curtain coater laminating applicators after laminating

with the polyester

resin. Water is used to clean the laminating applicators

after laminating

with the water-based

adhesives. Nomex Boards:

The Nomex boards are a specialty

board produced

on the BM2 line. The Nomex pulp has a different

formulation

than the wood pulp. Once the boards have been produced

and cut, .they may be sent to the Nomex process area or to other fabricating areas of the Facility. In the Nomex process area the boards are heated in an oven and pressed

together

to form a bond. This process also uses a release agent called Monocoat

327W. During the thermal bonding process,

the boards are heated up to approximately

550 °F. Combustion Sources:

EHV Weidmann

operates

two (2) No. 6 oil-fired boilers in the Main Building of the Facility.

Boiler #1 is a 700. horsepower

("HP") boiler which is used 6EHV Weidmann

Industries,

Inc. #AOP-O0-024 for 85% process heat and 15% space heat. Existing Boiler #2 is a 350 HP boiler used for 100% process heat. As stated previously,

EHV Weidmann

proposes

to replace this unit with the new Johnston

boiler. EHV Weidmann

also operates

three (3) No. 2 oil-fired boilers in the Fab North Building

(each rated less than 3 MMBTU/hr

of heat input),-a No. 2 oil-fired boiler (rated less than 3 MMBTU/hr

of heat input) in the Training

Center, and a No. 2 oil-fired space heating unit (rated less than 3 MMBTU/hr

of heat input) in the Recycle Building.

Recently,

EHV Weidmann

obtained

approval

to install a make-up

air duct heater for the Recycle

Building.

This additional

heater was necessary

to accommodate the expected

increase

in air transfer rates within the building associated with the installation

of a new fabric filter control device. The fabric filter control device is planned to be installed within the next two years in order to capture PM/PM10

emissions produced by transformer

board grinding and baling equipment

located within the building. This make-up

air heater is proposed

to have a maximum

rated heat input of 0.525 MMBTU/hr and will utilize No. 2 fuel oil. Board Machining

Operations:

Various machines

are employed

to cut the boards to desired shapes and sizes. Depending

upon the number of machines

in use, dust produced by the machines

may be vented to fabric filter collectors

(#M51, #M41, #FN15, and Torit & Day collector).

When a small number of machines

are in use, EHV Weidmann may choose not to operate the collection

system.

During these instances, the majority of the dust material

falls to the floor and is manually

recovered

(i.e., broom and dust pan). Recycling Building

Grinding

O_•erations As was stated previously,

the Agency granted approval

(on December

30, 1998) to EHV Weidmann for the installation

of a new fabric filter collector

in the Recycle

Building.

This collector is proposed

to be employed

to capture light airborne

dust that is produced during the chipping

of laminated

transformer

board and its subsequent

baling. Besides dust, the exhaust air is also expected

to contain a small quantity of styrene which is released from the resin-laminated

product during the chipping

process.

Plans are that the exhaust air exiting the collector

may be emitted directly to the ambient

air or be optionally diverted

through a heat exchanger

prior to discharging

outside.

When the heat exchanger is in use, it will recover much of the heat content of the exhaust air to pre-heat make-up air for the building.

In addition,

the heat exchanger

will be equipped

with a duct heater fired with No. 2 fuel oil to provide supplemental

heat for the make-up

air. The fabric filter is expected

to be a model FT-64-D14

manufactured

by the AGET Manufacturing Company.

The unit is planned

to have a maximum

rated exhaust air flow rate of 4,900 actual cubic feet per minute.

Note, EHV Weidmann

intends on installing

a used cyclone and fan in combination

with the above identified

dust collector.

Currently, EHV Weidmann

is in the process of investigating

the feasibility

of recycling

its laminated transformer board product,

and therefore,

the actual installation

date for this fabric filter collector is still questionable. Gluing O_•erations:

Glues and adhesives

are.used

throughout

the Facility.

Nearly all emissions from gluing operations

are considered

fugitive emissions.

EHV Weidmann has eliminated

formaldehyde

emissions

from its use of adhesives

on-site.EHV Weidmann

Industries,

Inc. #AOP-O0-024 Miscellaneous Other Processes:

EHV Weidmann

operates

an oil impregnation process which saturates

the transformer

boards with oil. This process

is located in the Fab North Building.

See Figure 9 in Appendix

A of this Technical

Analysis

for a flow diagram of this process.

Occasionally,

Nomex boards are laminated

together

using a phenolic bonding film. Finally, a liquid product called Zipguard

is applied to some fabricated parts, primarily

static rings made in the Metallizing

Department

of the Fab North Building.

When the Zipguard

is dry, it acts as a moisture

barrier. 2.3 Process

Equipment

and Stack Information 2.3.1 Description

of Equipment See Table 2-1: Equipment

Information,

for a list of the more important

emission

points at the Facility.

See Tables 2 and 3 in Appendix

B of this Technical

Analysis

for a complete listing of vents, stacks, and emission

points at the Facility. 2.3.2. Description

of Compliance

Monitoring

Devices No devices have been proposed

to continuously

monitor emissions

produced

at this Facility.• •EHV Weidmann

Industries,

Inc. #AOP-O0-024 3.0 QUANTIFICATION

OF POLLUTANTS Emissions must be calculated

for the Facility in order to establish

the regulatory

review process necessary

for the construction

and operating

permit portions

of the application and to determine

applicability

with various air pollution

control requirements.

These determinations are normally

based upon allowable

emissions.

Allowable

emission

is defined as the emission

rate calculated

using the maximum

rated capacity

of the source and, if applicable,

either: (a) the applicable

emission

standard

contained

in the Regulations, if any, or (b) the emission

rate or design, operational

or equipment

standard specified in any order or agreement

issued under the Regulations

that is state and federally enforceable.

In addition,

§5-101 of the Regulations

defines a "stationary

source" as any structures,

equipment,

installations,

or operations,

or combination

thereof, which emit or may emit any air contaminant,

which is located on one or more contiguous

or adjacent properties

and which is owned or operated

under common

control.

Based upon this definition,

all of the equipment,

operations,

and structures

at Facility are grouped together as one stationary

air contaminant

source. Under the Agency's

construction

permit program

(see Subchapter

V of the Regulations), a source is classified

as a major stationary

source if allowable

emissions

of any air contaminant equal or exceed fifty (50) tons per year ("tpy"), except the air contaminant lead which is five (5) tpy: Additionally,

any modification

to an existing major stationary source which results in an emissions

increase

equal to or greater than the "significant" levels identified

in §5-101 of the Regulations,

is classified

as a major modification

and subject to the same review requirements

as a new major source. Under the Agency's

operating

permit program,

asource

is classified

as a "TitleV Subject Source" and subject to federal review of the Permit to Operate

if the Facility satisfies

any one of the following

criteria: The source has allowable

emissions

of oxides of nitrogen

("NOx"), sulfur dioxide ("SO2"), carbon monoxide

("CO"), particulate

matter ("PM/PM10")

or any other air contaminant, except volatile organic compounds

("VOCs"),

of 100 tpy or greater; 2. The source has allowable

emissions

of VOCs of fifty (50) tpy or greater; The source is subject to a federal emission

standard

pursuant

to §111 of the Clean AirAct ("CAA") and promulgated

in 40 CFR Part 60 (Standards

of Performance for New Stationary

Sources); The source is subject to a federal emission

standard

pursuant

to §112 of the CAA and promulgated

in 40 CFR Part 61or 63 (National

Emission

Standards

for Hazardous Air Pollutants);

or The source has allowable

emissions

of any one hazardous

air pollutant

("HAP") regulated by the U.S. EPA of ten (10) tpy or greater, or allowable

emissions

of a combination of HAPs regulated

by the U.S. EPA of twenty-five

(25) tpy or greater. The HAPs regulated

by the U.S. EPA are identified

in §112 of the CAA.

11EHV Weidmann

Industries,

Inc. #AOP-O0-024 Note: Non-major

stationary

sources subject to a requirement

in § 111 or § 112 of the CAA are currently

not subject to the Title V operating

permit program,

since the U.S. EPA has deferred the requirement

for a Title V operating

permit for non-major

sources pursuant

to 40 CFR Part 70 §70.3(b)(1)

and the fact that the U.S. EPA has not completed rulemaking establishing

how the program

should be structured

for non-major

sources. Based upon its allowable

emissions

(see Table 3-1 below), the Facility is currently classified as a "major stationary

source" under the construction

permit program,

and a "Title V subject source" under the operating

permit program

requirements.

Upon completion of the proposed

modifications,

the Facility will retain these classifications. Emissions produced

from the combustion

of fuels in the fuel burning equipment

include: particulate matter ("PM/PM10"),

sulfur dioxide ("SO2"), oxides of nitrogen

("NOx"), carbon monoxide ("CO"), and volatile organic compounds

("VOCs").

MOCs from fuel burning equipment are also commonly

referred to as non-methane

hydrocarbons

("NMHCs")

or total organic compounds

("TOCs").

The board machining

operations

and recycling equipment result in the discharge

of PM/PM10

(i.e., dust), while VOCs are produced

by the laminating

lines, Nomex board production,

and gluing operations. As will be discussed

in paragraph

3.5 below, the existing Permit to Construct

and Operate places an enforceable

restriction

that limits emissions

of VOCs to less than 50 tpy site-wide.

A similar limit exists on emissions

of acetone

(a regulated

air contaminant in Vermont).

Record keeping requirements

are utilized to verify compliance

with these limits on a rolling twelve (12) consecutive

calendar

month period. For comparison purposes, the Agency has quantified

actual emissions

of VOCs and acetone

from EHV Weidmann in a 1999 inspection

report (most recent report on file). Based upon historical records, EHV Weidmann's

actual emissions

of VOCs and acetone

are 7 and 18 tpy, respectively. Individual constituents

which makeu p the categories

of PM/PM10

and VOCs are also regulated by state and federal regulations,

and must therefore

be quantified.

These individual constituents

are referred to as hazardous

a•r contaminants

("HACs")

and/or hazardous air pollutants

("HAPs").

HAPs are defined as those chemicals

listed in the §112(b) of the federal Clean AirAct, of which there are 188 chemicals.

HACs are defined as those chemicals

which are listed in Appendix

E] of the Regulations.

All of the 188 HAPs are included

as HACs. 3.1 Existing Designation

of the Stationary

Source -[he first step in designating

a modification

as major or non-major

(i.e., minor) is to classify the existing size of the source (i.e., major or minor). A source is considered major if it has allowable

emissions

of fifty (50) tons per year ("tpy") or greater for any air contaminant [Exception:

five (5) tpy for lead]. Allowable

emissions

are developed

using applicable emission

standards

in the Regulations,

permit conditions,

or emission estimates. Additionally,

allowable

emissions

must be determined

assuming

continuous operation of the stationary

source (i.e., 8760 hours per year) at maximum

capacity, unless the owner or operator

of a source operates

under enforceable

limits that restrict operationsto a lower level.

12EHV Weidmann

Industries,

Inc. #AOP-O0-024 Currently, EHV Weidmann

operates

under the confines

of its existing Air Pollution

Control Permit to Construct

and Operate

#AOP-95-075

issued on May 19, 1999. Summarized

in Table 3-1 below are the allowable

emissions

for EHVWeidmann

based upon the restrictions of its Permit to Construct

and Operate.

Additional

information

supporting

the derivation of the allowable

emissions

may be found in Table 1, Appendix

A of this Technical Analysis. Table 3-1: Existing

Allowable

Emissions

for EHV Weidmann

3.2 Fuel Burning Equip•nent

Fabric Filter Collectors Laminating Line, Nomex Board Production,

and Fugitive Emissionsof Adhesives <100

15

7.5 SeeNote 2 42 410

89

131 410 0.2

•-- 42 (+/-)SeeNote <50

<25 See See Note 2 Note 2 Total.Facility .[ <100

15

<50

<50

<25

continuous operation of all fuel burning equipment on-site• Actual emissions of VOCs from the fuel burning equipment approximately 2 tpy, Therefore, emissions of VOCs from the laminating line, Nomex board production, and adhesive usage allowed to exceed 42 Ipy, long total actual VOC emissions at the Facility remain less than 50 tpy. Record keeping and reporting conditions in place to vedfy that annual VOC emissions do not equal exceed 50 [py. Actual ereissions of VOCs approximately 9 tpy.
Note 2: EHV Weidmann operates under the restriction to reaintain NOx emissions below 100 tpy, actone below 50 •py, and Total HAPs below 25 tpy. As was stated previously,

a facility is designated

a major stationary

source of air contaminants if its allowable

emissions

of any air contaminant

equal or exceed fifty (50) tpy [Exception:

five (5) tpy for lead). As described

in Table 3-1 above, EHV Weidmann has allowable

emissions

greater than fifty (50) tpy for PM/PM10,

SO2, and NOx. Therefore, based upon its existing allowable

emissions,

EHV Weidmann

is designated an existing major stationary

source. Designation of the Modification The designation

of an existing stationary

source determines

the appropriate

levels for comparison when attempting

to classify the size of the modification

for new source review purposes.

As an existing major source, any emissions

increase

resulting

from modifications must be compared

to the Significant

Levels described

in §5-101 of the Regulations in order to determine

whether

or not the proposed

modifications

are subjected to the new source review requirements

of §5-502 of the Regulations

(Major Source and Major Modifications).

If a proposed

modification

or aggregation

of minor modifications at the source equal or exceed the "significant"

levels, then the modification is classified

as major and subject to the requirements

of §5-502 of the Regulations. Additionally, it is also important

to note that pursuant

to §5-502(1),

two forms of increases 13EHV Weidmann

Industries,

Inc. #AOP-O0-024 must be compared

to the Significant

Levels for determining

the applicability

of this section. First, the allowable

emissions

attributable

to the proposed

modification,

and second, the aggregated

emissions

increase

from minor modification

s constructed

since July 1, 1979 (including

the proposed

modification).

The purpose

of the aggregated emissions comparison

is to prevent the circumvention

of major source review due to incremental minor increases

in emissions

overtime.

It should be noted that prior modifications at a source which have been reviewed

under §5-502 of Regulations

do not continue to be aggregated

with proposed

modifications

for the purposes

of determining the applicability

of major modification

review. This determination

is performed

on a pollutant-by-pollutant basis. 3.2.1 New Allowable

Emissions

Increase The new allowable

emissions

are the allowable

emissions

associated

with the proposed replacement boiler. The new allowable

emissions

are summarized

in Table 3-2 below. Table 2 in Appendix

A of this Technical

Analysis

summarizes

the information

used to determine these allowable

emissions. Table 3-2: Proposed

Emissions

Increase

at EHV Weidmann

3.2.2 Proposed Modification Significant Level [per § 5-101 of the Regulations]

5.1

21.8 25/15 40

22.04O

1.7

0.4 50 40 Table 3-2 above indicates

the proposed

modification

by itself will not exceed any Sign, ificant Level. Aggregated Allowable

Emissions

Increase As was stated previously,

prior minor modifications

constructed

subsequent

to July 1, 1979, must be aggregated

with the proposed

modification

for the purposes

of determ=ning applicability

with §5-502 of the Regulations.

An exception

exists for those prior modifications

which have previously

been aggregated

for the purposes

of review pursuant to this section.

As can be seen in the Agency's

Technical

Analysis

dated July 17, 1996, EHV Weidmann

is beginning

with practically

a "fresh slate" in terms of emission increases

for PM/PMlo..

Only one prior modification

needs to be considered

for emissions of PM1PM10

(i.e., Recycle

Building fabric filter addition).

Since the aggregation process is performed

on a pollutant-by-pollutant basis, modifications

constructed

before 1998 must still be considered

for SO2, NOx, CO, and VOCs. Table 3-3 below summarizes the aggregated

emissions

increase

for comparison

to the Significant Levels. Table 3 in Appendix

A of this Technical

Analysis

summarizes

the information used to determine

the aggregated

emissions

=ncrease.

14EHV Weidmann

Industries,

Inc. #AOP-O0-024 Table 3-3: Aggregated

Emissions

Increase

at EHV Weidmann

Air Contaminant

EmisSions,

tons p•rye•g

" • - Source I Pi/Pilo IS O2 '1 : NOx

' CO IVOCsProposed Modification

5.1 Emission Due to Prior Modifications

4.9 Aggregated Emissions Increase Significant Level [per § 5-101 of the Regulations]

10.025115

21.813.435.2

4O

22.0

1.7

0.4 5.927.9

40 0.3

6.5 2.0

50 6.9

4O

3.3 Table 3-3 above indicates

the aggregated

emissions

increase

for all air contaminants

is less than the Significant

Levels.

Consequently,

the proposed

modification

is classified as a non-major

modification

and is not subject to review under § 5-502 of the Regulations.Designation of the Facility in the Future Summarized in Table 3-4 below are the allowable

emissions

for EHV Weidmann

for the future. Table 4 in Appendix

A of this Technical

Analysis

summarizes

the derivation

of the future allowable

emissions.

Based upon the level of emissions

identified

in Table 3-4 below, EHV Weidmann

will retain its classification

as a major stationary

source and Title V subject source.Table 3-4: Future Allowable

Emissions

for EHV Weidmann

3.4 Fuel Burning Equipment Fabric Filter Collectors Laminating Line, Nomex Board Production,

and Fugitive Emissions of Adhesives

34.4

301 87.4

Total Facility

122

301

91

12

12

6

43 (+/-)SeeNote

<50 <50

<25

<50 <25 operation of all fuel burning on-site. Actual emissions of VOCs fTom the fuel burning expected to much lower than 6 tpy. Therefore, emissions of VOCs from the laminating line, Nomex board production and adhesive usage exceed 43 tpy, long total actual VOC emissions at the site remain less than 50 tpy. Enforceable Operating

Restrictions The Facility presently

operates

under the limitations

imposed

by a Permit to Construct and Operate.

EHV Weidmann

proposes

to maintain

these limitations,

with the following
15EHV Weidmann

Industries,

Inc. modifications. 1."2. #AOP-O0-024

Eliminate conditions

pertaining

to existing Main Building

Boiler #2, Residual oil sulfur content restricted

to 0.5% by weight or less for the new boiler, andEmission of combustion

contaminants

from the new boiler are limited as follows:

Main BIdg.19.4MMBTU/hrBOiler#3

(Johnston)

0.12

0.53

0.040

2"4

10

0.8

3.5 Restrict fuel consumption

in the replacement

boiler to 558,500

gallons per year or less. Note the Agency proposes

to eliminate

an existing restriction

within the Permit to Construct and Operate

that limits total NOx emissions

at the :site to less than 100 tpy. The purpose

of this condition

was to specifically

keep EHV Weidmann

from being subject to the r/•asonably

available

control technology

("RACT")

requirements

in §5- 251(3) of the Regulations.

This was necessary

due to potential

emissions

beinggreater than 100 tpy based upon unrestricted

fuel consumption.

With the proposed

replacement boiler and fuel use restriction

noted in item 4. above, this condition

will not longer be necessary since potential

emissions

will 91 tpy. Additionally,.

the Agency proposes

to eliminate conditions

regarding

a monthly calculation

of site-wide

NOx emissions

and the semi-annual reporting

of NOx emissions.

These emissions

will still be reported

annually as part of the Agency's

annual registration

process. Identification of Insignificant

and Exempt Activities Activities which qualify as an "insignificant

activity" pursuant

to §5-1002(h)

of the Regulations need not be considered

when determining

the applicability

of Subchapter

X of the Regulations

and must only be listed as such within the operating

permit application. In its application,

EHV Weidmann

has identified

the below listed fuel burning equipment as having a heat input rating less.than

3 MMBTU/hr

and thus being classified as an "insignificant

activity" pursuant

to §5-1002(h)(1

)(i):

2.3.4. Three (3) No. 2 oil-fired boilers located in Fab North Building; Space Heater located in the Recycle

Building; Boiler located in the Training

Center; and Three propane-fired

roof top mounted

heating and cooling units installed

in 1999. The rated heat input for each unit is less than 300,000

BTU/hr. Other activities

classified

as producing

insignificant

emissions

include:

oil impregnation 16EHV Weidmann

Industries,

Inc. #AOP-O0-024 process, Nomex board lamination

process,

and finishing

application

(i.e., use of Zipguard product). Based on the estimated

emissions

produced

from these activities,

the Agency concurs with EHV Weidmann

that emissions

from these activities

need not be included and are considered

insignificant

activities

pursuant

to {}5-1002(h)(1

)(viii) of the Regulations.Although considered

"insignificant

activities"

within Subchapter

X of the Regulations, emissions from the above identified

activities

and equipment

must be quantified

(if possible) for the purposes

of establishing

allowable

emissions

for determining applicability with other air pollution

control requirements

(e.g., reasonably

available control technology,

major source status, Title V operating

permit applicability,

etc.). Consequently, allowable

emissions

for the Facility, as summarized

within this Technical Analysis, includes

emissions

produced

from the above listed activities

and equipment. Air contaminant

emissions

from the three roof mounted

heating and cooling units was not explicitly

calculated

since they are considered

negligible. The exclusion

of emissions

produced

by the insignificant

activities

does not alter the applicability status of the Facility under Subcha pter X of the Regulations.

4.0 MOST STRINGENT

EMISSION

RATE {}5-502(3) of Regulations

requires

that applicable

new major sources and major modifications achieve the Most Stringent

Emission

Rate ("MSER")

with respect to those air contaminants

for which it would have a "significant"

increase

in actual emissions. MSER must be achieved

for each proposed

physical

or operational

change which contributes to the increased

emissions

of the air contaminant.

As calculated

in item 3.2 above, the proposed

modification

is not subject to the requirements

in {}5-502 of the Regulations. However,

it should be noted that a major modification

at the Facility was approved in 1996. EHV Weidmann

was required

to achieve MSER for PM/PMlo

from the discharge of three fabric filter collectors

(#M41 in the Main Building and two Fab North collectors). MSER was established

as an emission

concentration

of 0.02 grains per dry standard cubic foot ("gr/dscf")

of undiluted

exhaust.
APPLICABLE REQUIREMENTS Citation and Description

of all Applicable

Requirements {}5-1006(e)(4) of the Regulations

requires

the owner/operator

of a stationary

air contaminant source to submit a complete

application

including,

but not limited to a demonstration of compliance

with all applicable

air pollution

control requirements.

These requirements include state and federal regulations,

and the requirements

of any construction permit issued under 10 V.S.A. {}556. Note that compliance

relative to {}5- 261 and {}5-1010

of the Regulations

will be discussed

separately

under paragraphs

6.0 and 7.0 of this Technical

Analysis. The compliance

analyses

and determinations

in this technical

analysis

rely on data and
17EHV Weidmann

Industries,

Inc. #AOP-O0-024 representations provided

by the Owner

Any statements

and conclusions regarding the compliance

status contained

herein are not binding against the state of .Vermont in any future legal or administrative

proceedings. Vermont Air Pollution

Control

Recjulations §5-201 and §5-202

Open Burning

Prohibited

and Permissible

Opening

Burning. Open burning of materials

is regulated

within these requirements.

EHV Weidmann periodically open burns natural wood pallets on-site after permission

is received

from local authorities. EHV Weidmann

has stated that it corn plies with these requirements. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. §5-211(2) Prohibition

of Visible Air Contaminants

Installations

Constructed Subsequent to April 30, 1970. This standard

applies facility-wide

and specifies

that visible air contaminant

emissions

may not exceed twenty (20) % opacity for a period of six (6) minutes or more in any hour, and at no time may they exceed sixty (60) % opacity. Primarily this standard

affects any source of particulate

matter emissions,

such as fuel burning equipment

and discharges

from the board machining

operations

and recycling

of laminated transformer

board. Compliance

with this standard

is based upon the procedures contained

in proposed

Reference

Method F-1 (51 Federal Register,

page 31076, August 29, 1986). EHV Weidmann

has stated that it complies

with the standard

based on their equipment maintenance. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility.§5-221(1)(a) Prohibition

of Potentially

Polluting

Materials

in Fuel. This section prohibits the use of.any fuel, in stationary

fuel burning equipment,

with a sulfur content more than 2.0% by weight. This prohibition

applies to all stationary

fuel burning equipment used on-site.

Compliance

with this standard

is based on fuel analyses following the procedures

prescribed

by the American

Society for Testing and Materials ("ASTM").EHV Weidmann

has stated that it complies

with this standard

based on the restrictions

in their existing permit, their proposed

limitation

for the new boiler, and their contract with fuel su ppliers. The continued

use of these methods

are sufficient

to ensure compliance

with this limitation in the future. The Agency may require EHV Weidmann

to perform oil sampling and analyses

to confirm compliance. §5-231(1) Prohibition

of PM; Industrial

Process

Emissions.

This standard

applies

18EHV Weidmann

Industries,

Inc. #A OP-O0-02

4 to any stack or vent associated

with an industrial

process at the Facility.

Primarily

this standard is of consequence

to anyindustrial

process which includes

a discharge

of PM/PM10, such as the fabric filter exhausts

serving the board machining

operations

and the recycling

of laminated

transformer

boards.

§5-231(1

of the Regulations

is divided into two subsections.

The first subsection,

subsection

(a), specifies

an emission

rate limit based upon the process weight of the production

process.

Where the process weight is considered

inappropriate,

such as wood processing

operations,

subsection

(b) identifies a PM/PM10

concentration

limit of 0.06 grains per dry standard

cubic-foot ("gddscf") of undiluted

exhaust.

The limit of 0.06 gr/dscf has been previously

determined to be applicable

to the fabric filter discharges

serving the board processing

operations. Compliance with tills standard

is based upon the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). Note, other methods,

such as the use of pressure

drop measurement devices on fabric filters, may be employed

as a means of monitoring

the performance of the control device and the likelihood

that such limitation

is being violated. PM/PM•o emission

limits for three fabric filter collectors

(#M41 in the Main Building and two collectors

in the Fab North Building)

are subject to more stringent

requirements

due to the application

of MSER. The MSER limits have been placed within the existing Permit to Construct

and Operate

and are specified

as 0.020 gr/dscf.

These permit restrictions overrule the limit derived from §5-231(1

)(b) of the Regulations

for the noted collectors. EHV Weidmann

has stated that it complies

with this section based upon the use of fabric filter collectors

and their emission

estimates. The Agency will assess compliance

with this standard

in the future as follows:

(1) EHV Weidmann will be required

to properly

operate and maintain

its fabric filter collectors,

(2) visual observations

of each exhaust will be conducted

during any Agency inspections

of the Facility, and (3) if visible emissions

are observed

to be •n excess of the limits specified in §5-211 (2) of the Regulations,

the Agency may require the performance

of a stack test to verify compliance

with the applicable

PM standard

or that other corrective measures be taken. §5-231(3)(a)(i) Prohibition

of PM; Combustion

Contaminants.

This standard applies to any fossil fuel burning equipment

with a rated heat input of 10 MMBTU/hr

or less. Specifically,

this standard

applies to the No. 2 oil-fired fuel burning equipment

(i.e., three boilers in the Fab North Building,

a space heater and make-up

air duct heater in the Recycling Building,

and a boiler in the Training

Center) operated

by EHV Weidmann. This standard

specifies

that PM emissions

may not exceed 0.5 Ibs/hr/MMBTU

of heat input. Compliance

with this standard

is generally

based on the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). EHV Weidmann

has stated that t complies

with the standard

based on their emission estimates and their scheduled

maintenance

of the fuel burning equipment. The Agency will assess compliance

with this standard

in the future as follows:

(1) EHV Weidmann will be required

to properly

operate and maintain

its fuel burning equipment, (2) visual observations

of each exhaust will be conducted

during any Agency inspections of the Facility, and (3) if visible emissions

are observed

to be in excess of the limits 19EHV Weidmann

Industries,

Inc. #AOP-O0-024 specified in §5-211 (2) of the Regulations,

the Agency may require the performance

of a stack test to verify compliance

with the above referenced

PM standard

or that other corrective measures

be taken.. §5-231(3)(a)(ii) Prohibition

of PM; Combustion

Contaminants.

The PM standard

in this section is applicable

to fuel burning equipment

with a heat input greater than 10 MMBTU/hr but equal to or less than 250 MMBTU/hr.

The PM standard

is in units of Ibs/hdMMBTU and varies based upon the heat input of the unit. The actual value of the standard is derived based upon the following

formula: Ep M ?. 10[?0.47039(log,o

HI)70,16936]
Where HI is the maximum

rated heat input of the unit in MMBTU/hr;

and EpM is the emission

rate in Ibs/hr/MMBTU. In accordance

with the above formula, the following

emission

standards

apply to Main Building Boiler #1 and the proposed

replacement

boiler: EpM for Cleaver Brooks 29.3 MMBTU/hr

Boiler 0.30 Ibs/hr/MMBTU;

and EpM for Johnston

19.4 MMBTU/hr

Boiler 0.37 Ibs/hr/MMBTU. Compliance with the standard

in §5-231 (3)(a)(ii) of the Regulations

is generally

based on the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). Note: A PM/PM10 emission limit for Main Building

Boiler #1 is identified

in the existing Permit to Construct and Operate

which is more stringent

than the above limitation.

This permit restriction overrules the limit derived from §5-23! (3)(a)(ii) of the Regulations.

Similarly,

EHV Weidmann has proposed

a more stringent

emissionlimitation

for the replacement

boiler. This limitation

will also overrule

the standard

derived from §5-231(3)(a)(ii)

of the Regulations. EHV Weidmann

has stated that it complies

with the standard

based on their emission estimates, and the scheduled

maintenance

of the boilers. Emissions of PM/PM10

will result from the burning of fuel in the boilers at the Facility.

The quantity of these emissions

produced

will depend upon the quality of their operation, maintenance, and the quality of the fuel being burned.

In an effort to maintain

compliance with this requirement

the Agency will require EHV Weidmann

to properly

maintain

and operate its fuel burning equipment

following

the manufacturer's

recommendations,

and that EHV.Weidmann

perform periodic maintenance

tuneups

on its equipment.

The Agency will also assess visible emissions

from the fuel burning equipment

while on-site performing inspections

of the Facility, and if visible emissions

are observed

to be in excess of the limits specified

in §5-2! 1 (2) of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standards or that other corrective

measures

be taken. §5-231(4) Prohibition

of PM; Fugitive

PM. This section requires

the use of fugitive PM control equipment

on all process operations

and the application

of reasonable
20EHV Weidmann

Industries,

Inc. #AOP-O0-024 precautions to prevent PM from becoming

airborne

during the handling,

transportation, and storage of materials,

or use of roads. This requirement

applies to the entire Facility and is of particular

concern with the board machining

operations

and recycling

of laminated transformer

boards. EHV Weidmann

has stated that it complies

with this requirement

based on the use of their fabric filter control devices on the board machining

operations. The Agency will verify compliance

with this requirement

in the future as follows:

(1) require the proper operation

and maintenance

of the fabric filter control devices,

(2) require the use of reasonable

precautions

to minimize

the generation

of PM/PM10

during the handling,

transportation,

storage and disposal

of PM1PM10

collected

by the fabric filter collectors, (3) application

of water or surfactants

to the haul roads and plant yard as necessary, (4) assess compliance

with this requirement

during any inspections

of the Facility, and (5) require the use of additional

measures

if found necessary

duringa compliance inspection. §5-241(1) & (2) Prohibition

of Nuisance

and Odor. This requirement

applies to the entire Facility and prohibits

the discharge

of air contaminants

that would be a nuisance

to the public or be source of objectionable

odors beyond the property-line

of the Facility. EHV Weidmann

has stated that it complies

with this requirement

due to their observation of dust and odors from the operations. The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all com plaints that it receives in order to determine

whether

or not there is a violation

of this requirement. §5-701 Maintenance

and Removal

of Control

Devices.

This section prohibits

the alteration or removal

of a motor vehicles

air pollution

control system, as well as the proper maintenance

of such systems.

These requirements

apply to any motor vehicles owned and operated

by EHV Weidmann. EHV Weidmann

has stated that it complies

with these requirements. The Agency will verify compliance

with this requirement

in the future. §5-702 Excessive

Smoke Emissions

from Motor Vehicles.

Prohibits

the discharge of excessive

visible air contaminants

from a motor vehicle for longer than five (5) consecutive seconds.

This requirement

applies to any motor vehicle owned and operated by EHV Weidmann. EHV Weidmann

has stated that it complies

with this requirement. The Agency will verify compliance

with this requirement

in the future. Subcha pter VIII Registration

of Air Contaminant

Source.

This Subchapter

requires the owner or operator

of a stationary

source register with the Agency if the source 21EHV Weidmann

Industries,

Inc. #AOP-O0-024 produces five (5) tons per year or greater of actual emissions

during the preceding calendar year. The owner or operator

of a source is required

to submit information regarding their operations

and pay a fee based upon the quantity of emissions

they produce and the fuels that they use at the source. EHV Weidmann

has stated that it complies

with this requirement

based on the information they have submitted

and the fees they have paid in preceding

years. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. §5-911 MotorVehicle

Air Conditioning.

Requirements

pertaining

to repair and service of motor vehicle air conditioners

and the use of chlorofluorocarbons

("CFCs"). These requirements

apply to the maintenance

of any air conditioning

equipment

present in any motor vehicle owned and operated

byEHV Weidmann. EHV Weidmann

has stated that it complies

with these requirements. The Agency will verify compliance

with these requirements

in the future. §5-921 Regulation

of Ozone-Depleting

Products.

Prohibits

the selling of fire extinguishers containing

halons and ozone depleting

products,

except for commercial

or industrial usage or unless sold to fire departments

for their own use in fighting fires. EHV Weidmann

has stated that it complies

with these requirements. The Agency will verify compliance

with these requirements

in the future. Air Pollution

Control

Permit to Construct Pursuant to §5-1002(d)(1)

of the Regulations,

the conditions

of any permit issued under the authority

in 10 V.S.A. §556 and its regulations

are considered

applicable requirements. EHV Weidmann

operates

under the confir•es

of an existing site-wide Permit to Construct

and Operate

issued on May 19, 1999. The conditions

of this Permit to Construct

and Operate

will carryover

into any new permit issued to EHV Weidmann approving the proposed

boiler replacement.

Some changes

in the existing permit conditions will be necessary

to acknowledge

the replacement

of Main Building

Boiler #2. Summarized below are the existing permit conditions. Condition (1) Modify and operate the Facility in accordance

with plans and specifications submitted

to the Agency. EHV Weidmann

has stated that it complies

with this requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (2) Requires

the control of PM from the board machining

operations

and recycling of laminated

transformer

boards by installing,

operating,

and maintaining

fabric 22EHV Weidmann

Industries,

Inc. filter collectors. EHV Weidmann

has stated that it complies

with this requirement. #AOP-O0-024

The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility. Condition (3} Limitations

on PM/PM10

emissions

from equipment

served by fabric filter collectors.EHV Weidmann

has stated that it complies

with this requirement

based upon their emission estimates. The Agency will assess compliance

with this standard

in the future as follows:

(1.) EHV Weidmann will be required

to properly

operate and maintain

its fabric filter collectors,

(2) visual observations

of each exhaust will be conducted

during any Agency inspections

of the Facility, and (3) if visible air contaminant

emissions

are observed

to be in excess of the limits specified

in {}5-211 (2) of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standards or that other corrective

measures

be taken. Condition (4) Limitations

on combustion

contaminants

from two boilers located in the Main Building and the planned

new make-up

air duct heater to be located in the Recycling Building.EHV Weidmann

has stated thatit complies

with this requirement

based upon their emissions estimates,

and their maintenance

and operation

of their fuel burning equipment. The Agency will assess compliance

with this standard

in the future as follows:

(1) EHV Weidmann will be required

to properly

operate and maintain

its fuel burning equipment, (2) perform visual observations

of the exhaust during any Agency inspections

of the Facility, and (3) if visible air contaminant

emissions

are observed

to be in excess of the limits specified

in {}5-211 (2) of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

standards

or other corrective measures

be taken. Conditions (5) and (6) Emissions

of VOCs and acetone

from the Facility are limited to less than 50 tpy. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility.

The Agency will also require the submittal

of semi-annual reports summarizing

production

data in order to verify compliance

with these limits, and EHV Weidmann

will be obligated

to certify compliance

with this requirement

at least once each year as part of the Agency's

registration

program

required

under Subchapter

VIII of 23EHV Weidmann

Industries,

Inc. #AOP-O0-024 the Regulations. Condition (7) Emissions

of NOx from the Facility are limited to less than 100 tpy. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility.

The Agency will also require the submittal

of semi-annual reports summarizing

fuel use data in order to verify compliance

with this limit, and EHV Weidmann will be obligated

to certify compliance

with this requirement

at least once each year as part of the Agency's

registration

program

required

under Subchapter

VIII of the Regulations. Condition (8) Visible air contaminant

emissions

limitations.

This specifies

the opacity limits that apply to Facility.

This standard

is based on the limits of §5-211 (2) of the Regulations. EHV Weidmann

has stated that it complies

with this requirement

based on their observation of the operations

and equipment

maintenance. The Agency will verify compliance

with this standard

in thefuture

during any inspections of the Facility. Condition (9) Restricts

the sulfur content of fuel oil burned in the boilers located in the Main Building.

Boilers may not burn fuel oil with a sulfur content greater than 2.0% by weight. Note, this condition

will be revised in order to specify a more stringent

sulfur content limitation

for the replacement

boiler. EHV Weidmann

has stated that it complies

with this standard

based on the restrictions

in their Permit to Construct

and their contract with fuel suppliers. The continued

use of these methods

are sufficient

to ensure compliance

with this limitation in the future. The Agency may require EHV Weidmann

to perform oil sampling and analyses

as appropriate

to confirm compliance. Condition (10) Restricts

the sulfur content of fuel oil burned in the No. 2 oil-fired fuel burning equipment

located at the Facility.

No. 2 oil-fired fuel burning equipment

may not burn fuel oil with a sulfur content greater than 0.5% by weight. EHV Weidmann

has stated that it complies

with this standard

based on the restrictions

in their Permit to Construct

and their contract with fuel suppliers. The continued

use of these methods

are sufficient

to ensure compliance

with this limitation in the future. The Agency may require EHV Weidmann

to perform oil sampling and analyses

as appropriate

to confirm compliance. Condition (11) Requires

EHV Weidmann

to notify the Agency in writing of the initial start•up of the planned

fabric filter to be located within the Recycling

Building. 24EHV Weidmann

Industries,

Inc. #AOP-O0-024 EHV plans to comply with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Condition (12) Requires

EHV Weidmann

to maintain

a Iog•)ook of maintenance performed and monthly observations

of the pressure

drop across each fabric filter. EHV Weidmann

has stated that it complies

with this requirement. The Agency will verify compliance

with this standard

in the future during any.inspections of the Facility. Condition (13) Requires

EHV Weidmann

to maintain

a logbook of maintenance performed on the fuel burning equipment

at the Facility. EHV Weidmann

has stated that it complies

with this requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Condition (14) Record keeping

requirements

for material

usage, fuel consumption, and board production. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility.

The Agency requests

the submittal

of above noted records as part of the Agency's

registration

program

required

under Subchapter

VIII of the Regulations. Condition (15) Requirement

to register if actual emissions

are greater than or equal to 5 tpy for the preceding

calendar

year. EHV Weidmann

has stated that it complies

with this requirement

based on the information they have submitted

and the fees they have paid for preceding

calendar years.The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Condition (16) Required

to notify the Agency of any proposed

physical

or operational change at the Facility which may increase

air contaminant

emissions. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any •nspections of the Facility.

25EHV Weidmann

Industries,

Inc. #AOP-O0-024 Condition (17) Required

to notify the Agency •n writing within ten (10) days of any violation.
Conditions (18) (22) Miscellaneous

reporting

and record keeping requirements, including compliance

certifications. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Condition (23)- Requires

the use of reasonable

precautions

to minimize

the generation of fugitive emissions.of

PM/PM10

and VOCs from the Facility. EHV Weidmann

has stated that it complies

with this requirement. The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Conditions (24) and (25) Prohibits

the discharge

of air contaminants

that would be a nuisance to the general public or a source of objectionable

odors. EHV Weidmann

has stated that it complies

with this requirement

due to their observation of dust and odors from their operations. The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all complaints

that it receives in order to determine

whether

or not there is a violation

of this requirement. Condition (26) Prohibition

of circumvention. Condition (27) and (28) Prohibition

of opening

burning and permissible

open burning. Condition (29) Motor vehicle requirements. Condition (32).- Stratospheric

ozone protection

measures. Condition (33} Permit shield condition. EHV Weidmann

has stated that it complies

with the requirements

in conditions

(26) through (33). The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Conditions (34) through

(48) Agency standard

conditions.

26EHV Weidmann

Industries,

Inc. #AOP-O0-024

27EHV Weidmann

Industries,

Inc. #AOP-O0-024 Federal Air Pollution

Control

Re,qulations Clean Air Act, Title I-Air Pollution

Prevention

and Control,

Part A -. Air Quality and Emission

Limitations,

§111 Standards

of Performance

for New Stationary Sources. EHV Weidmann

is subject to one applicable

federal new source performance standards established

under §111 of the federal Clean AirActand

promulgated

within Title 40 Code of Federal Regulations

("CFR") Part 60. 40 CFRPart

60 Subpart

Dc- The replacement

boiler (19.4 MMBTU/hr

boiler) is considered an affected

facility subject to 40 CFR Part 60 Subpart Dc Standards

of Performance for Small Industrial-Commercial-Institutional Steam Generating

Units. Subpart Dc specifies

emission

limitations

for PM/PM10,

SO2, and opacity, as well as monitoring, record keeping,

notification

and reporting

requirements.

Applicability

to Subpart Dc also subjects

EHV Weidmann

to the general notification,

record keeping,

and other requirements

of 40 CFR Part 60 Subpart A. EHV Weidmann

has stated that it complies

with these requirements. The Agency will incorporate

the applicable

requirements

of 40 CFR Part 60 Subpart A and Dc within any permit issued to EHV Weidmann

approving

the proposed modifications. Section 112 of the Clean Air Act National

Emission

Standards

for Hazardous

Air Pollutants (NESHAPs) No promulgated

NESHAPs

in 40 CFR Part 61 currently

apply to EHV Weidmann. There are currently

no promulgated

NESHAPs

in 40 CFR Part 63 that apply to EHV Weidmann. The NESHAPs

in 40 CFR Part 63 identify the "maximum

achievable

control technology" ("MACT")

standards

for major sources of hazardous

air pollutants

("HAPs"). Although there is currently

no MACT standard

that applies to EHV Weidmann,

the U.S. EPA has proposed

a MACT standard

for the pulp and paperboard

industry.

Also, the U.S. EPA has identified

EHV Weidmann

as a potential

source subject to this proposed MACT standard.

In response

to U.S. EPA's proposed

NESHAP,

EHV Weidmann investigated its emissions

from the pulping operations

and stated that the pro posed MACT standard

for the pulp and paperboard

industry does not apply to them. This determination was based upon the fact that the Facility engages

in no pulping, no bleaching, and the boardmaking

operations

result in negligible

emissions

(only trace amounts of acetone

released).

The Agency concurs with this assessment,

and therefore, this Facility does not qualify as a major source for the pulp and paperboard MACT standard. Although EHV Weidmann

is not a major source from the paperboard

making lines, it should be noted that "allowable"

emissions

of styrene (a federal HAP) exceed 10 tpy from the laminating

operations.

Since these emissions

are from board laminating

and not the board making lines, these em=ssions

do notqualify

the Facility under the pulp and

28EHV Weidmann

Industries,

Inc. #AOP-O0-024 paperboard MACT standard.

Ultimately,

EHV Weidmann

will be required

to achieve MACT for styrene at sometime

in the future if either the U.S. EPA adopts a MACT standard that applies to the laminating

operations,

or a case-by-case

MACT determination is required

as a consequence

of new source review (i.e., Subchapter

V of the Regulations

Permit to Construct/Modify).

The proposed

modification

will not result in an emissions

ncrease of styrene from the Facility, and therefore,

does not trigger the case-by-case MACT determination. 40 CFR Part 64 Compliance

Assurance

Monitoring.

Pursuant

to requirements concerning enhanced

monitoring

and compliance

certification

under the C/ean Air Act- ("CAA"), EPA promulgated

new regulations

and revised regulations

on October

22, 1997. These new requirements

implemented

compliance

assurance

monitoring

("CAM") for major stationary

sources of air pollution

that are required to Obtain operating

permits under Title V of the CAA. Subject to certain exemptions,

the new regulations

require owners or operators

of such sources to conduct

monitoring

that satisfies

particular criteria established

in the rule as a means of providing

a reasonable

assurance

of compliance with applicable

requirements.

Compliance

assurance

monitoring

is proposed to focus on emissions

units that rely on pollution

control equipment

to achieve compliance with applicable

standards.

The regulations

also provide procedures

for coordinating these new requirements

with the operating

permit program

regulations.

As a result of comments

received

during the rule making process and the lengthy delay in the adoption

of the CAM rule, U.S. EPA provided

an extended

implementation

schedule for this rule. Facilities

which had submitted

a complete

operating

permit application

prior to April 20, 1998, were not required

to address

CAM as part of their initial operating

permit application, unless.they

proposed

to make significant

changes

to the facility subsequent to this date and the facility operated

"large" pollutant

specific emission

units ("PSEU").

A "large PSEU" is defined as a unit with post control emissions

greater than or equal to the major source threshold. §64.2 in 40 CFR Part 64 specifies

that each PSEU at a facility that meets a three-part test is subject to the requirements

for CAM. An emission

unit must: (A) Be subject to an emission

limitation

or standard, (B) Use a control device to achieve compliance,

and (C) Have pro-control

emissions

that exceed or are equivalent

to the major source threshold in 40 CFR Part 70 (i.e., 10.tpy individual

HAP, 25 tpy total HAPs, 50 tpy VOCs, or 100 tpy for any other air contaminant). Note that the term "control device" means equipment,

other than inherent

process equipment, that is used to destroy or remove air pollutant(s)

prior to discharge

to the atmosphere. The term "control device" does not include passive methods

Such as lids or seals, use of low-polluting

fuels or inherent

process

equipment

provided

for safety or material recovery.

Additionally,

the CAM rule provides

some exemptions,

such as an exemption for any affected facility subject to an NSPS or NESHAP

promulgated

after November 15, 1990. Since EHV Weidmann

does not meet the above three part test for its boilers and transformer board manufacturing

operations,

it is not subject to the requirements

for 29EHV Weidmann

Industries,

Inc. #AOP-O0-024 CAM. 5.2 Citation and Identification

of Requirements

For Which a Permit Shield Provision

Has Been Requested Pursuant to §5-1015(a)(11

of.the Regulations,

an owner/operator

may request to be shielded from specific state or federal requirements

which do not apply to the subject source. If the applicability

of a regulatory

requirement

is unclear to the applicant,

when appropriate, the Agency may grant a permit shield stating that the requirement

does not apply to the source. Once a permit shield is granted,

the Agency may not initiate any enforcement action against the Facility based upon a regulation

or standard

covered

by the permit-shield.

The Agency would be required

to amend the Permit to Operate

and incorporate the applicable

requirement

prior to initiating

any enforcement

action fornoncompliance with the applicable

requirement.

The Agency's

permit shield determinations are based upon the information

submitted

by the owner/operator

in its operating

permit application. The resulting

permit shield shall be effectivejonly.with

res pect to activities disclosed in the application. It is the Agency's

procedure

to grant permit shields only for those requirements

or standards which conceivably

could apply to the Facility, and the Agency has made a determination that such requirement

does not in fact apply. The Agency does not intend to grant permit shields for those requirements

that clearly do not apply,to the Facility.

For example, an asphalt plant will not be granted a permit shield from a regulation

applying

to a dry cleaning

operation. EHV Weidmann

has requested

to be shielded

from several potentially

applicable requirements. These are identified

in Exhibit D of the operating

permit application

filed on February 12, 1996. For the reasons

stated in the preceding

paragraph,

the Agency did not grant a permit shield, in the subsequently

issued operating

permit, for each of the requirements requested

in EHV Weidmann's

application.

The Agency granted a permit shield for the state and federal regulations

listed in Table 5-1 below. These permit shields will be continued

into any permit issued by the Agency granting

approval

for the proposed boiler replacement,

with one exception.

The Agency will remove the permit shield granted for 40 CFR Part 60 Subpart Dc, since the new boiler will be subject to this requirement. The permit shields shall be binding only with respect to the activities disclosed in EHV Weidmann's

application.

Where the Agency has denied a shield, the basis for the determination

is. explained

in the Agency's

Technical

Analysis

dated May 11, 1999. Table 5-1: Permit Shield Determinations

§5-241(3) of Regulations

Prohibition of Nuisance and Odor Control of Odor from Industrial Processes Granted

30EHV Weidmann

Industries,

Inc. #AOP-O0-024

§5-251 (1) of Regulations §5-251 (3) of Regulations

§5-252 of Regulations §5-253.10 of Regulations §5-253.14 of Regulations §5-253.20 of Regulations Control of Nitrogen Oxide Emissions Control of Nitrogen Oxide Emissions

Reasonably Available Control Technology

for Large Stationary Sources Control of Sulfur Dioxide Emissions Control of VOCs Paper Coating Control of VOCs Solvent Metal Cleaning Control of VOCs Other Sources That Emit Volatile Organic Compounds GrantedGranted

GrantedGrantedGrantedGranted
5.3 Description

of Alternative

Operating

Scenarios

and Related Applicable

Requirements

Not Previously Identified EHV Weidmann

requested

the below listed alternative

operating

scenarios

as part of its application for a Permit to Operate. EHV Weidmann

projects that boardmaking

production

will increase

10% annually for the next seven (7) years. At the seventh year (2002) total production

of boards will be approximately

45.7 million pounds of board. This is a 114% increase

in production from 1994. EHV Weidmann

projects that the laminating

line will increase

production

a maximum of 50% over the next seven (7) years. EHV Weidmann

expects to add another shift to accommodate

the increase

•n production. The production

of NOMEX

boards has the potential

to triple over the next seven (7) years. To compensate

for the increase

in production,

the NOMEX

production will either be operating

more hours per day or more days per year. In either case, the maximum

production

rate will still be 130.4 Ibs/hr. With the projected

increase

in boardmaking

production,

the demand

for process steam will also increase.

It is assumed

that the quantity

of process

steam produced is linearly proportional

to the pounds of boards produced.

Since an overall increase

in board production

is projected

to be approximately

114%, a 114% increase

in fuel usage and steam production

=s anticipated. The projected

increase

in boardmaking

production

may result in the installation

of new machining

equipment

and a corresponding

increase

in the quantity of PM/PMlo emissions

being vented to the existing fabric filter collectors.

The increase in production

may also necessitate

the installation

of a new collector.

31EHV Weidmann

Industries,

Inc. #AOP-O0-024 With the projected

increase

in boardmaking

production,

the usage of adhesives

is anticipated to •ncrease.

It is assumed

that the quantity of adhesive

usage is linearly proportional

to the pounds of boards produced.

Since an overall increase in board production

is projected

to be approximately

114%, a 114% increase

in adhesive usage is projected.

5.4 The following

summarizes

the Agency's

determination

regarding

the incorporation

of the above identified

alternative

operating

scenarios

within the Permit to Operate.

Increases in the hours of operation

and/or production

need not be included

as an alternative operating scenario

within the Permit to Operate,

if such changes

are made without the installation of new equipment

and are not prohibited

by a term or condition

of a Permit. The definition

of modification

in §5-101 of the Regulations

allows such changes

in the method of operation

without triggering

new source review pursuant

to. 10 V.S.A. §556 and §5-501 of the Regulations.

If such changes

will necessitate

the installation

of additional equipment

or will result in an exceedance

of a permit term or limit, then EHV Weidmann must contact the Agency in order to determine

if such modification

would qualify for new source rewew. The current Permit to Construct

and Operate

provides

some operational

flexibility

for the source to accommodate

an increase

•n production

at the Facility.

The Permit to Construct and Operate

limits VOC and acetone

emissions

to less than 50 tpy each, allowable emissions

from the boilers assume nearly continuous

operation,

and the fabric filters are limited based upon maximum

discharge

rates. There are no limits on the production rate of any equipment

or hours of operation.

As long as VOC, acetone,

and fabric filter PM/PMlo

discharge

rates remain below their respective

limits, and no new equipment is installed,

EHV Weidmann

may increase

its board production.

If increased production will, for example,

require a new boiler or an increase

in the emissions

limits, then EHV Weidmann

will be required

to amend its existing Permit to Construct

and Operate and be subjected

to the requirements

of new source review. Equivalency and Streamlining Particulate Matter PM/PM10 emission

limits for the residual oil-fired boilers are identified

in Condition

(4) of the existing Permit to Construct

and Operate

for the Facility.

The limits within Condition (4) are more stringent

and therefore

overrule

the limits derived from §5-231(3)(a)(ii)

of the Regulations. PM/PMlo emission

limits for three fabric Jilter collectors

(#M41 in the Main Building and two collectors

at the Fab North Building)

are identified

in Condition

(3) of the existing Permit to Construct

and Operate

for the Facility.

The limits within Condition

(3) are more stringent and therefore

overrule

the limits derived from §5-231 (1)(b) of the Regulations. Sulfur Content For the replacement

boiler, EHV Weidmann

proposes

to comply with 40 CFR Part 60 through the purchase

and use of low sulfur residual oil (maximum

sulfur content of 0.5% by weight or less). This restriction

will be incorporated

as a condition

of any permit

32EHV Weidmann

Industries,

Inc. #AOP-O0-024 issued approving

the installation

of the re placement

boiler. This proposed

restriction

is more stringent

than and therefore

overrules

the limit specified

in {}5-221 (1) of the Regulations.

33EHV Weidmann

Industries,

Inc. #A 0P-00-024 6.0 HAZARDOUS

AIR CONTAMINANTS §5-261 of the Regulations

addresses

the release of hazardous

air contaminants (,HACs") into the ambient

air. Unless specifically

exempted

from §5-261, the owner or operator of a source must quantify

its emissions

of HACs regulated

by this rule. Any source whose actual emission

rate of a HAC exceeds

its respective

Action Level ("AL") is subject to the rule for that HAC, and the owner or operator

of the source must then demonstrate that emissions

of the HAC are minimized

to the greatest

extent practicable. This process is termed the "Hazardous

Most Stringent

Emission

Rate" or HMSER.

An air quality impact evaluation

may also be required

to further assess the ambient

impacts that may be attributable

to the source. The evaluation

of the air quality impacts is performed using the Hazardous

Ambient

Air Standards

("HAAS")

or Stationary

Source Hazardous Air Impact Standard

("SSHAIS")

contained

in the Regulations. 6.1 Quantification

of Hazardous

Air Contaminant

("HAC") Emissions Solid fuel burning equipment

(not including

incinerators)

installed

or constructed

prior to January 1, 1993, and all fuel burning equipment

which combusts

virgin liquid or gaseous fuel is exempted

from review pursuant

to §5-261 (1)(b)(ii) of the Regulations.

Based on this exemption,

no fuel burning equipment

used at the Facility qualified

for review of HAC emissions under §5-261 of the Regulations. The production

of transformer

boards does result in the discharge

of HACs from the laminating line, Nomex.board

production,

and general usage of adhesives

on-site. These emissions have been quantified

and compared

to their respective

Action Levels in order to determine

applicability

to §5-261 of the Regulations.

Emissions

of PM/PM10

resulting from the board machining

equipment

were not considered,

since such emissions

are not classified as a HAC in Appendix

B of the Regulations. Summarized in Table 6-1 are the estimated

HAC emissions

resulting

from the production process, as well as a comparison

to the respective

AL. The values in Table 6-1 were derived from a 1999 inspection

re port conducted

bythe Agency (last report on file). It should be noted that with the anticipated

increase

in production

identified

in paragraph 5.3 above, the actual emission

rate of any particular

HAC may increase

over the next seven (7) years. In order to address

the Agency's

concern with any potential exceedance of an AL in the future, EHV Weidmann

will be required

to certify at least once each year that it complies

with the requirements

of §5-261 of the Regulations. Table 6-1: Comparison

of HAC Emission

Rates to Action Levels

Vinyl acetateStyreneAcetone 108-05-4

0.3

14.7 100-42-5 24

42.5 67-64-1 68

7,480

34EHV Weidmann

Industries,

Inc.!1Dimethyl acetamide #AOP-O0-024

6.2 Based upon the information

in Table 6-1 above, EHV Weidmann

does not currently produce emissions

in excess of any AL. Therefore,

EHV Weidmann

is not subject to §5- 261 of the Regulations. Federal Hazardous

Air Pollutants Although exempt from §5-261 of the Regulations,

the U.S. EPA has identified

industrialinstitutional-commercial boilers as a potential

source that will be regulatedby

a "maximum achievable

control.technology"

("MACT")

standard

in the future. Emissions

of federally regulated

HAPs have been estimated

for the No. 6 oil-fired boilers, the units most likely to be regulated

by the federal MACT standard,

and summed

with VOC HAPs produced by the board production

process.

See Table 6-2 below for a summary

of HAP emissions from the Facility.

Currently,

total HAP emissions

from the Facility are estimated to be less than 25 tpy, and no individual

HAP is emitted at a rate of 10 tpy or greater. It should be noted, however,

that with the anticipated

increase

in production identified in paragraph

5.3 above, the actual emission

rates of HAPs will increase.

It is anticipated that EHV Weidmann

may produce

emissions

of styrene in excess of 10 tpy in the future, and thus may be subject to achieving

the MACT for styrene.

Based upon maximum potential

emissions

of HAPs from the boilers, it does not appear that EHV Weidmann will be a major source of HAPs due to fuel combustion. Table 6-2: HAP Emission

Rates

Constituent ' '•

CAS#

Emiss 0ii Rate I I.

(tpy) AntimonyArsenicBenzeneBerylliumCadmiumChromiumCobaltEthylbenzene Formaldehyde LeadManganeseMercuryNaphthalene 0071-43-2

0.00027 0 0.000036 000 0.00670.0017

0.000510.000830.0077 100-41-4 0.00082 50-00-0 0.001

0091-20-3 0.00190.00390.000150.0015

35EHV Weidmann

Industries,

Inc. #AOP-O0-024

Nickelo-XylenePolycyclic Organic Matter (POM) SeleniumStyrene1,1,1-Trichloroethane TolueneVinyl acetate TOTAL 1330-20-700100-42-571-55-6108-88-3108-05-4

0.110.000140.0017o.000887*0.000300.00800.07"7 Includes the actual emission rate from 1999.
7.0 REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the.Agency

has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility under {}5-1010 of the Regulations. Therefore, the Facility is currently

in compliance

with this requirement.

The Agency will notify EHV Weidmann

if any applicable

RACT requirement

applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensure that EHV Weidmann

complies

with such requirement

at that time.
8.0 AMBIENT

AIR QUALITY

IM PACT EVALUATION

(Criteria

Pollutants). An air quality impact evaluation

is performed

to demonstrate

whether

or not a proposed project will cause or contribute

to violations

of the ambient air quality standards

and/or significantly deteriorate

existing air quality. The Agency's

implementation

procedures concerning the need for an ambient

air quality impact evaluation

under {}5-501 of the Regulations, specifies

that such analyses

shall be performed

when project results in allowable emissions

increase

of ten (10) tpy or more of any air contaminant,

excluding VOCs. Additionally,

the Agency may require an air quality impact evaluation

where the short-term allowable

emission

rates will significantly

increase

as a result of a project. The Agency has not required

an air quality impact evaluation

as part of the application

for the proposed

modifications,

since site-wide

allowable

emissions

will decrease.
9.09.1 COMPLIANCE

PLAN Description of the Compliance

Status for Each Applicable

Requirement See paragraph

5.0 above.

36EHV Weidmann

Industries,

Inc. #AOP-O0-024 9.2 Compliance

Schedule

For Each Applicable

Requirement

for Which the Source is Not in Compliance Not applicable

to this Facility. 10.0 PUBLIC

PARTICIPATION The Facility operated

by EHV Weidmann

is classified

as a "Title V Subject Source,"

and consequently, any application

for a Permit to Operate

this Facility is subject to the public participation requirements

of {}5-1007

of the Regulations.

As required

by this section, the Agency published

noticed on October

31, 2000, in the Caledonian

Record that it had received an administratively

complete

application

from EHV Weidmann.

Additionally,

the Agency notified the affected

states of New Hampshire,

Massachusetts,

and New York of the receipt of this application

on October

26, 2000. On November

6, 2000,.the

Agency determined it received

sufficient

information

to declare the application

technically complete.On November

9, 2000, the Agency published

notice in the Caledonian

Record informing the public of the Agency's

plans to issue a draft Air Pollution

Control Permit to Construct and Operate.

The notice solicited

comments

and requests

for an informational

meeting on the matter. Requests

for an informational

meeting

had to be received

in writing on or before December

4, 2000. The Agency notified the affected

states (i.e., New Hampshire, New York, and Massachusetts)

and the U.S. EPA of its draft decision

on November

6, 2000. The public comment

period closed on December

8, 2000, without the Agency receiving comments

or a request for an informational

meeting.

11.0 CONCLUSIONS Based on the foregoing

technical

analysis

of the proposed

modification,

the following conclusions are made: The proposed

modification,

subject to the recommended

permit conditions,

will meet the applicable

emission

standards

contained

in state and federal regulations. Furthermore,

it is expected

that emissions

from the proposed modification will not significantly

deteriorate

air quality, nor will they cause or contribute to a violation

of an ambient air quality standard. Pursuant to regulatory

definition,

the proposed

project is designated

as anonmajor modification

to an existing major stationary

source. C. Recommended

Permit Conditions

See draft permit.

Consistent with 10 V.S.A. §556(e) and for the purposes

of reducing

the administrative burden of enforcing

two separate

permits,

the Agency proposes

to issue a combined

the issuance of the Air Pollution

Control Permit to Construct

with the Air Pollution

Control Permit to Operate.
37EHV Weidmann

Industries,

Inc. #AOP-O0-024

38APPENDICESAppendix A Figure 1 Plant Location

(USGS Map) Figure 2 Plant Layout Figure 4 Boardmaking

Line #1 Process

Flow Figure 5 Boardmaking

Line #2 Process

Flow Figure 6 Laminating

Line Process

Flow Figure 7 Fab West Activities Figure 8 Fab North Activities Figure'9- Oil Impregnation

Process

Flow Appendix B Table 1 -Allowable

Emissions

Estimates Tables 2 & 3 Complete

List of Stacks, Vents and Emission

Points[l'his Page Intentionally

Left Blank]

40Table

Existing Allowable Emissions Facility: EHV Weidmann Industries, Inc., St. Johnsbury Date: 10/20/2000 Author:

JLP

FUEL COMBUSTION

EMISSIONS Location: Main Bldg. Main Bldg. ID. #:

Boiler #1 Boiler #2 Fuel No. 6 Oil No. 6 Oil Unit Type:

Boiler

Boiler Manuf.: CIv-Brks

CIv-Brks Rated Output (HP):

700

350 Rated HI (MMBTU/hr): 29.3

14.6 Fuel Sulfur (% by wt.):

2

2 Fuel BTU {MMBTU/gal): 0.15

0.15 Max. Firing Rate (gph):

195.5

97.5 Potential Hrs. of Operation:

8.760

8,760 Load (%): 100

100 Potential Fuel Combustion:

1,712,580

854,100 Allowable Fuel Combustion: Fab NorthBoiler #1No. 2 OilBoilerPeerless Fab NorthBoiler #2No. 2 Oil[•oilerPeedess Fab NorthBoiler #3No. 2 OilBoiler RecycleHeater #1No. 2 OilHeater TrainingBoiler #1No. 2 OilBoiler RecycleDuct HeaterNo. 2 OilHeaterCox Manuf. 25 2.67 2.67

1.05

0.1

0.13

0.525 0.5 0.5

0.5

0.5

0.5

0.5 0.14 0.14

0.14

0.14

0.14

0.14 19 19

7.58

0.85

1.15

4.5 8,760 8,760

8,760

8,760

8,760

8,760 100 100

100

100

100

100 166,440 166,440

66,401

7,446

10,074

39,420 Facility Total Fuel Consumption: No. 6 Oil

2,566,680 No. 2 Oil

456,221 Emissions of all combustion contaminants based on emission factors Emissions from Cleaver Brooks and Peerless equipment based upon manufacturers

emission factors. while the heaters and boilers < 25 hp based upon U.S. EPA emission factors published in AP-42 Section 1.3. (Exception: Duct heater PM emission rate based upon PM limit specified in Section 5-231 of the Regulations and continuous operation)

CIv-Brks Peerless

AP-42 Factors Peerless

Other No. 6 Factors No. 2 Factors No. 2 Commercial

No. 6 Oil No. 2 Oil No. 2 Oil Total Ibs/1000 gals bs/1000 gals Ibs/1000 gals

tpy

tpy

tpy

tpy PM/PM10 31.8

4.2

2

40.8

0.7

1.5 SO2 307.2

71

71

394:2

11.8

4.4 Nox 73.4

28

20

94.2

4.7

1.2 .CO 11.2

neg.

5

14.4

neg.

0.3 NMHCs 5.3

4.1

0.34 6.8

0.7

0.0 HAPs

43.0410.4100.114.77.5EPA

HAP Emissions from Residual Oil-Fired Boilers. Quantified in order to determine whether or not EHV Weidmann is a potential major HAP source and applicability to future MACT standard for industrial fossil fuel-fired boilers. Emissions from distillate oil-fired equipment were not considered., since these units would not likely.be considered within the MACT standard (i.e., too small). Emissions derived from AP-42 emission factors published in Table 1.3-8. Emission based upon unlimited operation at full load (equivalent to 2,566,680 gpy of No. 6 Oil)

POLLUTANT AP-42 EMISSION

BOILER #1

BOILER #2

TOTAL FACTOR EMISSION RATE

EMISSION RATE

EMISSION RATE (Ibs/1000 gals)

(Ibs/hr)

(Ibs/hr)

(tpy)

POM 0.0013 0.00

0.00

0.00 Formaldehyde 0.033 0.01

0.00

0.04 Benzene 0.000214 0.00

0.00

0.00 Ethylbenzene 0.0000836 0.00

0.00

0.00 Naphthalene 0.00113 0.00

0.00

0.00 1,1,1-Trichloroethane 0.000236 0.00

0.00

0.00 Toluene 0.0062 0.00

0.00

0.01 o-Xylene 0.000109 0.00

0,00

0.00 Antimony 0.00525 0.00

0.00

0.01 Arsenic 0.00132 0.00

0.00

0.00 Beryllium 0.0000278 0.00

0.00

0.00 Cadmium 0.000398 0.00

0.00

0.00 Chromium 0.000845 0.00

0.00

0.00 Coball 0.00602 0.00

0.00

0.01 Lead 0.00151 0.00

0.00

0.00 Manganese 0.003 0.00

0.00

0.00 Mercury 0.000113 0.00

0.00

0.00 Nickel 0.0845 0.02

0.01

0.11 Selenium 0.000683 0.00

0.00

0.00
TOTAL HAPs 0.15 0.! 9

PROCi=SS EMISSIONS Fabdc Filter Collectors: Emissions have been estimated based on a maximum permitted PM discharge concentration for each fabric filter collector.

ID# Collector ID. Proposed AGET FT-64-D1 FN 232RFW8 M51 72RJ96 M41 72RJ60 FN15 232RFT8 Air Flow Discharge Rate

Hours of PM

PM Rate, acfm gr/dscf

Operation

(Ibs/hr)

(tpy) 4,900 0.02

8,760

0.84

3.7 25,000 0.02

8,760

4.3

18.8 15,000 0.06

8,760

7.7

33.8 15,560 0.02

8,760

2.7

11.7 26,000 0.02

8,760

4.5

19.5 Total PM from Fabdc Filter Collectors: 87.4 tpy Laminating Line/NOMEX boards/Gluing

Operations: Allowable emissions to be limited based on facility-wide restrictions of <50 tpy VOCs and <50 tpy acetone. For comparison purposes, actual emissions of VOCs and acetone were 6.9 tpy and 18 tpy in 1998 IData used in last inspection report).TOTAL

FACILITY ALLOWABLE

EMISSIONS, tons/year PM/PM10 SO2

Nox Fuel 43.0

410.4 Fabric Filters

87.4

0 Process 0

0 100.1 00 CO

VOCs14.700 7.50+/- 42.5 Acetone

Total HAPs 0 0.19 0 0 49 24
TOTAL 130.4

410.4

100.1

14.7

<50

<50

<25Table

2 New Allowable Emissions Facility: EHV Weidmann Industries, Inc., St. Johnsbury Date: 10/20/2000 Author:

JLP

FUEL COMBUSTION

EMISSIONS
Location: Main Bldg. ID. #:

Boiler #2 Fuel No. 6 Oil Unit Type:

Fire tube boiler Manuf.: Johnston Model: PFTA500-4 Rated Output (HP):

500 Rated HI (MMBTU/hr): 19.4 Fuel Sulfur (% by wt.):

0.5 Fuel BTU (MMBTU/gal): 0.15 Max. Firing Rate (gph):

130 Potential Hrs. of Operation:

8,760 Load (%): 100 Potential Fuel Combustion:

1,138,600 Proposed Fuel Use Limit:

558,500 (replacement for existing Boiler #2)

Emissions of all combustion contaminants based on emission factors Emissions from Cleaver Brooks and Peerless equipment based upon manufacturers

emission factors, while the heaters and boilers < 25 hp based upon U.S. EPA emission factors published in AP-42 Section 1.3. (Exception: Duct heater PM emission rate based upon PM limit specified in Section 5-231 of the Regulations and continuous operation)

PM/PM10SO2NoxCONMHCs Johnston

Emission Rates Emission Rates

No. 6 Oil Ibs/hr Ibs/MMBTU

tpy 2.35 0.121

5.1 10.1 0.521

21.8 10.2 0.526

22.0 0.78 0.040

1.7 0.2 0.010

0.4Table

3: Aggreagted Emissions Increase Step a) Calculate allowable emissions for new •quipment.

Step b)

Step c)

Step d)

5.1

21.8

22

1.7

0.4
Calculate allowable emissions for all existing processes that are affected by the modification.

Calculate actual emissions for existing equipment that are affected by the modification but which were installed prior to 7/1/79 or have been previously reviewed under § 5-502.

Calculate allowable emissions from all other equipment at the site added to the site since 7/1/79 or have not been reviewed under § 5-502. (2) Peerless Boilers; 25 HP Boiler; Recycling Center Heater; Training Center Heater; Nomex Board Manufacturing Line approved 8/21/1996. See Agency's Technical Analysis dated July 17, 1996.

NOTE: PM/PM10 emissions are not counted, since were included in determine previous modification as major. Recycle Bldg. Fabric Filter and Duct Heater approved 12/30/1998. See Agency's Technical Analysis dated same date.

Total Emissions Increase From Prior Modifications

Step e) Calculate size of modification-

Step a) + Step b) Step c) + Step d) Aggregated PM/PM10 Emissions Increase Aggregated SO2 Emission Increase Aggregated NOx Emission Increase Aggregated CO Emission Increase Aggregated VOCs Emission Increase 5.1 + 0 + 0 + 4.9 10 tons/year 21.8 + 0 + 0 + 13.4 35.2 tons/year 22 + 0 + 0 + 5.89 27.9 tons/year 1.7 + 0 0 + 0.3 2 tons/year 0.4 + 0 + 0 + 6.5 6.9 tons/yearTable

4 Future Allowable Emissions Facility: EHV Weidmann Industries, Inc., St. Johnsbu•y Date: 10/20/2000 Aulhor:

JLP

FUEL COMBUSTION

EMISSIONS
Location: Main Bldg. Main Bldg. D. #:

Boiler #1 Boiler #2 Fuel No. 6 Oil No. 6 Oil Unit iype:

Boiler

Fire Tube Manuf.:. CIv-Brks

Johnston Rated Output (HP):

700

500 Rated H (MMBTU/hr): 29.3

19.4 Fuel Sulfur (% by wt.):

2

0.5 Fuel BTU (MMBTU/gal): 0.15

0.15 Max. Firing Rate (gph):

195.5

130 Potential Hrs. of Operation:

8,760

8,760 Load (%): 100

100 Potential Fuel Combustion:

1,712,580

1,138,800 Allowable Fuel Combustion: 558,500 Fab NorthEioiler #1No. 2 OilBoilerPeerless

2.670.50.14198,760100165,440 Fab Nortl•Boiler #2No. 2 OilBoilerPeerless
2.670.50.14198,760100166,440 Fab NorthBoiler #3No. 2 OilBoiler

251.050.50.147.588,76O10066,401 RecycleHeater #1No. 2 OilHeater TrainingBoiler #1No. 2 OilBoiler

0.10.50.140.858,76O1007,446 0.130.50.141.158,76O10010,074 RecycleDuct HeaterNo. 2 OilHeaterCox Manuf.

0.5250.50.144.58,76010039,420 Facility Total Fuel Consumption: No. 6 Oil

2,271,080 No. 2 Oil

456,221
Emissions of all combustion contaminants based on emission factors Emissions from Cleaver Brooks, Johnston and Peerless equipment based upon manufacture[s emission factors, while the heaters and boilers 25 hp based upon U.S. EPA emission factors published in AP-42 Section 1.3. (Exception: Duct heater PM emission rate based upon PM limit specified in Section 5-231 of the Regulations and continuous operation)

CIv-Brks Johnston

Peerless

AP-42 Factors

CB + Jhnston Peerless

Other No. 6 Factors No. 6 Factors No. 2 Factors No. 2 Commercial

No. 6 Oil No. 2 Oil No. 2 Oil Total Ibs/1000 gals Ibs/hr

Ibs/1000 gals Ibs/1000 gals

tpy

tpy

tpy

tpy PM/PM10 31.8

2.35

4.2

2

32.3

0.7

1.5

34.4 SO2 307.2

10.1

71

71

284.7

11.8

4.4

300.9 Nox 73.4.

10.2

28

20

84.8

4.7

1.2

90.7 CO 11.2

0.78

neg.

5

11.3

neg.

0.3

11.6 NMHCs 5.3

02

4.1

0.34 5.0

0.7

0.0

5.7EPA

HAP Emissions from Residual Oil-Fired Boilers. Quantified in order to determine whether or not EHV Weidmann is a potential "najor HAP source and applicability to future MACT standard for industrial fossil fuel-fired boilers. Emissions from distillate oil-fired equipment were not considered, since these units would not likely be considered within the MACT standard (i.e., too small). Emissions derived from AP-42 emission factors published in Table 1.3-8. Emissions based upon unlimited operation at full load for Boiler #1 and proposed fuel use limit for Boiler #3.

POLLUTANT AP-42 EMISSION

BOILER #1

BOILER #2

TOTAL FACTOR EMISSION RATE

EMISSION RATE

EMISSION RATE (Ibs/1000 gals)

(Ibs/hr)

(Ibs/hr)

(tpy)

POM 0.0013 0.00

0.00

0.00 Formaldehyde 0.033 0.01

0.00

0.04 Benzene 0.000214 0.00

0.00

0.00 Ethylbenzene 0.0000636 0.00

0.00

0.00 Naphthalene 0.00113 0.00

0.00

0.00 1,1,1-Trichloroethane 0.000236 0.00

0.00

0.00 Toluene 0.0062 0.00

0.00

0.01 o-Xylene 0.000109 0.00

0.00

0.00 Antimony 0.00525 0.00

0.00

0.01 Arsenic 0.00132 0.00

0.00

0.00 Beryllium 0.0000278 0.00

0.00

0.00 Cadmium 0.000398 0.00

0.00

0.00 Chromium 0.000845 0.00

0.00

0.00 Cobalt 0.00602 0.00

0.00

0.01 Lead 0.00151 0.00

0.00

0.00 Manganese 0.003 0.00

0.00

0.00 Mercury 0.000113 0.00

0.00

0.00 Nickel 0.0845 0.02

0.01

0.10 Selenium 0.000683 0.00

0.00

0.00

TOTAL HAPs 0.15 0.17

PROCESS EMISSIONS Fabric Filter Collectors: Emissions have been estimated based on a maximum permitted PM discharge concentration

for each fabric filter collector.

D# Collector ID. Proposed AGET FT-64-D1 FN 232RFW8 M51 72RJ96 M41 72RJ60 FN15 232RFT8

Air Flow Discharge Rate

Hours of PM

PM Rate, acfm gr/dscf

Operation

(Ibs/hr)

(tpy) 4,900 0.02

8,760

0.84

3.7 25,000 0.02

8,760

4.3

18.8 15,000 0.06

8,760

7.7

33.8 15,560 0.02

8,760

2.7

11.7 26,000 0.02

8,760

4.5

19.5 Total PM from Fabric Filter Collectors: 87.4 tpy Laminating Line/NOMEX boards/Gluing

Operations: Allowable emissions to be limited based on facility-wide restrictions of <50 tpy VOCs and <50 tpy acetone.TOTAL

FACILITY ALLOWABLE

EMISSIONS, tons/year PM/PM10 SO2

Nox

CO

VOCs

Acetone

Total HAPs Fuel 34.4

300.9

90.7

11.6

5.7

0 0.17 Fabric Filters

87.4

0

0

0

0

0

0 Process 0

0

0

0 +1- 42.5

49

24
TOTAL 121.9

300.9

90.7

11.6

<50

<50

<25VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division

TECHNICAL ANALYSIS

OF AN AIR CONTAMINANT

SOURCE FOR A PERMIT

TO OPERATE #OP-95-066 DEC# NS94-0008 April 19, 2006

OWNER/OPERATOR: Putney Paper Company,

Inc. P.O. Box 226 Putney, VT 05346

SOURCE:

RESPONSIBLE OFFICIAL: CONTACTS:

COUNTY:AREA DESIGNATION: Putney Paper Company,

Inc. U.S. Route 5 and Mill Street Putney, VT 05346 Mr. Paul Mallet, Vice President

Operations Mr. Bruce Raymond,

Environmental

Manager Putney Paper Company,

Inc. Tel: (802) 387-5571 Fax: (802) 387-5297 WindhamAttainment for PM10, SO2, NOx, CO, & Pb Unclassified for O3 UTM COORDINATES: 7021°° m E, 47609°° m N, Zone 18 Boiler Room StackPutney Paper Company,

Inc. 1.0 INTRODUCTION 1.1 Administrative

MilestonesTable

1-1: Administrative

Summary #0P-95-066

Date Application

Received: Date Administratively

Complete: Date & Location Receipt of Application

Noticed: Date Technically

Complete: 01/30/1996 02/14/1996 02/15/1996 The Brattleboro Reformer 05/23/2001 Date Draft Decision: 06/21/2001 Approved Date & Location Draft Decision/Comment

Period Noticed:

06/21/2001

The Brattleboro Reformer Date U.S. EPA and Affected States Notified of Draft Decision: 06/21/2001 Date & Location Public Meeting Noticed: 7/16/2001, The Brattleboro Reformer Date & Location of Public Meeting: Deadline for Public Comments: Written Response to Public Comments Classification of Source Under §5-401: Operating Permit Classification: New Source Review Designation

of Facility: Facility SIC Code(s) and Description(s): 8/6/2001, Putney, VT 10/15/2001 1/23/2006 §5-401 (6)(a)(ii) Fossil fuel burning installation with aggregated

heat input of 10 MMBTU/hr or greater. Title V Subject Source Major Stationary Source 2621 (Paper Mills) 2676 (Sanitary Paper products)

55 361

84

6

26

<1

1.2 PM/PM10 particulate matter, SO2 sulfur dioxide NOx oxides of nitrogen, CO carbon monoxide, VOCs volatile organic compounds, HAPs hazardous air pollutants as listed in §112 of the C/ean AirAct. Basis of Review Putney Paper Company,

Inc. (hereinafter

"Putney Paper" and also referred to herein as "Owner/Operator") owns and operates

a tissue paper manufacturing

facility located off U:S. Route 5 and Mill Street in the town of Putney, Vermont

(referred

to herein as "Facility").

The operations performed

by Putney Paper at the Facility are classified

as a stationary

source of

2Putney Paper Company,

Inc. #0P-95-066 air contaminants

under {}5-401 (6)(a)(ii) of the Vermont

Air Pollution

Control Regulations ("Regulations"). Additionally,

pursuant

to {}5-101 of the Regulations,

"stationary

source" is defined as any structures,

equipment,

installations,

or operations,

or combination

thereof, which emit or may emit any air contaminant,

which is located on one or more contiguous

or adjacent properties

and which is owned or operated

under.common

control.

Based upon this definition,

all of the equipment,

operations,

and structures

at Facility are grouped together as one stationary

air contaminant

source. This Facility was constructed

prior to July 1,1979, and has not undergone

any modifications that required Agency of Natural Resources,

De partment

of Environmenta

Conservation,

Air Pollution Control Division

(hereinafter

"Agency")

review and approval

pursuant

to Title 10 Vermont Statutes Annotated

("10 V.S.A.") {}556 and {}5-501 of the Regulations.

Based upon information provided

by Putney Paper, allowable

emissions

of all air contaminants

from the Facility are estimated

to be greater than ten (10) tons per year ("tpy").

Furthermore, allowable emissions

of sulfur dioxide ("SO2") exceed 100 tpy. Therefore,

pursuant

to {}{}5- 1002, 5-1003, and 5-1005 of the Regulations,

the Facility is classified

as a "Title V Subject Source" and Putney Paper must obtain an Air Pollution

Control Permit to Operate

("Permit to Operate")

consistent

with the requirements

of Subchapter

X of the Regulations

and Title 40 Code of Federal Regulations

("40 CFR') Part 70. 2.0 FACILITY

DESCRIPTION

AND LOCATION 2.1 Description

of Plant Layout and Surrounding

Area The Facility is located in the town of Putney, Vermont.

The area surrounding

the Facility is primarily

mixed commercial

and residential.

The Facility is located within a mile of the Putney Central School. The Facility is located within 100 kilometers

of the Lye Brook Wilderness area in Manchester,

Vermont

and greater than 100 kilometers

from the Great Gulf and Dry River Wilderness

areas in New Hampshire. 2.2 Explanation

of Process The operations

performed

at the Facility are described

using the Standard

Industrial Classification Codes

2621 (Paper Mills) and 2627 (Sanitary

Paper Products). Putney Paper's

Facility is a 100% recycled

deink facility with a primary

function

of manufacturing tissue and other various grades of disposable

papers.

Within this primary function there exist five (5) individual

processes:

repulping,

deinking

and cleaning, formation, drying and wastewater

treatment.

The manufacturing

facility operates

twentyfour (24) hours per day, seven (7) days per week and produces

approximately

110 tons per day of finished paper products. The repu!ping

process

is located in the Mill #2 area. This process

employs

pulpers to physically change various grades of wastepaper,

using water and horsepower,

to a pulp like material. The repulping

process

varies from ten (10) to fifty (50) minutes

in duration. Historically the Facility has also added to the repulping

process a 50% solution of sodium hydroxide ("NaOH"),

a12.5%

solution

of sodium hypochlorite

("NaOCI")

and a non-ionic surfactant to the slurry. More recently the facility has been assessing

their operation

without the use of the sodium hypochlorite

solution.

The chemicals

are added to aid in fiberPutney Paper Company,

Inc. #0P-95-066 separation and preparing

the fiber for the next phase. Steam heat is also employed

in this step in the production,

and is supplied

by two (2) No. 6 oil-fired boilers located on-site. The deinking

and cleaning

process

is also located in the Mill #2 work space. Within this process the repulped

fiber is highly diluted with water (1% fiber consistency).

This process uses physical

means such as screening,

velocity,

centrifugal

forces, air injection

and fine mesh fabrics to separate

.and remove any impurities

and/or contaminants

from the fiber. No process aids are introduced

in this stage of the process.

Occasionally,

the equipment

must be cleaned using a 30% solution of hydrogen

chloride ("HCI") and/or sulfuric acid ("H2SO4"). Inhibitor chemicals

are also used to eliminate

the deposition

of calcium,

barium, and other crystal scale growth on the equipment. The formation

process

consists

of dispersing

the pulp slurry at a 1% consistency

onto a fabric, forming the pulp fibers through velocity and force and removing

the water quickly to retain the physical-form

achieved.

During this stage several process

aids may be introduced depending

upon the grade of product being manufactured.

Materials

used include: dyes for shade enhancement,

polyglycols

for foam control, wet strength

resins to enhance the strength

of the final product.

Wet strength

resins consist of hydrochloric

acid ("HCI") and 1,3-dichloropro

pane. Low molecular

weight polymers

are applied to the forming fabrics to repel built up of sticky substances

and thereby reduce the need for equipment cleanup. The formation

process equipment

is also periodically

cleaned using refined pine terpene hydrocarbons

and/or potassium

hydroxide. The final stage in the manufacturing

process

involves

drying of the formed sheet. The formed sheet is passed through a dryer section which is enclosed

by a hood. The drying stage is also served by steam produced

by the two (2) oil-fired boilers. The temperature

of the steam varies from 220 °F to 280 °F. Hot air and water vapors captured

by the hood are released to the ambient

air. Steam is produced

on-site by thetwo

(2) No. 6 oil-fired boilers both manufactured

by Cleaver Brooks.

The boilers are identical

and are served by a common

breaching

entering into a single stack. The final stage of the process

is the treatment

of the water that has been used throughout the various manufacturing

stages. This is accomplished

through the use of both physical and biological

waste water treatment

systems. 2.3 Process

Equipment

and Stack Information 2.3.1 Description

of Equipment See Table 2-1: Equipment

Information,

in Appendix

A of this Technical

Analysis

for a list of the more important

emission

points at the Facility.

See Table 2-2 in Appendix

A of this Technical Analysis

for a listing of stack and vent parameters

at the Facility. 2.3.2. Description

of Compliance

Monitoring

Devices No devices have been proposed

to continuously

monitor emissions

produced

at this Facility.Putney3.0 Paper Company,

Inc. #0P-95-066 QUANTIFICATION OF EMISSIONS Emissions must be calculated

for the Facility in order to establish

the regulatory

review process for the operating

permit portions

and to determine

applicability

with various air pollution control requirements.

These determinations

are normally

based upon allowable emissions. Allowable

emission

is defined as the emission

rate calculated

using the maximum rated ca pacity of the source and, if applicable,

either: (a) the applicable

emission standard contained

in the Regulations,

if any, or (b) the emission

rate or design, operational
or equipment

standard

specified

in any order or agreement

issued under the Regulations that is state and federally

enforceable.

In addition,

§5-101 of the Regulations

defines a "stationary source" as any structures,

equipment,

installations,

or operations,

or combination thereof, which emit or may emit any air contaminant,

which is located on one or more contiguous or adjacent

properties

and which is owned or operated

under common

control. Based upon this definition,

all of the equipment,

operations,

and structures

at Facility are grouped together

as one stationary

air contaminant

source. Under the Agency's

operating

permit program,

a source is classified

as a "Title V Subject Source" and subject to federal review of the Permit to Operate

if the Facility satisfies

any one of the following

criteria: The source has allowable

emissions

of oxides of nitrogen

("NOx"), sulfur dioxide ("SO2"), carbon monoxide

("CO"), particulate

matter ("PM/PM10")or

any other air contaminant, except volatile organic com pounds ("VOCs"),

of 100 tpy or greater; 2. The source has allowable

emissions

of VOCs of fifty (50) tpy or greater; The source is subject to a federal emission

standard

pursuant

to §111 of the Clean Air Act ("CAA'• and promulgated

in Title 40 Code of Federal Regulations

("40 CFR') Part 60 (Standards

of Performance

for New Stationary

Sources); The source is subject to a federal emission

standard

pursuant

to §112 of the CAA and promulgated

in 40 CFR Part 61 or 63 (National

Emission

Standards

for Hazardous Air Pollutants);

or The source has allowable

emissions

of any. one hazardous

air pollutant

("HAP") regulated by the United States Environmental

Protection

Agency ("U.S. EPA") often (10) tpy or greater, or allowable

emissions

of a combination

of HAPs regulated

by the U.S. EPA of twenty-five

(25) tpy or greater.

The HAPs regulated

by the U.S. EPA are identified

in §112 of the CAA. Note: Non-major

stationary

sources subject to a requirement

in § 111 or § 112 of the CAA are currently not subject to the Title V operating

permff program,

since the U.S. EPA has deferred the requirement

for a Title V operating

permit for non-major

sources pursuant

to 40 CFR Part 70 §70.3(b)(1)

and the fact that the U.S. EPA has not completed

rulemaking establishing how the program

should be structured

for.non-major

sources.

5Putney Paper Company,

Inc. #0P-95-066 3.1 Emission

Related

Information Based upon its allowable

emissions

(see Table 3-1 below), the Facility is currently

classified as a "Title V subject source" under the operating

permit program

requirements. Since there is no existing permit for this Facility, allowable

emissions

have been estimated from all fuel burning equipment

on-site and the paper machines.

Allowable

emissions

have been estimated

based upon continuous

operation

and maximum

rated capacity

for the equipment on-site. The facility has a maximum

production

capability

of 110 tons per day. Emissions produced

from the combustion

of fuels in the fuel burning equipment

include: particulate matter ("PM/PM10"),

sulfur dioxide ("SO2"), oxides of nitrogen

("NOx"), carbon monoxide ("CO"), and volatile organic compounds

("VOCs").

VOCs from fuel burning equipment are also commonly

referred

to as non-methane

total organic

compounds ("NMTOCs"). The operation

of the paper lines results in the discharge

of VOCs resulting from the volatilization

of materials

added during the production

of the paper products. Individual constituents

which makeup

the categoriesof

PM/PM10

and VOCs may also be regulated by state and federal regulations,

and must therefore

be quantified.

These individual constituents

are referred

to as hazardous

air contaminants

("HACs")

and/or hazardous air pollutants

("HAPs").

HAPs are defined as those chemicals

isted in the §112(b) of the federal Clean AirAct, of which there are 188 chemicals.

HACs are defined as those chemicals

which are listed in Appendix

B of the Regulations.

All of the 188 HAPs are included

as HACs. 3.2 Enforceable

Operating

Restrictions The Facility does not presently

operate under any enforceable

limitations

imposed

by an Air Pollution Control

Permit.

However,

emissions

have been estimated

based upon a production rate of 110 tons per day. Based upon 1994 usage rates (56 gallons per ton of product) in the application,

fuel use in the boilers was projected

to be less than 2,300,000 gallons per year at this maximum

production

rate. This value was utilized to estimate emissions from the boilers, rather than the potential

usage rate derived by assuming

full load operation

for the entire year. This fuel use will be placed as a restriction

within any Permit to Operate

issued to Putney Paper. 3.3 Identification

of Insignificant

and Exempt Activities Activities which qualify as'an "insignificant

activity"

pursuant

to §5-1002(h)

of the Regulations need not be considered

when determining

the applicability

of Subchapter

X of the Regulations

and must only be listed as such within the operating

permit application. Additionally, guidance

provided

by the U.S. EPA (entitled

"White Paper for Streamlined Development of Part 70 Permit Applications")

lists activities

which are considered

as "trivial" sources of air contaminants,

and may be presumptively

omitted from operating

permit applications.Although not required for determining

applicability

with Subchapter

X, quantifiable

emissions from "insignificant

activities"

must be included

for the purposes

of establishing

whether

or not a source is subject to other air pollution

control requirements,

including,

but not limited 6Putney

3.4 Paper Company,

Inc. #0P-95-066 to: reasonably

available

control technology,

major source status, and Title V operating permit applicability. In its application,

Putney Paper has not identified

any equipment

or activities

as insignificant
or trivial. However,

the Agency is aware of the following

insignificant

or trivial activities

at the site:

2.3.4.5.6.7.8.9. Propane

fueled forklifts; Repair and maintenance

shop activities; Soldering and welding equipment; Ventilating units used for human comfort; Fuel oil storage tanks Paper testing laboratory; Diesel fire pump; Propane electrical

generator

set (65 kW) manufactured

by Onan;and Intermittent building maintenance

activities. Emissions were not quantified

from the above insignificant

activities

because

they are considered negligible

or not quantifiable.

The exclusion

of emissions

produced

by the insignificant and trivial activities

does not alter the applicability

status of the Facility under Subcha pter X of the Regulations. Allowable Emissions

from Each Emission

Point, Including

Quantifiable

Fugitive Emissions, As Necessary

to Determine

Applicable

Requirements Summarized in Table 3-1 below are the allowable

emissions

for Putney Paper. Table 1 in Appendix A of this Technical

Analysis

summarizes

the derivation

of the allowable emissions. Table 3-1: Allowable

Emissions

for Putney Paper

BoilersPaper Production TOTAL

55.2

55.2

361.1

361.1

83.7

83.7

5.8

5.8

0.325.7

0.18<0.01 26.0 <0.2 APPLICABLE REQUIREMENTS Citation and Description

of all Applicable

Requirements §5-1006(e)(4) of the Regulations

requires the owner/o perator of a stationary

air contaminant source to submit a complete

application

including,

but not limited to a demonstration

of compliance with all applicable

air pollution

control requirements.

These requirements include state and federal regulations,

and the requirements

of any construction

permit issued under 10 V.S.A. §556. Note that compliance

relative to §5-261 and §5-1010

of the

7Putney Paper Company,

Inc. #0P-95-066 Regulations will be discussed

separately

under paragraphs

5.0 and 6.0 below. The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions regarding the compliance

status contained

herein are not binding against the state of Vermont in any future legal or administrative

proceedings. Vermont Air Pollution

Control

Regulations §5-201 and §5-202

Open Burning

Prohibited

and Permissible

Opening

Burning. Open burning of materials

is regulated

within these requirements. Putney Paper has stated that it complies

with these requirements. The Agency will verify compliance

with this standard

in the future during .any inspections

of the Facility.§5-211(1) Prohibition

of Visible Air Contaminants

Installations

Constructed

Prior to April 30, 1970. This standard

applies one of the boilers manufactured

by Cleaver Brooks (Boiler #1 which was installed

in 1967, and specifies

that visible air contaminant emissions may not exceed forty (40) % opacity for a period of six (6) minutes or more in any hour, and at no time may they exceed sixty (60) % opacity.

Compliance

with this standard is generally

based upon the procedures

contained

in proposed

Reference

Method F-1 (51 Federal Register,

page 31076, August 29, 1986). Putney Paper has stated that it complies

with the standard

based on their equipment maintenance. The Agency will verify compliance

with this standard

in the future during any inspections

of the Facility.§5-211(2)

Prohibition

of Visible

Air Contaminants

Installations

Constructed Subsequent to April 30, 1970. This standard

applies to the second boiler manufactured

by Cleaver Brooks, the emergency

generator

set, and diesel fire pump. The limitations

of this section specify that visible air contaminant

emissions

may not exceed twenty (20) % opacity for a period of six (6) minutes

or more in any hour, and at no time may they exceed sixty (60) % opacity.

Compliance

with this standard

is generally

based upon the procedures contained in proposed

Reference

Method F-1 (51 Federal Register,

page 31076, August 29, 1986).Putney Paper has stated that it complies

with the standard

based on their equipment maintenance. The Agency will verify compliance

with this standard

in the future during any inspections

of the Facility.§5-221(1)(a)

-Prohibition

of Potentially

Polluting

Materials

in Fuel Sulfur Limitation in Fuel. This subsection

prohibits

the use of any fuel, in stationary

fuel burning equipment, with a sulfur content more than 2.0% by weight. This prohibition

applies to all stationary

fuel
8Putney Paper Company,

Inc. #0P-95-066 burning equipment

used on-site.

Compliance

with this standard

is based on fuel analyses following the procedures

prescribed

by the American

Society for Testing and Materials ("ASTM").Putney Paper has stated that it complies

with this standard

based on their contract with fuel sup pliers.The continued

use of these methods

is sufficient

to ensure compliance

with this limitation

in the future. As part of a compliance

inspection,,

the Agency may require Putney Paper to perform oil sampling

and analyses

to confirm compliance

with the 2.0% imit. §5-231(1)(a) Prohibition

of Particulate

Matter; Industrial

Process

Emissions.

"No person shall discharge,

cause, suffer, allow, or permit in any one hour from any stack whatsoever particulate

matter in excess of the amount

shown in Table 1 (of the Regulations). For purposes

of this regulation

the total process weight entering

a process unit shal be used to determine

the maximum

allowable

emissions

of particulate

matter which may pass through the stack associated

with the process

unit. When two or more process units exhaust through a common

stack, the combined

process weight of all of the process units, served by the common

stack, shall be used to determine

the allowable particulate matter emission

rate." Compliance

with this emission

standard

shal be determined in accordance

with 40 CFR Part 60, Appendix

A, Reference

Method 5 or an alternative method approved

in writing by the Agency. Based on the application

and information

available

to the Agency,

the paper making operations are potentially

subject to this regulation.

However,

given the nature of the paper making operations,

it unlikely

that significant

quantities

of particulate

matter may be generated from these operations

and therefore

it is expected

that Putney Paper is in compliance with the particulate

matter emission

limit of this section. The Agency will assess compliance

with this emission

standard

in the future during any ins pections

of the Facility. The inspections

will include confirmation

of the proper operation and maintenance'

of the required

air pollution

control devices and visual observations

of the stack exhaust. §5-231(3)(a)(i)

Prohibition

of PM; Combustion

Contaminants.

This standard

applies to any fossil fuel burning equipment

with a rated heat input of ten (10) MMBTU/hr

or less. Specifically, this standard

applies to the small stationary

propane-fired

emergency

generator and the diesel fire pump identified

in item 3.3 of this Technical

Analysis.

This standard specifies that PM emissions

may not exceed 0.5 Ibs/hr/MMBTU

of heat input. Compliance with this standard

is generally

based on the use of Reference

Method 5 (40 CFR Part 60, Appendix A). Putney Paper has stated that it complies

with the standard

based on their maintenance-of the fuel burning equipment. The Agency wil assess compliance

with this standard

in the future as follows:

(1) Putney Paper will be required

to properly

operate

and maintain

its fuel burning equipment,

(2) visual observations

of each exhaust will be conducted

during any Agency inspections

of the Facility, and (3) if visible emissions

are observed

to be in excess of the limits specified

inPutney Paper Company,

Inc. #0P-95-066 §5-211 of the Regulations,

the Agency may require the performance

of a stack test to verify compliance with the above referenced

PM standard

or that other corrective

measures

be taken.§5-231(3)(a)(ii) Prohibition

of PM; Com bustion Contaminants.

The PM standard

in this section is applicable

to the two No. 6 oil-fired boilers manufactured

by Cleaver Brooks, since they each have a heat in put rating greater than ten (10) MMBTU/hr

but equal toot less than 250 MMBTU/hr.

The PM standard

is in units of Ibs/hr/MMBTU

and varies based upon the heat in put of the unit. The actual value of the standard

is derived based upon the following formula:EpM 1 0['°47°39(1°g1°

H/)+0.16936]
Where HI is the maximum

rated heat input of the unit in MMBTU/hr;

and EpM iS the emission

rate in Ibs/hr/MMBTU. In accordance

with the above formula,

the following

emission

standards

apply to the boilers operated by Putney Paper: Ep• for Cleaver Brooks 25.1 MMBTU/hr

Boiler #1 0.32 Ibs/MMBTU

and 8.0 Ibs/hr Ep• for Cleaver Brooks 25.1 MMBTU/hr

Boiler #2 0.32 Ibs/MMBTU

and 8.0 Ibs/hr Emissions of PM/PM10

will result from the burning of fuel oil in the boilers at the Facility. The quantity of these emissions

produced

will depend upon the quality of the operation

and maintenance of the fuel burning equipment,

and the quality of.the fuel being burned.

In an effort to maintain

compliance

with this.req uirement

the Agency will require Putney Paper to maintain and operate its equipment

following

the manufacturer's

recommendations,

and that Putney Paper perform annual maintenance

tune-ups

on its equipment.

The Agency is also requiring the facility to routinely

monitor the combustion

efficiency

of the boilers.

The Agency will also assess visible emissions

from the fuel burning equipment

while on-site performing an inspection

of the Facility, and if visible emissions

are observed

to be in excess of the limits specified

in §5-211 of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standards

or that other corrective

measures

be taken. Putney Paper has stated that it complies

with the standard

based on their emission estimates, emission

performance

data from Cleaver-Brooks,

the boiler manufacturer,

and the scheduled

maintenance

of the boilers. Compliance with the standard

in §5-231(3)(a)(ii)

of the Regulations

is generally

based on the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). Based on available

emission data, emission

performance

data from the boiler manufacturer,

and fuel properties,

the estimated PM emissionsfrom

the boilers at the Facility are anticiPated

to be well below the regulatory limit thereby ensuring

compliance

with the standard.

Therefore

the Agency is not, at this time, requiring

emissions

testing for the boilers.

10Putney Paper Company,

Inc. #0P-95-066 §5-231(4) Prohibition

of PM; Fugitive

PM. This section requires

the use of fugitive PM control equipment

on all process operations

and the a pplication

of reasonable

precautions to prevent PM from becoming

airborne

during the handling,

transportation,

and storage of materials, or use of roads. This requirement

applies to the entire Facility. The Agency will require the use of reasonable

precautions

such as the application

of water or surfactants

to the haul roads and plant yard as necessary.

Additionally,

the Agency will assess compliance

with this requirement

during any inspections

of the Facility, and will require the use of additional

measures

if found necessary

during a compliance

ins pection. §5-241(1) & (2) Prohibition

of Nuisance

and Odor. This requirement

applies to.the entire Facility and prohibits

the discharge

of air contaminants

that would be a nuisance

to the public or be source of objectionable

odors beyond the property-line

of the Facility. Putney Paper has stated that it complies

with this requirement

due to their observation

of dust and odors from the operations. The Agency will verify compliance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all complaints

that it receives

in order to determine

whether

or not there is a violation

of this requirement. §5-253.14 Control

of Volatile

Organic

Compounds

Solvent

Metal Cleaning.

This subsection applies to all cold cleaning

operations,

open-top

vapor degreasing

operations with an open area of 10.8 square feet or greater, and conveyorized

degreasing

operations with an air/solvent

interface

21.5 square feet or greater.

The cold cleaning

standards require the units to be designed

and equipped

with a cover easily operated

with one hand if the vapor pressure

of the solvent exceeds

0.3 psi and an internal drainage

area and additional control measures

if the vapor pressure

of the solvent exceeds

0.6 psi. All cold cleaning operations

regardless

of solvent vapor pressure

must... "...(iv)(v)(vi)(vii](viii)(ix)(x) Provide

a permanent,

legible, conspicuous

label, summarizing

the operating req uirements; Store waste solvent in covered

containers; Close the cover whenever

parts are not being handled

in the cleaner; Drain the cleaned

parts until dripping

ceases; Supply a solvent spray, if used, that ensures

a solid fluid stream at a pressure

that does not exceed 10 pounds per square inch gauge; Degrease only materials

that are neither porous nor absorbent;

and Cease operation

of the unit upon the detection

of any visible solvent leak until such solvent leak is repaired." That applicant

has stated that the cold cleaning

unit and solvent used at the Facility has a vapor pressure

less than the applicable

levels requiring

controls other than the requirements of parts (iv) through (x) above and that the u nit is designed

and operated

in accordance

with those provis ions. The Agency will assess compliance

with this regulation

in the future during any inspections of the Facility. The inspections

will include confirmation

of the solvent used and the proper design and operation

of the unit.

11Putney Paper Company,

Inc. #0P-95-066 §5-403 Circumvention.

"No Person shall build, erect, install or use any article, machine, equipment or other contrivances,

the use of which, without resulting

in a reduction

in the total release of air contaminants

to the atmosphere,

reduces or conceals

an emission

which otherwise would constitute

a violation

of these regulations." Based on the application

submittal

and information

available

to the Agency,

the Facility is currently in compliance

with this regulation. Subchapter VIII Registration

of Air Contaminant

Source.

This Subchapter

requires the owner or operator

of a stationary

source register with the Agency if the sou rce produces

five (5) tons per year or greater of actual emissions

during the preceding

calendar

year. The owner or operator

of a source is required

to submit information

regarding

their operations and pay a fee based upon the quantity

of emissions

they produce

and the fuels that they use at the source. Putney Paper has stated that it complies

with this requirement

based on the information they have submitted

and the fees they have paid in preceding

years. The Agency

will ensure compliance

with this requirement

in the future during any inspections of the Facility. Federal Air Pollution

Control

Regulations Section 111 of the Clean Air Act New Source Performance

Standards

(NSPS) No promulgated

NSPS in 40 CFR Part 60 currently

apply to Putney Paper. Section 112 of the Clean Air Act National

Emiss,on

Standards

for Hazardous

Air Pollutants (NESHAPs) No promulgated

NESHAPs

in 40 CFR Part 61 currently

apply to Putney Paper. The Pulp and Paper Production

MACT in 40 CFR Part 63 Subpart

S applies to pulp and paper facilities

that are major HAP sources.

Based upon its estimated

emissions

of HAPs regulated by the U.S. EPA, Putney Paper does not generate

HAP emissions

in excess of the federal thresholds

for a major source. Consequently,

the pulp and paperboard

industry NESHAP does not apply to Putney Paper. Furthermore, although

exempt from §5-261 of the Regulations,

the U.S. EPA has identified industrial-institutional-commercial boilers as a potential

source that will be regulated

by a "maximum achievable

control technology"

("MACT")

standard

in the future. Emissions

of federally regulated

HAPs have been estimated

for the boilers. Total HAP emissions

from the Facility are estimated

to be less than 0.2 tl•y, and no individual

HAP is emitted at a rate of 0.2 tpy or greater.

Based upon maximum

potential

emissions

of HAPs from the boilers, it does not appear that Putney Paper will be a major source of HAPs due to fuel combustion. The federal definition

of major source of HAPs is any facility which generates

25 tpy or more of total HAPs or 10 tpy or more of any individual

HAP. The federally

regulated

HAPs are
12Putney Paper Company,

Inc. #0P-95-066 isted in §112(b) of the Clean AirAct. 40 CFR Part 64 Compliance

Assurance

Monitoring.

Pursuant

to requirements concerning enhanced

monitoring

and compliance

certification

under the Clean Air Act ("CAA"), EPA promulgated

new regulations

and revised regulations

on October

22, 1997. These new requirements

implemented

compliance

assurance

monitoring

("CAM") for major stationary sources of air pollution

that are required

t o obtain operating

permits under Title V of the CAA. Subject to certain exemptions,

the new regulations

require owners or operators of such sources to conduct monitoring

that satisfies

particular

criteria established

in the rule as a means of providing

a reasonable

assurance

of compliance

with applicable requirements. Compliance

assurance

monitoring

is proposed

to focus on emissions

units that rely on pollution

control equipment

to achieve

compliance

with applicable

standards. The regulations

also provide procedures

for coordinating

these new requirements

with the operating permit program

regulations.

As a result of comments

received

during the rule making process and the lengthy delay in the adoption

.of the CAM rule, U.S. EPA provided
an extended

implementation

schedule

for this rule. Facilities

which had submitted

a complete operating

permit application

prior to April 20, 1998, were not required

to address CAM as part of their initial operating

permit application,

unless they proposed

to make significant changes

to the facility subsequent

to this date and the facility operated

"large" pollutant specific emission

units ("PSEU").

A "large PSEU" is defined as a unit with post control emissions

greater than or equal to the major source threshold. §64.2 in 40 CFR Part 64 specifies

that each PSEU at a facility that meets a three-part

test is subject to the requirements

for CAM. An emission

unit must: (A)(B)(C) Be subject to an emission

limitation

or standard, Use a control device to achieve compliance,

and Have pre-control

emissions

that exceed or are equivalent

to the major source threshold in 40 CFR Part 70 (i.e., 10 tpy individual

HAP, 25 tpy total HAPs, 50 tpy VOCs, or 100 tpy for any other air contaminant). Note that the term "control

device"

means equipment,

other than inherent

process equipment, that is used to destroy or remove air pollutant(s)

prior to discharge

to the atmosphere. The term "control device" does not include passive methods

such as lids or seals, use of low-polluting

fuels or inherent

process

equipment

provided

for safety or material recovery.

Additionally,

.the CAM rule provides

some exemptions,

such as an exemption for any affected

facility subject to an NSPS or NESHAP

promulgated

after November 15, 1990. Since Putney Paper does not meet the above three part test for its boilers and paper manufacturing operations,

it is not subject to the requirements

for CAM. Clean AirAct, Title VI Stratospheric

Ozone Protection.

The requirements

of Title VI of the CAA are implemented

through

regulations

and standards

within 40 CFR Part 82 Subparts A through

F. Of these regulations,

Putney Paper is subject to Subpart

F Recycling and Emissions

Reduction.

This requirement

is applicable

to any facility that owns services, maintains,

repairs,

and disposes

of appliances

containing

ozone depleting substances. Putney Paper utilizes such refrigeration

systems

at the Facility.

The Agency will incorporate

the applicable

requirements

of 40 CFR Part 82 Subpart

F into any permit 13Putney Paper Company,

Inc. issued to Putney Paper. #0P-95-066

4.2

4.3

4.4 Citation

and Identification

of Requirements

For Which a Permit Shield Provision

Has Been Requested Pursuant to {}5-1015(a)(11)

of the Regulations,

an owner/operator

may request to be shielded from specific state or federal requirements

which do not apply to the subject source. If the applicability

of a regulatory

requirement

is unclear to the applicant,

when appropriate, the Agency may grant a permit shield stating that the requirement

does not apply to the source.

Once a permit shield is granted,

the Agency may not initiate any enforcement action against the Facility based upon a regulation

or standard

covered by the permit shield.

The Agency

would be required

to amend the Permit to Operate

and incorporate the applicable

requirement

prior to initiating

any enforcement

action fornoncompliance with the applicable

requirement.

The Agency's

permit shield determinations

are based upon the information

submitted

by the owner/operator

in its operating

permit application. The resulting

permit shield shall be effective

only with •espect to activities disclosed in the application. It is the Agency's

procedure

to grant permit shields only for those requirements

or standards which conceivably

could apply tothe Facility, and the Agency has made a determination that such requirement

does not in fact apply. The Agency does not intend to grant permit shields for those requirements

that clearly do not apply to the Facility.

For example,

an .asphalt plant will not be granted a permit shield from a regulation

applying

to a dry cleaning operation. Additionally,

the Agency and the U.S. EPA do not favor granting

permit shields from broad requirements

such as a section of the C/ean AirAct or an entire Subpart of the federal regulations

in 40 CFR. In the words of the U.S. EPA, "... the intended

purpose

of a negative applicability

determination

is to memorialize

a decision

where applicability

of a certain regulation

is somewhat

unclear without extensive

knowledge

of the regulations

and investigation of the relevant

facts." Putney Paper has not requested

in its application

to be shielded

from any potentially applicable requirements.

Therefore,

the Agency

has not proposed

to grant any permit shields to Putney Paper in its Permit to Operate. Description of Alternative

Operating

Scenarios

and Related Applicable

Requirements Not Previously

Identified Putney Paper has not identified

any alternative

operating

scenarios

as part of its application for a Permit to Operate. Equivalency and Streamlining On February

10, 1982 the Federal EPA approved,

as part of Vermont's

State Implementation Plan, {}5-261 of the Vermont.

Air Pollution

Control Regulations.

As

14Putney Paper Company,

Inc. #0P-95-066 approved, {}5-261 required

a "most stringent

emission

rate" (MSER),

as defined for major stationary

sources for the control of hazardous

air contaminants.

The current State of Vermont

hazardous

air contaminants

regulation,

as amended

on January

20, 1993, employs

both an action level and a "hazardous

most stringent

emission

rate" (HMSER) for the control of hazardous

air contaminants.

Both MSER and HMSER

are established on a case-by-case

basis and are based on the lowest emission

rate achieved in practice

by such category

of source. The Agency has determined

that the use of an action level in conjunction

with a HMSER is at least as stringent

as the MSER as adopted

by the EPA.

5.0 HAZARDOUS

AIR CONTAMINANTS {}5-261 of the Regulations

addresses

the release of hazardous

air contaminants

("HACs") into the ambient

air. Unless specifically

exempted

from {}5-261, the owner or operator

of a source must quantify its emissions

of HACs regulated

by this rule. Any source whose actual emission rate of a HAC exceeds

its respective

Action Level ("AL") is subject to the rule for that HAC, and the owner or operator

of the source must then demonstrate

that emissions

of the HAC are minimized

to the greatest

extent practicable.

This process

is termed the "Hazardous Most Stringent

Emission

Rate" or HMSER.

An air quality impact evaluation may also be required

to further assess the ambient

impacts that may be attributable

to the source. The evaluation

of the air quality impacts is performed

using the HazardousAmbient Air Standards

("HAAS")

or Stationary

Source Hazardous

Air Impact Standard

("SSHAIS") contained in the Regulations. Solid fuel burning equipment

(not including

incinerators)

installed

or constructed

prior to January 1, 1993, and all fuel burning equipment

which combusts

virgin liquid or gaseous fuel is exempted

from review pursuant

to {}5-261 (1)(b)(ii) of the Regulations.

Consequently,

no fuel burning equipment

used at the Facility qualified

for review of HAC emissions

under {}5-261 of the Regulations. The production

of tissue paper does result in the discharge

of some HACs at the Facility. These emissions

have been quantified

as part of the Agency's

registration

program.

This data has been compared

to the Action Levels in order to determine

applicability

to {}5-261 of the Regulations. Summarized

in Table 5-1 are the estimated

actual HAC emissions

resulting

from the paper production process,

as well as a comparison

to the respective

AL. The data for d ipropylene glycol methyl ether and. 1,2-propanediol

was obtained

from the registration

files for year 2004. The emission

estimates

assume

100% discharge

to the ambient air of the ingredients included in the products

used by Putney Paper that contain dipropylene

glycol methyl ether and 1,2-propanediol. Tt•e use of sodium hypochlorite

as a process

chemical

in the papermaking

process will produce chloroform

as a by product.

The emission

rate of chloroform

has been estimated based on a study by the National

Council of the Paper Industry for Air and Stream Improvement,

Inc: (NCASI).

The estimated

emission

rate shown in Table 5-1 is based on an annual usage of 500 gallons of a 12.5% solution of sodium hypochlorite. 15Putney Paper Company,

Inc. #0P-95-066

If the Permittee

proposes

to continue

the use of more than 500 gallons per year of sodium hypochlorite

at the Facility, then the chloroform

Action Level will be exceeded. In this event, within 180 days of the permit issuance,

the Permittee

shall conduct and submit to the Agency a Hazardous

Most Stringent

Emission

Rate evaluation

for the hazardous a•r contaminant

chloroform

resulting

from the use of chlorinated oxidants/bleaching agents in their papermaking

processes. Table 5-1: Comparison

of HAG Emission

Rates to Action Levels

Dipropylene glycol methyl ether 34590-94-8

0.24

252 1,2-Propanediol 57-55-6

0.01

67 Chloroform 66-66-3

0.0033

0.0034 6.0

7.07.1

7.2

8.0 REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the Agency has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility under {}5-1010

of the Regulations. Therefore, the Facility is currently

in compliance

with this requirement.

The Agency will notify Putney Paper if any applicable

RACT requirement

applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensu-e that Putney Paper complies

with such requirement

at that time. COMPLIANCE PLAN Description of the Compliance

Status for Each Applicable

Requirement See paragraph

4.0 above. Compliance Schedule

For Each Applicable

Requirement

for Which the Source is Not in Compliance Not applicable

to this Facility. PUBLIC PARTICIPATION The Facility operated

by Putney Paper is classified

as a "Title V Subject Source,"

and consequently, any application

for a permit modification

is subject to the public participation requirements of {}5-1007

of the Regulations.

As required

by this section,

the Agency published notided on February

15, 1996, in the Brattleboro

Reformerthat

it had received

an administratively complete

application

from Putney Paper. On May 23, 2001, the Agency determined it received

sufficient

information

to declare the application

technically

complete. On June 21,2001,

the Agency published.a

notice in the Brattleboro

Reformerinforming

the public of the Agency's

plans to issue a draft Air Pollution

Control Permit to Operate.

The
16Putney Paper Company,

Inc. #0P-95-066 notice solicited

comments

on the draft decision

and requests

for an informational

meeting
on the matter. The public comment

period was tentatively

set to close on July 20, 2001. Requests for an informational

meeting were received

by the Agency.

On August 6, 2001, a public meeting was held. The public comment

period closed on October

15, 2001. The U.S. EPA and affected

states of New York, Massachusetts,

and New Hampshire

were notified of the draft decision

on June 21, 2001. 9.0 CONCLUSIONS 9.1 Putney Paper has demonstrated

that the Facility is in compliance

with all applicable

air pollution control requirements.

17Putney Paper Company,

Inc. #0P-95-066

APPENDICES
Appendix A Table 2-1" Equipment

Information Table 2-2: Stack Information

18Putney Paper Company,

Inc. #0P-95-066

Table 2-1: Equipment

Information

PARAMETER BOILER #1 Boiler Manufacturer: Model No.: Serial No.:Purpose of boiler: Boiler Type: Boiler Maximum Rated Heat Input (MMBTU/hr): Boiler Maximum Rated Heat Output: (horsepower): Boiler Design Heat Transfer Efficiency: Maximum & Design Operating Pressures (psig): If purpose of the boiler is for steam production,

indicate maximum and design steam production rate (Ibs of steam/hr): Fuel Type: Assumed Fuel Higher Heating Values (MMBTU/gal): Fuel Sulfur Content (% by weight): Fuel Nitrogen Content (% by weight) Number of Burners: Burner Manufacturer: Model No.: Serial No.: Burner Type or Fuel Feeding Mechanism: Maximum Fuel Firing Rate (gals/hr): Forced draft or atmospheric

boiler: Combustion air blower capacity in actual cubic feet per minute: % Excess Air Oxygen Content of Flue Gas (% by volume, wet): Carbon Dioxide (CO2) Content of Flue Gas (% by volume, wet): Moisture Content of the Flue Gas (% by volume): Will flue gas recirculation

(FGR) be employed? Will staged air combustion

or staged fuel combustion

be used? Will the combustion

air be preheated? Will Iow-NOx burners be utilized? Soot blowing frequency and duration: Will the steam be utilized for electrical generation? Cleaver Brooks 655-600L-42356 Steam production Fire tube2560076%150/12020,000/18,400

No. 6 Fuel Oil0.152.00.5

Cleaver Brooks 655-600?L-42356? Air atomizing (tow pressure) nozzle 167.5Forced draft7,09730-50%4.4%13%N/ANoNoNoNo2 times per dayNo

Cleaver Brooks 655-600L-36070 Steam production Fire tube2560076%150/12020,000/18,400

No. 6 Fuel Oil0.152.00.5

Cleaver Brooks 655-6O0L-42356? Air atomizing (low pressure) nozzle 167.5Forced draft7,09730-50%4.4%13%N/ANoNoNoNo2 times per dayNo

19Putney Paper Company,

Inc. #0P-95-066 Table 2-2: Stack Information

PARAMETER

Stack #1 60 Stack height above base, feet: Internal Diameter of Stack, feet: Exit Flow Rate, acfm: Exit Flow Rate, dscfm: Exhaust •emperature,

°F: Exhaust Moisture Content, %.by vol.: Exhaust Velocity, flJsec: Exhaust Static Pressure inches of water: UTM Coordinates,

meters: Lack or presence of rain cap: Orientation of stack: (Stack Base Elev.: 364 ft above MSL) 35,0897,097?394N/A12N/A 702100 m E, 4760900 m N, Zone 18 No rain capVertical

2O#AOP-05-018a DEC#E J96-0028 Operating Permit Expiration

Date: January

11, 2011

State of Vermont Agency of, Natural Resources Department of Environmental

Conservation

Air Pollution

Control

Division Waterbury, Vermont TITLE V AIR POLLUTION CONTROL

PERMIT TO CONSTRUCT AND

OPERATE

Date Permit Issued: January

11, 2006 Owner/Operator: Rock-Tenn

Converting

Company P.O. Box 4098 Norcross, GA 30091

Source: Rock-Tenn

Company

Missisquoi

Mill 369 Mill Street Sheldon Springs,

VT 05485Rock-Tenn Converting

Company #AOP-05-018a FINDINGS OF FACT (A) FACILITY

DESCRIPTION Rock,Tenn Company

(also referred

to herein as "Permittee")

owns and operates

a paperboard manufacturing

facility located off Mill Street in the town of Sheldon,

Vermont (also referred to herein as "Facility").

The facility.currently

operates

under an Air Pollution Control Permit to Construi•t

and Operate

(AOP-95-148a)

issued on March 8, 2001. Concurrent with the renewal of this prior Permit to Construct

and Operate the Agency is also incorporating as a technical

amendment

into the permit herein approval

of the Permittee's request to increase

annual fuel oil usage by 4,800 gallons per year. This increase,

in conjunction with prior increases,

is the maximum

the Facility may increase

fuel oil usage and remain a minor modification. Upon issuance

of this permit the Facility will consist of the following

equipment:

Paperboard Machine #1 Paperboard Machine #1b Paperboard Machine #2 Paperboard Machine #2b

Wickes Boiler #1

Wickes Boiler #2

B&W Boiler #3

B&W Boiler #4

MMBtu/hr Million British Thermal Units

52.98Steam supplied from Boilers 3.264 Natural Gas

Natural Gas 1.6789 Fuel Oil 80 Natural Gas 27
33

31 Fuel OilFuel OilNatural GasFuel OilNatural Gas )er hour maximum rated heat input.

196920011996"19982001

1950

Page 2 of 22Rock-TennConverting Company #AOP-05-018a

(B)

(c) Equipment

Specifications

Diesel Emergency Generator 16

Diesel bhp Brake Horsepower FACILITY CLASSIFICATION •lon1950

The Facility is classified

as a source of air contaminants

pursuant

to Title 10 of the Vermont Statutes Annotated

("10 VSA.") §555 and §5-401 of the Vermont

Air Pollution

Control Regulations (hereinafter

"Regulations").

In addition,

§5-101 of the Regulations

defines a stationary source as any structure(s),

equipment,

installation(s),

or operation(s),

or combination thereof, which emit or may.emit

any air contaminant,

which is located on one or more contiguous

or adjacent

properties

and which is owned or operated

by the same person or persons

under common

control.

Based on this definition,

all of the equipment, operations, and structures

at the Facility are grouped

together

by the Agency of Natural Resources, Department

of Environmental

Conservation,

Air Pollution

Control Division (hereinafter "Agency")

as one stationary

air contaminant

source for purposes

of review under the Regulations. PRIOR AGENCY

ACTIONS/APPROVALS The Facility has been issued the following

"Permit to Construct"

approvals

pursuant

to 10 VSA §556 and §§5-501

and/or 5-502 of the Regulations

and the following

"Permit .to Operate" approvals

pursuant

to 10 VSA §556a and Subchapter

X of the Regulations.

March 8, 2001

AOP-95-148a

Modification

of two paper machines,

including additional coating stage and drying. July 16; 1999

AOP-95-i48

-Initial Operating

Permit. December 30, 1998 AP-96-019b

Application

requesting

approval for a new coating stage w/infrared drying on existing paper machine (Machine #2).
June 13, 1996

AP-96-019a

Administrative

amendment

made. December 2, 1996 AP-96-019

.- Use existing boilers to supply heat to coating oven.

Page 3 of 22Rock-Tenn Converting

Company #AOP-05-018a (D) FACILITY

PERMIT

APPLICABILITY Pursuant to 10 VSA §556a and Subchapter

X of the Regulations

a Permit to Operate

is required for any air contaminant

source with allowable

emissions

of all air contaminants combined often (10) tons per year ("tpy") or more or that is subject to a standard,

limitation or other requirement

under §111 and/or {}112 of the Clean Air Act. The Facility currently

operatesunder

a Permit to Construct

and Operate

issued on March 8, 2001. The allowable

emissions

from the Facility are estimated

to be greater than ten (10) tpy. Pursuant

to §§5-1002,

5-1003, and 5-1005 of the Regulations

the Facility is classified as a "Title V Subject Source".

In accordance

with §5-1009 of the Regulations,

the agency •s •ssuing the Permit to Operate

herein as a renewal of the previous

Permit to Construct

and Operate for the Facility and the Permit herein supercedes.al

prior Permits for theFacility. In accordance

with IOVSA §556(e) the Agency has combined

the Permit to Construct

and the Permit to Operate

for this Facility into one combined

Permit to Construct

and Operate. The allowable

emissions

for the Facility are summarized

below:

(E) < oo 3 .o PM/PM10 particulate matter and particulate matter of 10 micrometers

in size Or smaller; SO2 sulfur dioxide; NO× oxides of nitrogen measured as NO2 equivalent; CO carbon monoxide; VOCs volatile organic compounds;

HAPs hazardous air pollutants as defined in {}112 of the federal Clean Air Act. REVIEW FOR THE PERMIT

TO CONSTRUCT (a) New Source Review Designation The.Permittee has proposed

to increase

the allowed fuel oil usage by 4,800 gallons per year, which combined

with prior minor modifications

will result in an increase

of just less than 40 tons per year of the pollutant

sulfur dioxide.

Thus the modification is considered

minor and is being processed

as a technica

amendment

under the New Source Review requirements

in §5-501 of the Regulations. (b) Most Stringent

Emission

Rate Pursuant to §5-502 of the Regulations,

the owner/operator

of each new major stationary source or major modification

must apply control technology

adequate

to achieve the Most Stringent

Emission

Rate ("MSER")

with respect to those air contaminants for which there would be a major or significant

actual emissions increase, respectively,

but only for those currently

proposed

physical

or operational changes which would contribute

to the increased

emissions.
Page 4 of 22Rock-Tenn Converting

Company #AOP-05-018a

(F) The Permittee

has not proposed

any major modifications

to the Facility in conjunction with the review for this Permit to Operate

and therefore

is-not subject to review under the MSER requirements

in §5-502 of the Regulations

at this time. (c) Ambient

Air Quality Impact Evaluation An ambient

air quality impact evaluation

("AQIE")

is performed

to demonstrate whether or not a proposed

project will cause or contribute

to violations

of the ambient air quality standards

and/or significantly

deteriorate

existing air quality. The Agency's implementation

procedures

concerning

the need for an ambient air quality impact evaluation

under §5-406(1

of the Regulations,

specifies

that such analyses may be required

when a project results in an allowable

emissions

increase

of ten (10) tons per year or more of any air contaminant,

excluding

VOCs. Additionally,

the Agency may require an air quality impact evaluation

where the short-term

allowable emission rates wil significantly

increase

as a result of a project. The Permittee

has not proposed

any significant

modifications

to the Facility in conjunction with the review for this Permit to Operate

and therefore

is not subject.to
an air quality impact analysis

under §5-501 of the Regulations

at this time. The Facility was previously

required

to conduct

an AQIE for modifications

to the Facility on August 2, 1995. An AQIE was conducted

for the pollutants

SO2, NOx, PM10 and CO. The results of the AQIE concluded

that in order for the Facility to meet short term ambient

standards,

the Facility may not run more than two of it's boilers at any given time on 2% sulfur fuel oil. REVIEW FOR THE PERMIT

TO OPERATE (a) Applicable

Requirements The operations

at the Facility are subject to the following

state and federal laws and regulations, the requirements

of which are embodied

in the conditions

of this Permit. (i) Vermont

Air Pollution

Control Regulations:

Section 5-211 (1) Prohibition

of Visible Air Contaminants,

Installations

Constructed

Prior to April 30, 1970. Applicable

units: Coating Dryer#l,

Wickes Boiler#I, #2, B&W Boiler #3, #4, Diesel Emergency

Generator. Section 5-211(2)

Prohibition

of Visible Air Contaminants,

Installations

Constructed Subsequent to April 30, 1970. Applicable

units: Coating Dryer #1B, 2, and 2b. Section 5-221 (1) Prohibition

of Potentially

Polluting Materials in Fuel, Sulfur Limitation in Page 5 of 22Rock-Tenn Converting

Company #AOP-05-018a

Fuel.Section 5-221(2)

Prohibition

of Potentially

Polluting Materialsin

Fuel, Waste Oil. Section 5-231 (3) Prohibition

of Particulate

Matter; Combustion

Contaminants. Section 5-231(41

Prohibition

of Particulate

Matter; Fugitive Particulate

Matter. Section 5-241 Prohibition

of Nuisance and Odor. Section 5-253.10

Control of Volatile Organic Compounds

from Paper Coating. Section 5-402 Written Reports When Requested. Section 5-403 Circumvention. Subchapter Vlll- Registration

of Air Contaminant

Sources. Subchapter X Operating

Permits. (ii) Reasonably

Available

Control Technology

{}5-1010

of the Regulations Pursuant to 10 VSA {}556a(d)and

{}5-1010

of the Regulations

the Agency may establish

and include within any Permit to Operate

emission

control requirements based on Reasonably

Available

Control Technology

("RACT"). The Agency has not imposed

any RACT requirements

on this Facility under this authority

at this time. Existing Air Pollution

Control Permit to Construct

and/or Operate The Facility currently

operates

under the confines

of a Permit to Construct issued on March 8, 2001 (#AOP-95-148a).

The conditions

within that existing permit are considered

applicable

requirements

pursuant

to {}5-1002 of the Regulations..The

requirements

of that permit which are not being modified herein are incorporated

into this new combined

Permit to Construct and Operate

(#AOP-05-018).

Page

6 of 22Rock-Tenn Converting

Company #AOP-05-018a

(b) Non-Applicable

Requirements

Clean Air Act §§114(a)(3),

502(b), and 504(a)-(c);

40 CFR Part 70 §§70.6(a)(3)(i)(B)

and 70.6(c)(1 ); and •,0 CFR Part 64 Compliance

Assurance

Monitoring.

Upon renewal Of a Title V Permit to Operate, a facility must comply with enhanced

monitoring

and compliance assurance

monitoring

requirements

for any emission controlled unit subject to am emission standard with uncontrolled

emissions

from the unit in excess of the Title V major source thresholds. There are no emission control devices used by the Facility, therefore this Federal Regulation is non-applicable.

(c)

(d) Pursuant

to §5-1015(a)(14)

of the Regulations,

an owner/operator

may request to be shielded

from potentially

applicable

state or federal requirements.

The applicant has requested

a permit shield. The Agency

determined

that all regulations from which the applicant

has requested

to be shielded

from arenonapplicable. Therefore,

the Agency

is not granting

a permit shield from any regulations. (Example:

§5-251(3)

Control of Nitrogen

Oxide Emissions

The Facility is capped at 100 tons per year of NOx therefore

this regulation

is not applicable. A permit shield is meant for situations

which a Regulation

could or could not potentially

apply. In this situation,

there are no Regulations

that are in question on whether

or not they could potentially

apply.). Enforceability This section delineates

which permit conditions

are federally

enforceable

and which conditions are state only enforceable.

All federal enforceable

conditions

are subject to federal citizen suit provisions.

All conditions

of this Permit are enforceable

by both state and federal authorities. Compliance Certification The Permittee

is required

by this Permit to certify compliance

as part of its annual registration with the Agency pursuant

to.the requirements

of Subchapter

X of the Regulations.. Additionally,

this Permit requires

the submission

of semi-annual reports of monitoring

records used to demonstrate

compliance

with the limitations contained in this Permit.

Page 7 of 22Rock-Tenn Converting

Company #AOP-05-018a

(G) HAZARDOUS

MOST STRINGENT

EMISSION

RATE Pursuant to §5:261 of the Regulations,

any stationary

source whose current or proposed actual emission

rate of a hazardous

air contaminant

("HAC") is equal to or greater than the respective Action Level (found in Appendix

C of the Regulations)

shall achieve

the Hazardous Most Stringent

Emission

Rate ("HMSER").for

the respective

HAC. Pursuant

to §5-261 (1)(b)(ii) of the Regulations,

all fuel burning equipment

which combusts

virgin liquid or gaseous

fuel is exempt from this section.

The Facility is not expected

to have regulated emissions of any HAC in excess of an Action Level. Therefore,

the Facility is not subject to §5-261 of the Regulations

at this time.

Page 8 of 22Rock-Tenn Converting

Company #AOP-05-018a Based on the Agency's

review of the Facility's

application

and the above Findings

of Fact, the Agency concludes

that the Facility, subject to the following

Permit conditions,

complies

with all applicable state and federal air pollution

control laws and regulations

or is subject to an acceptable schedule of compliance.

Therefore,

pursuant

to 10 VSA §§556 and 556a, as amended,

the Agency hereby issues a Permit approwng

the Facility, as described

in the above Findings

of Fact, subjeot to the following: PERMIT

CONDITIONS Construction and Equipment

Specifications (1) The Permittee

shall operate the Facility in accordance

with the plans and specifications submitted to the Agency and in accordance

with the conditions

set forth herein, including the equipment

specifications

as listed in Findings

of Fact (A). [10 V.S.A. §§556(c) and 556a(d)] [§5- 501 (1) of the Regulations] (2) Except as provided

below, the Facility at no time shall operate more than two (2) of its four (4) boilers on residual fuel oil concurrently.

For the purpose

of this condition,

a third boil.er may be available

in "standby"

mode while the other two (2) boilers are operational.

Standby mode shall be defined as a mode of operation

which does not produce a measurable

steam output. The Facility may operate three (3) of its four (4) boilers on fuel oil concurrently

if the Facility exclusively

burns fuel oil having a sulfur content of 1% by weight or less in the three boilers. [10 V.S.A. §556(0)] [§5-406 of the Regulations] (3) Each boiler shall be equipped

with a steam output chart or equivalent

recording

device. Each steam chart or recording

device shall be operational

whenever

the boilers are operated. The steam output record shall be made available

to the Agency upon request.

[10 V.S.A. §556(c)] [AP-96-019] (4) The Facility shall vent exhaust from its equipment,

vertically

through stacks of the following heights: Coating Oven #1 44 Coating Oven #2 46 Coating Oven #2b Wickes Boiler #1 193 Wickes Boiler #2 B&W Boiler #3. B&W Boiler #4 167 Coating Mixer 12. Cylinder Exhaust #1 29 Cylinder Exhaust #2

39 Dryer Hood #1 Dryer Hood #2 40 Page 9 of 22Rock-Tenn Converting

Company #AOP-05-018a [AP-96-019] [§5-406 of the Regulations] Operational

Limitations (5) The Facility shall not burn more than 1,024,800

gallons of residual

fuel oil with a sulfur content of 2.0 percent by weight in all boilers combined

based on any rolling twelve (12) consecutive calendar

month period commencing

with the issuance

of this permit. Should the Facility choose to burn fuel oil with a sulfur content less than 2.0 percent by weight, then the quantity of fuel oil shall de limited by the following.formula

based on any rolling twelve (12) consecutive calendar

month period commencing

with the issuance

of this permit: (GPY) x (%S) < 2,049,600 Where "GPY" means gallons of fuel oil, "%S" means the weighted

average

sulfur content of the fuel expressed

as percent by weight. [10 V.S.A. §§556(c)] [AP-96-019]

[{}5-502 avoidance of the Regulations] (6) The fuel oil burned at the Facility shall not exceed a maximum

sulfur content of 2.0 percent by weight.

[§5-221(1)(a)

of the Regulations] (7) Waste Oil Used as a Fuel (a) The combustion

efficiency

of any boiler burning waste oil, either alone or in combination with any other fuel, shall be ninety-nine

(99) % or greater.

Combustion efficiency shall be determined

using the following

equation:

CE (%)

CO•

x 100 CO• + CQ

(b)
(c) Where; CE Combustion

efficiency, CO2 % by volume of carbon dioxide in the flue gas on a dry basis, and CO % by volume of carbon monoxide

in the flue gas on a dry basis. The Permittee

shall comply with all necessary

requirements

for handling,

storage, and disposal

of waste oil specified

in the Vermont

Hazardous

Waste Management Regulations. The Permittee

shall only burn waste oil which has properties

and constituents

within the allowable

limits set forth in Table A of the Regulations

as reproduced

on the next page:

Page 10 of 22Rock-Tenn Converting

Company #AOP-05-018a

(8)

(9) Polychlorinated

Bephenyls

(PCBs) Total Halogens ArsenicCadmiumChromium <2 ppm.maximum 1000 ppm maximum 5 ppm maximum 2 ppm maximum 10 ppm maximum Chlorine 500 ppm maximum Lead 100 ppm maximum Net Heat of Combustion 8000 BTU/Ib minimum Flash Point 140 degree F minimum

Note: 1units of pads per million (ppm) are by weight on a water free basis. [§5-221 (2) of the Regulations] The Permittee

shall not install or operate a stationary

reciprocating

internal combustion engine, as defined in the Regulations,

that is 450 bhp or greater unless the engine complies with {}5-271 of the Regulations,

as applicable.

Engines installed

after July 1, •1999 or leased after July 1, 2003 must comply with the emission

standards

of {}5-271 of the Regulations immediately upon installation,

including

those engines

installed

for emergency

only operation. Engines

installed

prior to July 1, 1999 must comply with the emission

standards of {}5-271 of the Regulations

by no later than July 1,2007 or those engines must be limited to emergency

only operation

thereafter.

The new installation

of any size stationary reciprocating interna combustion

engine, even those below 450 bhp, may still require approval from the Agency in the form of an amended

Permit prior to installation.

Stationary reciprocating internal combustion

engines include those used to power generator

sets or to provide shaft power for equipment

but.does

not include engines

used to power motor vehicles. [§§5-501 and 5-271 of the Regulations] The emergency

generator(s)

at the Facility shall be used only during emergency

power failures except for a maximum

period of up to 100 hours per year each for routine testing and maintenance.

Emergency

power failures are defined as those times when the normal power source for the Facility is temporarily

unavailable

due to circumstances

beyond the reasonable control of the Permittee.

In the event the Facility must take action to restore the normal power source, the Facility shall take such action in a reasonable

period of time. The emergency generator(s)

shall not be used as part of any peaking or load shedding

activities without the prior written approval

of the Agency.

[10 V.S.A. §§556(c) and 556a(d)] [§§5-401(6)(c)

and 5-501 Page 11 of 22Rock-Tenn Converting

Company #AOP-05-018a

of the Regulations] (10) The Permittee

shall burn only natural wood in any open burn pile and shall only burn in accordance with this Permit and the Regulations.

For the purposes

of this Permit, natural wood shall be defined as trees, including

logs, boles, trunks, branches,

limbs, and stumps, lumber including

timber, logs or slabs, especially

when dressed for use. This definition

shall also include pallets which are used for the shipment

of various materials

so long as such pallets are not chemically

treated with any preservative,

paint, or oil. This definition

shall not extend to other wood products

such as sawdust,

plywood,

particle board and press board. Prior to conducting

any open burning of natural wood, the Permittee

shall notify the Air Pollution Control Officer and shall obtain approval

from the Air Pollution

Control Officer to conduct open burning at the Facility, if required.

[§5-202 of the Regulations] Emission Limitations (11) In order to maintain

Facility emissions

of nitrogen

oxides (NOx) below the threshold

of {}5- 251 (3) of the Regulations,

the Permittee

shall limit emissions

of nitrogen

oxides from the entire Facility to less than one-hundred

(100) tons per year based on any rolling twelve (12) consecutive calendar

month period commencing

with the issuance

of this permit. [10 V.S.A. §556a(d)] [§5-251 (3) avoidance of the Regulations] (12) Total emissions

of VOCs from the Facility shall not equal or exceed fifty (50) tons per rolling twelve (12) consecutive

calendar

month period without prior Agency review and approval. Compliance with this limit shall be determined

based upon the products

employed,

monthly usage rates, and VOC contents

of the various products

used by Rock-Tenn

at the Facility. [10 V.S.A. §556a(d)] [{}5-253.20 avoidance of the Regulations]

Page 12 of 22Rock-Tenn Converting

Company #AOP-05-018a
(13) Emissions

of particulate

matter shall not exceed the following

limits:

(!4) Coating Dryer #1

5 Coating Dryer #1 b

2.983.264 Coating Dryer #2b

Wickes Boiler #1 Wickes Boiler #2 B&W Boiler #3 B&W Boiler #4 Diesel Emergency

Generator

1.678927333116

0.5

0.180.310.290.290.40

2,51.491.6320.83516.08.89,6.

3.7 Ibs/MMBTU equals pounds of pollutant emitted per million British Thermal Units of heat input. Ibs/hour equals pounds of pollutant emitted per hour. §5-231(3)(a)(i)

§5-231 (3)(a)(ii)

Any emission

testing conducted

to demonstrate

compliance

with the above emission

limit shall be performed

in accordance

with 40 CFR Part 60, Appendix

A, Reference

Method.5

or an alternative

method which has been published

in 40 CFR provided

the federally

approved alternative method has been accepted

in writing by the Agency

before testing. [10 V.S.A. §556a(d)] [§5-404 of the Regulations] (a)

(b) With the exception

of the paragraph

below, the Facility shall not cause or allow the application of any coatings

on its paper coating ines with a VOC content in excess of 2.9 pounds per gallon of coating,

(excluding

water and exempt compounds),

as applied. [10 V.S.A. §556(c) and §5-253.10 of the regulations] If multiple coatings

are applied during the same day, the Facility shall not cause or allow the application

of coatings

whose daily-weighted

average

VOC content exceeds 2.9 pounds

per gallon ("lbs/gallon"),

excluding

water and exempted compounds, as applied.

The daily-weighted

average

VOC content

shall be calculated as follows:

Page 13 of 22Rock-Tenn Converting

Company #AoP-05-018a

Evo c

Where:Evoc Is the daily weighted

average VOC content in Ibs/gallon,

excluding

water and exempted compounds,

as applied. Mi The total mass usage of an individual

coating applied in 24-hour period in units of gallons per day. Cl The VOC content of the individual

coating applied during the 24-hour period in units of Ibs/gallon,

excluding

water and exempted

compounds,

as applied. Each individual

coating applied in the 24-hour period. (c) Any testing that is conducted

to demonstrate

compliance

with the above VOC contents limits shall be performed

in accordance

with Reference

Method 24 of Appendix A of 40 CFR Part 60 or an alternative

method which has been published

in 40 CFR provided

the federally

approved

alternative

method has been accepted

in writing by the Agency before testing. [10 V.S.A. §556a(d)] [AOP-95-148] (15) Emissions

of visible air contaminants

from any process

stack at the Facility, except where otherwise noted in this Permit, shall not exceed twenty (20) percent opacity for more than a period or periods aggregating

six (6) minutes

in any hour and at no time shall visible emissions exceed sixty (60) percent c pacity.

(16) Any emission

testing conducted

to demonstrate

compliance

with the above emission

limits shall be performed

in accordance

with the proposed

Federal

Reference

Method

F-1 contained in the Federal Register

Vol.51, No.168, pp. 31076-31081,

August 29, 1986 or an equivalent method approved

in writing by the Agency.

[AP-96-019]

[§§5-211(2),

5-211(3) and 5-404 of the Regulations]Emissions of visible air contaminants

from the Coating Dryer #1, #2, Wickes Boiler #1, #2, B&W Boiler #3, and #4,shall not exceed forty (40) percent opacity for more than a period or periods aggregating

six (6) minutes

in any hour and at no time shall visible emissions exceed sixty (60) percent opacity. Any emission

testing conducted

to demonstrate

compliance

with the above emission

limits shall be performed

in accordance

with the proposed

Federal

Reference

Method

F-1 contained in the Federal Register

Vo1.51, No.168, pp. 31076-31081,

August 29, 1986 or an equivalent method approved

in writing by the Agency.

[§§5-211(1),.

5-211(3) and 5-404 of the Regulations] Page 14 of 22Rock-Tenn Converting

Company •AOP-05-018a (17)

(18) Emissions

ofvisible

air contaminants

from any boiler stack where waste oil is being fired shall not exceed twenty (20) percent opacity for a period or periods aggregating

six (6) minutes in any hour and at no time shall visible emissions

exceed sixty (60) percent opacity. Any emission

testing conducted

to demonstrate

compliance

with the above emission

limits shall be performed

in accordance

with the proposed

Federal

Reference

Method

F-1 contained in the Federal Register

Vol.51, No. 168, pp. 31076-31081,

August 29, 1986 or an equivalent method approved

in writing by the Agency.

[AP-96-019]

[§§5-211(2),

5-211(3) and 5-404 of the Regulations]Emissions of state hazardous

air contaminants

(HACs) from the applicable

operations

at the Facility shall not equal or exceed their respective

Action Level (found in Appendix

C of the Regulations) unless the Agency has reviewed

and approved

such HAC emission

under §5- 261 of the Regulations.

[§5-261 of the Regulations] (19) The Permittee

shall not discharge,

cause, suffer, allow, or permit from any source whatsoever such quantities

of air contaminants

or other materia

which will cause injury, detriment, nuisance

or annoyance

to any considerable

number of people or to the public or which endangers

the comfort,

repose, health or safety of any such persons or the public or which causes or has a natural tendency

to cause injury or damage

to business

or property. The Permittee

shall not discharge,

cause, suffer, allow, or permit any emissions

of objectionable odors beyond the property

line of the premises.

[§5-241(1)and

(2)of the Regulations]

(20)

(21)

(22) Compliance

Testing

and Monitoring The Permittee

shal perform

emission

testing on the Wickes Boiler #1 for NOx, PM, and Combustion Efficiency

and shall furnish the Agency with a written report of the results within thirty (30) days after the completion

of the testing. The initial emission

testing shall be performed during calendar

year 2006; emission

testing shall be conducted

at a minimum once every five years. The emission

testing shall be performed

in order to demonstrate compliance with the emission

limitations

specified

within the conditions

of this Permit. At least thirty (30) days prior to performing

the emission

testing required

above, the Permittee shall submit to the Agency

a pretest report prepared

in accordance

with the Agency's "Source Emission

Testing Guidelines".

[§§5-402(1),

5-404(1), 5-405(1) and 5-1015(a)(3)

and (4) of the Regulations] Record Keeping

and Reporting The Permittee

shall maintain

records of the total quantity of fuel oil consumed

in the boilers, in gallons, each month. At the beginning

of each month, the Permittee

shall calculate

the total quantity of fuel oil consumed

in the boilers, in gallons, during the previous

twelve (12) consecutive month period commencing

with the issuance

of this permit, [10 V.S.A. §§556(c)and 556a(d)] [§5-405(1 of the Regulations] The Permittee

shall maintain

records in a log book of all hours of operation

of each emergency generator

and shall make such records available

to the Agency upon request. Page 15 of 22Rock-Tenn Converting

Company #AOP-05-018a The records shall include: the dates on which each engine was operated;

the number of hours the engine was operated

on the respective

date, including

the starting and ending time shown on the engine's

elapsed

hour meter; the purpose

of the operation

be it emergency, testing or maintenance;

and, if the purpose

of the operation

was for an emergency, the records shall include a brief description

of the emergency

and its cause. [10 V.S.A. §§556(c) and 556a(d)] [§5-405(1 of the Regulations] (23) Whenever

the Facility adds waste oil to its boiler's fuel tank, it shall record the date and approximate amount of waste oil added. [10 V.S.A. §556(c)] [AP-19-019] (24) In addition

to the record keeping

requirements

above, the Facility shall maintain

the following records: (a) For its paper coating lines each day the name and identification

number of each coating, as applied, on each paper coating unit. (b) The mass of VOC per volume of each coating

(excluding

water and exempt compounds), as applied, used each day on each paper coating unit. (c) Monthly usage rate of VOC containing

material used in the production

of paperboard in units of gallons or pounds. (d) Monthly

consumption

of natural gas and fuel oil in gallons.

(25)

(26) For the purpose

of condition

the paragraphs

above, "coating

unit" shall be defined as a coating application

station and its associated

flash off area, drying area and/or oven, where coating is applied and dried or cured on a paper coating line. A paper coating line may include more than one paper coating unit. At the beginning

of each month, the Facility shall calculate

and record the total quantity of VOC's and NOx emissions

during the previous

(12) consecutive

calendar

month period. [10 V.S.A. §556(c) and §5-253.10 and 5-405(1 of the Regulations] The Permittee

shall maintain

records of the results of any combustion

efficiency

testing conducted on the boilers during the burning of waste oil. These records shall at least include the test date, identification

of boiler tested, a measurement

of the load on the boiler (such as fuel. feed rate or steam production

rate), the concentrations

of oxygen,

carbon monoxide and carbon dioxide in the exhaust gas as well as the calculated

combustion

efficiency.

[10 V.S.A. §§556(c) and 556a(d)] [§§5-405(1

and 5-1015(a)(3)

and (4) of the Regulations]

[§5-221(2)(b)(iv)] The Permitteeshal]

obtain from the fuel supplier,

for each shipment

of fuel oil received

at the Facility,

a certification

or invoice stating the sulfur content

of the fuel oil. The certification or invoice shall include the name of the fuel oil supplier,

date of delivery,

fuel type, quantity

of fuel oil delivered,

and a statement

from the fuel oil supplier

that the oil complies with the specifications

for fuel oil numbers

1 or 2, as defined by the American Society of Testing and Materials

in ASTM D396, "Standard

Specifications

for Fuel Oils" or a statement as to the sulfur content of the fuel oil in percent sulfur by weight. [10 V.S.A. §§556(c) Page 16 of 22Rock-Tenn Converting

Company #AOP-05-018a

and 556a(d)] [§5-405(1)of

the Regulations] (27) Within thirty. (30) days after July 1 and January

1 of each year, the Permittee

shall submit to the Agency,

signed by a responsible

official of the Facility, a report containing

the following information regarding

thelpreceding

six (6) months: (a)(b)(c)(d) A summary

of any periodic emission

testing completed

during the 6 month period; A summary

of the fuel usage records required

by this Permit; and A statement

of the sulfur content of any and all fuel delivered

to the Facility during the reporting

period. A summary

of the VOC and NOx emissions

records required

by conditions

of this permit. [§§5-402(1 ), 5-405(1 and 5-1015(5) of the Regulations] (28) Records

of all required

compliance

testing shall include the following: (a)(b)(c)(d)(e)(f) the date, place, and time of sampling

or measurements; the date analyses

were performed; the company

or entity that performed

the analyses; the analytical

techniques

or methods

used; the results of all such analyses;

and the operating

conditions

existing at the time of sampling

or measurement. [§§5-402(1 ), 5-405(1 and 5-1015(5) of the Regulations] (29)(30)

(3!) All records shall be retained

for a minimum

period of five (5) years from the date of.record and shall be made availableto

the Agency upon request.

[§§5-402(1),

5-405(1) and 5-1015(a)(7)ofthe Regulations]The Permittee

shall notify the Agency in writing within ten (10) days of any violation,

of which it is aware, of any requirements

of this Permit.

This notification

shall include, at a minimum, the cause for the violation

and corrective

action or preventative

maintenance taken to correct the violation.

[§§5-402(1)

and 5-1015(a)(6)

of the Regulations] The Permittee

shall notify the Agency in writing of any proposed

physical

or operational change at the Facility which may increase

the emission

rate of any air contaminant

to the ambient air regardless

of any concurrent

emission

reductions

that may be achieved.

This notification requirement.includes, but is not limited to, the proposed

installation

of any new equipment that is a source of air pollution,

including

the replacement

of an existing permitted air pollution

source.

If the Agency

determines

that a permit amendment

is required, a new application

and the appropriate

application

fee shall be submitted.

The permit amendment

shall be obtained

prior to commencing

any such change.

[10 V.S.A. §556(c)] [§§5-402(1 and 5-501 of the Regulations] (32) The Facility shall develop and implement

an operation

and maintenance

plan for its boilers. The Facility shall revise this plan at the Agency's

request or on its own motion to reflect equipment or operational

changes.

Said operation

and maintenance

plan shall be present at Page 17 of 22Rock-Tenn Converting

Company #AOP-05-0t

8a the Facility at all times and shall be made available

to representatives

of the Agency upon request. The operation

and maintenance

plan shall include, but not be limited to, provisions for annual boiler tune-up,,

and provisions

for maintaining

records of routine maintenance inspections, findings of those inspections,

and any corrective

actions which were taken. [10 V.S.A. §556(c), §§5-405(1) and 5-1015(a)(3)

of the Regulations

and 40 CFR Part 70 §70.6(a)(3)(i)(B)] (33) The Facility shall take reasonable

precautions

at all times to control and minimize

emissions of fugitive particulate

matter and volatile organic compounds

from the operations

at the Facility. This shall include but not be limited to the following: (a) Taking reasonable

precautions

to prevent fugitive particulate

matter. (b) The covering

of all containers

which contain VOC when not in use. [10 V.S.A. §556a(d)] (34) By February

1st of each year, the Permittee

shall submit an annual certification

of compliance for the previous

calendar

year which ascertains

and identifies

the compliance status of the Facility with respect to all terms and conditions

of this Permit, including

but not limited to the following: (a)(b)(c)(d)(e)(f) Identification

of each term or condition

of the permit that is the basis of the certification; The compliance

status; Whether compliance

was continuous

or intermittent;

and The methods

used for determining

the compliance

status of the Facility over the reporting period. Emissions of federal HAPs from. the Facility are less than ten (10) tons per year for each individual

HAP and less than twenty-five

(25) tons per year for total HAPs; and Emissions of each regulated

state HACs is less than its respective

Action Level (found in Appendix

C of the Regulations)

or the emission

of the respective

HAC has previously been reviewed

and approved

by the Agency

under {}5-261 (3) of the Regulations. A copy of the compliance

certification

shall also be sent to the U.S. Environmental Protection Agency at the following

address:

(35) Air Technical

Unit (Mail Code SEA) Office of Environmental

Stewardship U.S. Environmental

Protection

Agency John. F. Kennedy

Federal Building Boston, MA 02203 [{}114(a)(3) of the CAA] [{}§5-402(1

and 5-1015(a)(11

of the Regulations] The Permittee

shall calculate

the quantity of emissions

of air contaminants

from the Facility annually. If the Facility emits more than five (5) tons of any and al air contaminants

per year, the Permittee

shall register the source with the Secretary

of the Agency

(hereinafter "Secretary"), and shall renew such registration

annually.

Each day of operating

a source which is subject to registration

without a valid, current registration

shall constitute

a separate Page 18 of 22Rock-Tenn Converting

Company #AOP-05-018a violation and subject the Permittee

to civil penalties.

The registration

process shall follow the procedures

set forth in Subchapter

VIII of the Regulations,

including

the payment

of the annual registration

fee on or before May 15 of each year. [SubchapterVIII

§§5-802, 5-803, 5-807, 5-808 of the Regulations] (36) All records,

reports, and notifications

that are required

to be submitted

to the Agency by this Permit shall be submitted

to: Agency of Natural Resources Air Pollution

Control Division 103 South Main Street, Bldg 3 South Waterbury, Vermont

05671-0402. [§5-402(1 of the Regulations]

(37)

(38)

Standard

Permit Conditions These Permit conditions

may be suspended,

terminated,

modified,

or revoked for cause and reissued upon the filing of a written request with the Secretary

of the Agency

(hereinafter "Secretary") or upon the Secretary's

own motion.

Any modification

shall be granted only with the written approval

of the Secretary.

If the Secretary'

finds that modification

is appropriate; only the conditions

subject to modification

shall be re-opened.

The filing of a request for modification,

revocation

and reissuance,

or termination,

or of a notification

of planned changes

or anticipated

non-compliance

does not stay any terms or conditions

of this Permit. The Secretary

may provide opportunity

for public comment

on any proposed modification of these conditions.

If public comments

are solicited,

the Secretary

shall follow the procedures

set forth in 10 V.S.A. {}556 and {}556a, as amended.

[!0 V.S.A. §§556(d) and 556a(g)] [{}§5-1008(a)

and 5-1008(e) of the Regulations] Cause for reopening,

modification,

termination

and revocation

of this Permit includes,

but is not limited to: (a)(b)(c)(d)(e)(f)(g) Inclusion

of additional

applicable

requirements

pursuant

to state or federal law; A determination

that the permit contains

a material

mistake

or that inaccurate information was used to establish

emissions

standards

or other terms or conditions of the operating

permit; A determination

that the operating

permit must be modified

or revoked

to ensure compliance with applicable

requirements; A determination

that the subject source has failed to comply with a permit condition; For Title V subject sources,

a determination

by U.S. EPA that cause exists to terminate, modify, revoke or reissue an operating

permit; Those causes which are stated as grounds

for refusal to issue, renew or modify an operating permit under {}5-1008(a)

of the Regulations;

or If more than three (3) years remain in the permit term and the source becomes subject to a new applicable

requirement. [§5-1008(e)(4) of the Regulations]

Page 19 of 22Rock-Tenn Converting

Company #AOP-05-018a

(39)

(40)

(41)

(42)

(43)

(44)
(45)

(46) The Permittee

shall furnish to the Agency, within areasonab

le time, any information

that the Agency may request in writing to determine

whether

cause exists to modify, revoke, reissue, or terminate

the Permit or to determine

compliance

with this Permit. Upon request,

the Permittee shall also furnish to the Agency copies of records required

to be kept by this Permit. [10 V.S.A. §§556(c) and 556a(d)] [§5-402(1) of the Regulations]

[40 CFR Part 70 §70.6(a)(6)(v)] By acceptance

of this Permit, the Permittee

agrees to allow representatives

of the State of Vermont access to the properties

covered by the Permit, at reasonable

times, to ascertain compliance with Vermont

environmental

and health statutes and regulations

and with this Permit. The Permittee

also agrees to give the Agency access to review and copy any records required

to be maintained

by this Permit, and to sample or monitor at reasonable times to ascertain

compliance

with this Permit. [10 V.S.A. §§556(c), 556a(d)and

557] §§5-402(1),

5-404, and 5-1015(a)(1 O) of the Regulations] All data, plans, specifications,

analyses

and otherinformation

submitted

or caused to be submitted to the Agency as part of the application

for this Permit or an amendment

to this Permit shall be complete

and truthful and, for Title V permit applications,

certified

by a responsible official whose designation

has been approved

by the Secretary.

Any such submission which is false or misleading

shall be sufficient

grounds

for denial or revocation of this Permit, and may result in a fine and/or imprisonment

under the authority

of Vermont statutes. [10 V.S.A. §§556(c) and 556a(d)] [§§5-505 and 5-1006(f) of the Regulations] For the purpose

of establishing

whether

or not a person has violated or •s in violation

of any condition of this Permit, nothing in this Permit shall preclude

the use, including

the exclusive use, of any Credible evidence

or information

relevant to whether

a source would have been in compliance

with applicable

requirements

if the appropriate

performance

or compliance test or procedure

had been performed.

[10 V.S.A. §§556(c) and 556a(d)] Any permit noncompliance

could constitute

a violation

of the federal Clean Air Act and is grounds for enforcement

action; for permit termination,

revocation

and reissuance,

or modification; or for denial of a permit renewal application.

[10 V.S.A. §§556(c) and 556a(d)] [§§5- 1008(a) and 5-1008(e) of the Regulations] It shall not be a defense

for the Permittee

in an enforcement

action that it would have been necessary to halt or reduce the permitted

activity to maintain

compliance

with the conditions of this Permit. [10 V.S.A. §§556(c) and 556a(d)] No person shall build, erect, install or use any article, machine,

equipment

or other contrivances, .the use of which, without resulting

in a reduction

in the total release of air contaminants to the atmosphere,

reduces or conceals

an emission

which otherwise

would constitute a violation

of these Regulations.

[§5-403 of the Regulations] The provisions

of this Permit are severable.

If any provision

of this Permit, or its application to any person or circumstances

is held invalid, illegal, or unenforceable

by a court of competent jurisdiction,

the invalidity

shall not apply to any other portion of this Permit which can be given effect without the invalid provision

or application

thereof.

[10 V.S.A. §§556(c) and Page 20 of 22Rock-Tenn Converting

Company 556a(d)] •AOP-05-018a

(47)(48)

(49)

(5O) This Permit does not convey any property

rights of any sort or any exclusive

privilege,

nor does it authorize

any injury to private property

or any invasion

of personal

rights. [10 V.S.A. §§556(c) and 556a(d)] All subsequent

owners and/or operators

of this Facility must request an amendment

and transfer of this Permit prior to commencing

any operations

covered

by this Permit.

All subsequent owners and/or operators

shall submit to the Agency as part of the request for amendment al such information

the Agency deems necessary

to establish

legal ownership and/or interest in the property

and all such information

the Agency deems necessary

to ensure the 0ew owners

and/or operators

will construct

and operate

the Facility in compliance with the Regulations

and this Permit. The terms and conditions

of this Permit shall remain in full force and effect after submittal

of the request for amendment

and until the. issuance

of an amended

Permit or denial. Should the Secretary

deny the request,

the new owner and/or operator

must take whatever

action •s necessary

to comply with the denial. [lO V.S.A. §§556 and 556a] [§§5-501, 5-1004, and 5-1013(a) of the Regulations] With the exception

of conditions

(1), (2), (3), (5), (11), and (12) above, this Operating

Permit shall expire January

11, 2011. The Permittee

shall submit to the Agency

a complete application for renewal

of the Operating

Permit at least twelve (12) months before the expiration of the Operating

Permit. If a timely and administratively

complete

application

for an operating

permit renewal

is submitted

to the Secretary,

but the Secretary

has failed to issue or deny such renewal

before the end of the term of this Operating

Permit, then the Permittee may continue

to operate the subject source and all terms and conditions

of this Operating Permit shall remain in effect until the Secretary

has issued or denied the operating permit renewal.

However,

this Operating

Permit shall automatically

expire if, subsequent to the renewal

application

being determined

or deemed

administratively complete pursuant

to {}5-1006

of the Regulations,

the Permittee

fails to submit any additional information

required

by the Secretary

as well as information

pertaining

to changes to the Facility within thirty (30) days or such other period as specified

in writing by the Secretary.

[§§5-1011 and 5-1012(a) of the Regulations]

[§§5-1005(c)

and 5-1012 of the Regulations] The conditions

of this Permit as set forth above supercede

all conditions

contained

in all prior Permits

issued by the Agency to the Permittee

for this Facility.

[10 V.S.A. §§556(c) and 556a(d)]

Page 21 of 22Rock-Tenn Converting

Company #AOP-05-018a

The Agency's

issuance

of this Air Pollution

Control Permit relies upon the data, judgment,

and other information supplied

by the Permittee.

The Agency makes no assurances

that the air contaminant source approved

herein will meet performance

objectives

or vendor guarantees

supplied

to the source Permittee.

It is the sole responsibility

of the Permittee

to operate the source in accordance with the conditions

herein and with all applicable

state and federal standards

and regulations. Dated this

day of Waterbury, county of Washington,

state of Vermont. 200, in the town of Agency of Natural Resources Jeffrey Wennberg,

Commissioner De partment

of Environmental

Conservation By: Richard A. Valentinetti,

Director Air Pollution

Control Division

JR/jrA2 Rock-Term Company

Sheldon Springs.

Page 22 of 22#AOP-04-005

State of Vermont Agency of Natural Resources Department of Environmental

Conservation

Air Pollution

Control

Division Waterbury, Vermont

Technical Support

Document For:Title V Air Pollution

Control

Permit

to Construct

and Operate #AOP-04-005

Ethan Allen,

Inc. Beecher Falls Division Main Street Beecher Falls, Vermont

05902-0217Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005
This document

is intended

to provide

additional

technical

information

and clarification in support

of the Permit.

It is not intended

to provide

a comprehensive review of the Facility

or permit process

or duplicate

the information contained

in the Permit. FACILITY AND PERMIT

SUMMARY: Ethan Allen, Inc. Beecher

Falls Division

("Ethan Allen") owns and operates

a wood furniture manufacturing facility at 1280 VT Route 253 (Main Street) in the town of Beecher

Falls, Vermont ("Facility"). Operations

at the Facility include a rough mill, drying kilns, woodworking

processes, wood gluing, traditional

spray wood finishing,

ultra-violet

(UV) roll coat wood finishing,

and boilers for process

and space heat. This Permit is the initial Title V Permit to Operate

for the Facility and incorporates

an emission

limitation

on federally

regulated

hazardous

air pollutants (HAPs) to a level below the federal major HAP source threshold

as requested

by Ethan Allen, Inc. The Permit also incorporates

minor modifications

recently completed

to the "System

A" and "System B" dust collection

systems. PROCESS DESCRIPTION: The Facility is a typical wood furniture

manufacturing

and finishing

plant that receives

raw logs that are debarked

and sawed into boards in the saw mill and sent to the onsite kilns for drying. The boards are then planed in the rough mill and ready for further processing

in the finishing

mill bldg. Here the boards may be further processed

into furniture

parts with saws, shavers, shapers, molders,

lathes, tenors, drills, and sanders.

Some furniture

pieces are then partially assembled and sent on to finish coating ,operations.

Some pieces are sent directly to finishing before assembly,

such as flatwood

pieces including

drawer bottoms

and back panels that go to the UV flatline finishing

system.

The pieces then undergo

final assembly

including

the addition of hardware.EQUIPMENT

SPECIFICATIONS:

see Permit

Page 2 of 12Ethan Allen, Inc, Beecher

Falls Division #AOP-04-005

EMISSION CALCULATIONS: °Emissions from the facility are from three main sources: (cyclones and fabric filters), and finishing

operations, Boilers: boilers, wood waste handling

Bigelow #240 59.5 Na Wickes #239 31.8 24.9 Bigelow #232 Na 19.5 CB #238 Na Dravo Na Rettew 21.0

Total Wood/Oil

Capacity (MMBTU/hr) 3.694.9

Total MMBTU/yr

(x8760) 831,324 94,468 wet/54,692

dry Max possible fuel usage (tons/yr or gal/yr) 2.5

67.9594,804 4,248,600 No.22 3,965,360 No.42

Based on a hig her heating value of 4400 BTUs/Ib at 50% moisture for wet wood and 7600 BTUs/Ib at 12% moisture for dry wood. These values represent the same heat content for wood and are sire ply adjusted for the weight percent of moisture in the fuel. 2 Based on a higher heating value of t40,000 BTU/gal for No.2 oil and 150,000 BTU/gal for No.4 oil. Thus if the Permittee

were to run at ful capacity

for 8760 hours per year it could burn 94,468 tons of wet wood or 54,692 tons of dry wood. However,

as a result of the fuel usage restrictions to keep NOx below 100 tpy, the Permittee

is more restrictively

limited for dry wood usage to 26,845 tons per year. Below are the maximum

amounts

of each fuel that can be burned and the facility still remain below 100 tpy NOx. In the case of No.2 and No.4 oil and Wet wood, the facility does not have the capacity

in its existing boilers to consume

this much fuel. No.2 oil: 0.02 Ibs NOx/ga

x "X" gal/yr 100 tpy NOx No.4 oil: 0.02 Ibs NOx/gal

x "X" gal/yr 100 tpy NOx Wet wood: 1.94 Ibs NOx/ton

x "X" tons/yr

100 tpy NOx Dry wood: 7.45 Ibs NOx/ton

x "X" tons/yr

100 tpy NOx "X" 10 million gal/yr "X" 10 million gal/yr "X" 103,093

tons/yr "X" 26,845 tons/yr

Page 3 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005

Worst case emission

scenarios

for each fuel case: ,1. Maximized

wet fuel usage scenarios: 94,468 tons wet wood (=91.6 tpy NOx) + 2,255 tons.dry

wood (=8.4 tpy NOx) #1 94,468 tons wet wood (=91.6 tpy NOx) + 840,000

gal No.2 oil (=8.4 tpy NOx) #2 94,468 tons wet.wood

(=91.6 tpy NOx) + 840,000

gal No.4 oil (=8.4 tpy NOx) #3

242245  ̧114073

<100<100<100

251252

7

.1616 PM/PM•0 particulate matter and particulate matter of 10 micrometers

in size or smaller; SO2 sulfur dioxide; NO, oxides of nitrogen measured as NO2 equivalent;

CO carbon monoxide; VOCs volatile organic compounds;

HAPs hazardous a•r pollutants as defined in §112 of the federal Clean Air Act. HCl is the largest single HAP with a potential of 8.2 tpy. 2. Maximized

dry fuel usage scenario: 26,845 tons dry wood (=100 tpy NOx) #4

5 <100

122

3 3. Maximized

No.2 oil scenarios: 4,248,600 gal No.2 oil (=42.5 tpy NOx) + 59,278 tons wet wood (=57.5 tpy NOx) #5 4,248,600 gal No.2 oil (=42.5 tpy NOx) + 15,436 tons dry wood (=57.5 tpy NOx) #6

15856 157

<100

167

5

i0 154 <100

81

3

5

Page 4 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005

4. Maximized

No.4 oil scenarios: 3,965,360 gal No.4 oil (=39.7 tpy NOx) + 62,165 tons wet wood (=60.3 tpy NOx) #7 3,965,360 gal No.4 oil (=39.7 tpy NOx) + 16,188 tons dry wood (=60.3 tpy NOx) #8

175 • 68 300

<100 11 <100 .84

3

5 5• Worst Case Boiler Emissions

of All Fuels

248 304

<100

260

7

17

Page 5 of 12Ethan Allen, Inc. Beecher.Falls

Division #AOP-04-005

Wood Waste Handling

Systems:

Fuel Metering bin Cyclone #6 Na Closed loop blower Sawmill Cyclone #7 and #8 Na green material only 4 Sawmill/Grinding Room Fabric Filter #9 •System B ' Pneumafil

#4 System B MAC #1 System A MAC #2 2,700

System A Cyclone #5 System A Pneumafil

#1 Silo #1 with cyclone #30 Silo #4 with cyclone #2. UV Flat Line Sander Pneumafil

#3 Main Plant Grinding Room Cyclone #1 Total

48,80031,300

0.06

58,200 0.020.02

1.48.45.4

6.136.823.7 50,400 0.02

8.7

38.1 0.06 29.9

131.0 18.1 35,200 0.06 Na air returned to SyStem B Pneumafil

#4 79.3

Na green material only 0.02 5.3 30,4503,000 0.06

1.5

13.3@5000hrs6.6334.9 gr/dscf equals grains of pollutant emitted per dry standard cubic foot of undiluted exhaust gas. See discussion

of condition (30) of permit for basis for emission limitations. 2 Ibs/hour equals pounds of pollutant emitted per hour based on the air flow rates as given n Findings of Fact A. TPY based on 8760 hours of operation unless noted otherwise. 4 Conveying

of green wood wastes are not considered

to be a particulate

matter emission due to its weight and rapid settling out of the air per APCD policy.

Page 6 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005 Finishing Operations: Since the Facility finishing

operations

were installed

prior to the inception

of the new source review permitting

requirements

there is no tons per year emission

cap on the VOC emissions from these operations,

The potential

emissions

are thus stated simply as greater than 50 tons per year which is the threshold

for determining

major source status under both the Permit to Construct and the Title V Permit to Operate

regulations.

Any modifications

to the finishing operations in the future could subject those modifications

to the new source review permitting requirements of section 5-501 of the Regulations.

Actual VOC emissions

from the Facility have ranged as high as 300 tons per year in 1992 to as low as 146.6 tons in 2003 as .they have implemented lower VOC coatings

and improved

coating

transfer

efficiency.

A historical summary of actual VOC emissions

is provided

below.

1987 25322682 19881989 2922 1990 2842 1991199219931994 26623002255.6251.6 4.4 1995 264.2 11.8 1996 224.7 40.3 1997 239.1 54.9 1998i999 a 222.8219:4 2000 4 219.0 2001 184.1 45.9 177.0 44.0 146.6 20022003 48.251.647.0

29.4
The registration

database

includes all hydrocarbons

in its VOC total, including acetone.

'Where acetone data is available, the VOC total above DOES NOT include acetone. 2 Acetone data is not available for these years but is assumed to be negligible

since its usage did not become widespread in the industry until it was delitsted by EPA as a VOC on June 16, 1995. a Installation

of flatline UV rollcoat unit. Installation of high solids hot spray for sealer and topcoat application.

Page 7 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005

Total Facility Emissions:

582.9 304

<100

260

>50

<10•5

APPLICABLE REQUIREMENTS

DISCUSSION: Section 5-211(1)

Prohibition

of Visible Air Contaminants,

Installations

Constructed

Prior to April 30, 1970 Bigelow

Boiler #240 and Wickes

Boiler #239. While the Facility was constructed prior to 1970, only the above two boilers are considered

subject to the above VE limits since all other boilers at the Facility were installed

or modified

after this date. Records indicate that the Bigelow Boiler #232 was installed

in 1970 but absent any additional

records it is reasonable to assume

that it did not commence

(•perations

until after April 30 th. All dust collection equipment-is

assumed

to have undergone

either modifications,

reconfigurations,

or replacements including

the tools ducted to them since 1970 and therefore

are subject to the more stringent

VE limitations

of 5-211 (2). Section 5-253.16

Wood Furniture

Manufacturing.

This state regulation

incorporates

the requirements of both the Control Techniques

Guideline

for VOC emissions

and the National Emission Standards

for Hazardous

Air Pollutants

(NESHAP)

for Wood Furniture

Manufacturing Operations (40 CFR Part 63 Subpart

J J), commonly

referred

to as the MACT (maximum achievable control technology)

standard

for wood furniture

manufacturing

operations.

As of the issuance of this Permit, Vermont

has not accepted

delegation

of this NESHAP

and instead intends to submit our rule to EPA for approval

in lieu of the MACT. In the interim, the Facility is subject to both the state and federal regulations

which are functionally

equivalent.

The Facility will remain subject to both regulations

despite the imposition

in this Permit of a cap on HAP emissions that will no longer classify the Facility as a major HAP source since EPA's "once-in, always-in" policy on applicability

to their NESHAP

regulations

applies and the authority

under HMSER enables

continued

applicability

to the state rule. Section 5-261 Control of Hazardous

Air Contaminants.

See below. 40 CFR Part 63, Subpart

JJ.- National

Emission

Standards

for Wood Furniture

Manufacturing Operations. See above Section 5-253.16. 40 CFR Part 63, Subpart

DDDDD

National

Emission

Standards

for Hazardous

Air Pollutants for Industrial,

Commercial,

Institutional

Boilers and Process

Heaters.

Ethan Allen has requested a cap on the HAP emissions

that will no longer classify the Facility as a major HAP source. While the MACT standard

was finalized

on February

26, 2004 before issuance

of this Permit restricting HAP emissions,

the Permit is being issued prior to the compliance

date contained

in the regulation

for existing

boilers which is three years after promulgation.

Therefore

the facility is not subject to this regulation

provided

the permit is issued and the cap remains

in place thereafter.

Page 8 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005

HAZARDOUS MOST STRINGENT

EMISSION

RATE DISCUSSION

(HMSER): As discussed

further in the Finding of Fact of the Permit, the Agency has determined

that the Facility has regulated

emissions,

namely from the finishing

operations,

of the following

HAC compounds in excess of their respective

Action Levels and those emissions

are now being reviewed under §5-261: Crystalline silica (14808-60-7) isobutyl acetate (110-19-0) isobutyl alcohol (78-83-1) 1,2,4-trimethyl benzene

(95-63-6) methyl amyl ketone (110-43-0) 1-butoxy-2-propanol (syn. butyl propasol)

(5131-66-8) The Agency has determined

that the Permittee

has achieved

HMSER

for the respective

HACs through implementation

of several emission

reduction

measures

over the past several years. These measures

are discussed

more fully in the Findings

of Fact but are comprised

of the following five measures: (1) coating reformulations

to reduce VOCs and TRI reportable

toxics and thus replace more toxic HACs and HAPs with less toxic compounds; (2) continued

reformulation

measures

specifically

focused

on increased

use of acetone

in place of more toxic components; (3) more extensive

use of high volume

low pressure

(HVLP) spray guns to improve

coating transfer efficiency

and reduce coating usage; (4) use of high solids "hot spray" coatings

(sealer 3.8 Ibs VOC/gal;

topcoat 4.8 Ibs VOC/gal)

in place of the previous

conventional

and precatalyzed

coatings

(sealer 4.0 4.3 Ibs VOC/gal; topcoat 3.6 6.0 Ibs VOC/gal).

The high solid hot spray coatings

use heat to increase

viscosity of higher solids coatings

with less solvent.

Due to the increased

solids content,

these coatings also attain the necessary

film build thickness

with two coats instead of the previous

standard

of three coats; and (5) the installation

of the UV flatline rollcoat finishing

system that uses 100% solids (solVent free) coatings where high quality finishes are not necessary

such as drawer bottoms

and backs. In addition,

the HMSER

determination

requires

the Permittee

to continue

to comply with the state wood furniture

regulation,

regardless

of that regulation's

applicability

section. Emissions of silica are also reduced

by measures

that decrease

coating usage such as HVLP spray guns, high solids coatings

and UV coating applications.

In addition,

overspray

filters are used to capture a minimum

of 95% of the overspray

in the exhaust

air. It should also be noted that while the silica in the coatings

is in the crystalline

silica form it is not emitted with the hazardous properties

of free crystalline

silica since it is encapsulated

in the overspray

coatings. As part of the HMSER

determination,

an emission

cap on each of the respective

HACs is being established. These emission

caps are based on the highest level of respective

HAC emission since year 2000 (first full year after implementation

of HMSER

measures)

plus a factor of growth of 33% which is equivalent

to the addition

of an additional

production

shift which could reasonably be accomplished

without triggering

a permit modification. The following

table provides

a summary

of actual HAC emissions

over the past several years. The year 2000 was selected

as the oldest year representing

actual emissions

under normal Page 9 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005 operations since it reflects the first year after full implementation

of all the emission

reduction measures. The year 2000 also represents

the highest production

year since 1991 at the facility in terms of sq.ft, of product finished

(8,362,097

sq.ft.). Subsequent

years show a decline in production due to the national

economic

decline and are not considered

fully representative

of normal operations.

Crystalline silica 1,2,4-Trimethyl benzene Isobutyl acetate Methyl amyl ketone

:ActionLevel0.0110.013229498

AnnualAnnual8 hr8 hr24 hr

34.028076000778004380

24.01706400064200

42366120055000 Butyl propasol 7.4 3440

3220 Isobutan01 63

8 hr

16720

16580

16160

4356541832265812688
Action Level is slated to be revised to 0.02 and moved from Category II to Category

(known or suspected carcinogensl based on review of latest toxicological

data. 2 Action Level is slated to be revised to 24.7 based on review of latest toxicological

data and Facility will no longer exceed AL at that time. Since the year 2000, the above hazardous

air contaminants

are the only ones that have approached or exceeded

their respective

Action Levels at the Facility, even if emissions

of all other contaminants

were to •ncrease

by 17.8% which is representative

of the 39 ton VOC increase being approved

over the existing

baseline

of 219 tons VOC per year. On an annual average basis, only silica and TtvlB exceed their Action Levels.

However,

since the remaining HAC Action Levels are based on 8 hr or 24 hr exposures,

it is not appropriate

to annualize

the emissions but rather base the comparison

on the operating

hours during which the emission actually occur. Thus for those HACs one must compare

the respective

Action Level to the annual emissions

divided by the operating

hours (not 8760 which is used to annualize

the emissions) and then multiplied

by 8. These HACs all exceed their respective

Action Level when 2000 hours of operation

is assumed.

No ambient

air quality impact evaluation

was required given the respective

emissions

are not significantly

exceeding

their respective

Action Levels. Note regarding

federal enforceability

and equivalency:

On February

10, 1982 the Federal EPA approved, as part of Vermont's

State Implementation

Plan, §5-261 of the Vermont

Air Pollution Control Regulations.

As approved,

§5-261 required

a "most stringent

emission

rate" (MSER), as defined for major stationary

sources

for the control of hazardous

air contaminants.

The current State of Vermont

hazardous

air contaminants

regulation,

as amended

on January

20, 1993, employs

both an action level and a "hazardous

most stringent

emission

rate" (HMSER) for the control of hazardous

air contaminants.

Both MSER and HMSER

are established

on a case-by-case basis and are based on the lowest emission

rate achieved

in practice

by such category of source.

The Agency has determined

that the use of an action bevel in conjunction with a HMSER

is at least as stringent

as the MSER as adopted

by the EPA. Page 10 of 12Ethan Allen, Inc. Beecher

Falls Division #AOP-04-005

MOST STRINGENT

EMISSION

RATE DISCUSSION

(MSER):

Not applicable
AMBIENT AIR QUALITY

IMPACT

EVALUATION

DISCUSSION

(AQIE):

Not applicable PERMIT CONDITIONS

DISCUSSION: (2) Boilers:oFlyash reinjection

is allowed

on those boilers that have historically

used it but since it increases PM emissions

it would not be allowed on other boilers.

The only other solid fuel boiler here is the sawmill's

Rettew furnace at 3.6 MMBTU

so this is not a significant issue. (3) Wood Waste Dust Collection

Systems: °The main concern

here is that the total air flow not increase

above the values provided to us since PM emissions

are directly calculated

from those air flow rates. In addition,
as the air to cloth ratios start to increase

above 10:1 it is more likely that they will not achieve the 0.02 gr limit if so limited. (6) Stack Heights:

The exhaust

gases from the Bigelow

Boiler #240 and the Wickes Boiler #239 shall be vented vertically

through

a stack or stacks which extends

a minimum

of seventy-nine (79) feet above the stack base grade elevation.

The stack shall not be equipped with any device that may obstruct

the upward discharge

of the exhaust

gases such as a fixed raincap.

[10 V.S.A. §§556(c)and

556a(d)] [§5-406 of the Regulations] °These stack heights are taken from the OP application

and are not based on a Permit to Construct or a modeling

analysis

requirement.

This condition

is intended

to establish

the base conditions

at the facility.

Under the authority

of 5-406, the Agency

may require modeling if these stack heights were ever to be decreased

in the future. (7) In order to maintain

emissions

of nitrogen

oxides (NO×) below the one hundred

(100) tons per year threshold

of §5-251(3),

the Permittee

shall not burn fuel in all boilers combined located at its Facility in quantities

greater than the following

limit during any rolling twelve (12) consecutive

calendar

month period: 0.02*X + 1.94"Y + 7.45"Z < 200,000 where: X quantity

of No. 4 and No. 2 fuel oil burned in units of gallons; Y quantity

of wet wood fuel burned in units of tons (as fired including

moisture); Z quantity

of dry wood fuel burned in units of tons (as fired including

moisture). The NOx emission

rates of 1.94 Ibs per ton of wet wood and 7.45 Ibs per.ton of dry wood in the above formula may be revised by the Agency

based on the results of any stack emission testing on the Facility boilers or other credible

emission

data as approved

by the Agency. [10 V.S.A. §§556(c)and

556a(d)] [§5-251 (3)of the Regulations] °The Permittee

burns a combination

of bark, wet wood chips, wet and dry sawdust,

and Page 11 of 12Ethan Al.len, Inc. Beecher

Falls Division #AOP-04-005 dry wood wastes.

The fuel oil emission

factor in the equation

above is from AP42 Section 1.3 Fuel Oil Combustion

(9/98) Table 1.3-1 which provides

a value of 20 Ibs/1000 gallons for both No.2 and No.4 fuel oil. The formula to account

for nitrogen content of residual

oil was not used. The wood fuel emission

factors are from AP42 Section 1.6 -Wood Residue

Combustion

in Boilers (9/03) which provides

a value of 0.22 bs/MMBTU for wet wood and 0.49 Ibs/MMBTU

for dry wood. A heat value of 4400 BTU/Ib is assumed

for wet wood at 50% moisture.

A heat value of 7600 BTU/Ib is assumed for dry wood at 12% moisture.

The values both assume

the same heat value of the wood and are s•mply adjusted

by the weight of the moisture

(4400 is to 50% solids as 7600 is to 88% solids). Thus 0.22 Ibs NOx/MMBTU

x 0.0044MMBTU/Ib

wood x 2000 1.94 Ibs NOx/ton

of wet wood burned.

The NOx emission

factors for wet wood and dry wood may be revised upward or downward,

decreasing

or increasing

allowed

annual fuel usage respectively,

based on actual stack emission

testing of these boilers. (14) S•)lvent Metal Cleaning: °Most large facilities

have a maintenance

shop that contains

a small Safety-Kleen

type degreaser so this condition

is added for completeness. (15) Stage Vapor Recovery

Controls:

(28)

(29) °The Facility has a small gasoline

tank for refueling

some on-site equipment.

While it is unlikely that they would receive deliveries

from tank trucks instead of account trucks, this condition is added for completeness

since any non account

truck delivery must be done with Stage vapor recovery. °Incorporates several of the HMSER

measures

the Permittee

has taken to achieve HMSER. Other measures

are contained

in the requirements

to require overspray

filters, specifically to address

silica emissions

(condition

[5]) and require use of HVLP (condition [24]).,PM [Boilers] °The wood boiler emission

limits are both based on 5-231(3)(b)(i)

since they were both installed prior to 1977. The oil boiler limits are based on 5-231(3)(a).

With respect to the Wickes boiler #239 which may burn both wood and No.4 oil, the wood emission

limit shall apply when wood fuel comprises

50% or more of the heat input to the boiler. (30) PM [Wood Waste Dust Collection

Systems] °]'hose dust collection

systems

that have historically

never been modified

are subject only to the 0.06 gr/dscf emission

limitation

of 5-231(1)(b).

For those dust collection systems which have been modified,

a lower allowed emission

rate has been imposed

to maintain any associated

emission

increase

below the "significant"

emission

increase thresholds of 5-502. The new System B units, which qualify as modifications

under the Regulations, are limited to 0.02 gr/dscf which is readily achievable

by a well maintained unit with air to cloth ratios below 10:1, thus no stack emission

compliance

test is being required at this time for these units.

Page

12 of 12VERMONT AGENCY

OF NATURAL

RESOURCES Department of Environmental

Conservation Air Pollution

Control Division

TECHNICAL SUPPORT

DOCUMENT

FOR PERMIT

TO CONSTRUCT AND OPERATE
#AOP-02-024

December 21,2004 Prepared By: Beth Eliason,

P.E.

APPLICANT: Agrimark-Cabot,

Inc. Home Farm Way Montpelier, Vermont

05602

SOURCE: Agrimark-Cabot,

lnc. Cheese Manuffa•uring 869 Exchange

St•et Middlebu•, Vermont

05753

APPLICATION CONTACT:

Ray Dyke, Vice President

of Technology Agrimark-Cabot, Inc. Home Farm Way Montpelier, Vermont

05602 Tel- (802) 229-9361Agrimark-Cabot, Inc., Middlebury TAOP-02-024

1. INTRODUCTION Agrimark-Cabot,

Inc. (also referred to herein as "Permittee")

owns and operates

a cheese manufacturing facility located at 869 Exchange

Street in the town of Middlebury,

Vermont

(also referred to herein as "Facility"). The Facility currently

operates

under a combined

construction

and operating

permit issued June 22, 2001 (#AOP-99-014a).

This permit expired July 17, 2003. Agrimark-Cabot

submitted

an application for renewal of their operating

permit on May 31,2002.

This Technical

Support Document details the Agency of Natural Resources,

De partment

of Environmental Conservation, Air Pollution

Control Division

(hereinafter

"Agency")

review for renewal of the Permit to Construct.

and Operate.

49 174

64

14

<50

>100

<10/25 PM/PMI0 particulate matter and particulate matter of 10 micrometers

in size or smaller; SO2 sulfur dioxide; NOx oxides of nitrogen measured as NO2 equivalent; CO carbon monoxide; VOCs volatile organic compounds;

HAPs hazardous air pollutants as defined in {}112 of the federal Clean Air Act. Emissions of individual HAPs each < 10 tpy and emissions of total HAPs combined <25 tpy. Actual total combined HAPs estimated at <1 tpy.
2. FACILITY

DESCRIPTION

AND LOCATION 2.1 Facility Locations

and Surrounding

Area Agrimark-Cabot, Inc. owns and operates

the cheese plant located at 869 Exchange Street, Middlebury,

Vermont.

The area surrounding

the Facility is primarily

industrial. The closest residences

to the Facility are at a distance

greater than one-half

a kilometer. The Facility is ]ocated 97 kilometers

from the Lye Brook Wilderness

area, and greater than 100 kilometers

from the Great Gulf and Dry River Wilderness

areas in New Hampshire. The Facility location and layout are depicted

in Appendix

A of this document. 2.2 Facility Description The operations

performed

at the Facility are classified

within the Standard

Industrial Classification Code 2022 (Production

of Natural,

Processed

or Imitation

Cheese).

The regulated sources of air contaminant

emissions

at the Facility are two 27 MMBTU/hour Nebraska boilers, two propane-fired

whey dryers, a whey powder conveying

system, two cooling towers, and two Cummins

emergency

generators.

Specifications

for emission sources are presented

in Table 2-1. Boilers: The Facility operates

two Nebraska

boilers for space and process heat. The boilers burn No. 6 fuel oil and each unit has an estimated

heat input of approximately

27 MMBTU/hr. Both boilers were installed

in 1974. Approximately

90% of the steam

Page 2 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024

Page 3 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024
demand at the facility is for process heat, so seasonal

variation

in fuel consumption

is minimal. Both boilers exhaust through a common

stack that is 115 feet above grade and 48 inches in diameter.

Emissions

from the boilers consist of combustion

products. Whey Dryers:

The two propane-fired

whey dryers are rated at 8 MMBTU/hr

and 12 MMBTU/hr maximum

heat input. The 8 MMBTU/hr

whey dryer spray-dries

whey protein concentrate ("WPC")..

Emissions

from this dryer are controlled

by cyclones

and fabric filters. The 12 MMBTU/hr

whey dryer is used to spray dry whey permeate.

Following thespray dryer, permeate

drying is completed

in a fluidized

bed. The emissions

from the permeate

dryer are controlled

by cyclones

followed

by a wet venturi-style

scrubber system. The fluidized

bed emissions

are controlled

by fabric filters. Emissions

from the whey dryers include both products

of combustion

and whey particulates. Whey Powder

Transport

System:

The whey vacuum

filtration system is used to transfer, store, and package

the finished whey product.

The system transports

dry whey permeate to a holding bin which gravity feeds to the packaging

machine.

Emissions from the system are controlled

by a fabric filter and then discharge

into the building.

As the whey powder transport

system discharges

inside the building it is not a source of ambient air contaminants. Evapco Cooling

Tower:

The Evapco cooling tower is used for process cooling.

The flow rate of the Evapco cooling tower is 1200 gallons per minute ("gpm").

Although

the cooling tower emits particulate

matter, calculations

demonstrate

that the emissions

are negligible (see Table 3-3). Lilly Hoffman

Cooling

Tower:

The Lilly Hoffman

cooling tower is used for process cooling. The cooling tower has a flow rate of 1,100 gpm. The operation

of the cooling tower results in negligible

emissions

of particulate

matter (see Table 3-3). Cheese Production:

The cheese-making

process

begins with the pasteurization

of raw milk. Following

pasteurization,

the milk is pumped

to a coagulation

tank, mixed with rennin, and cooked at approximately

100 degrees

Farenheit.

During coagulation

milk solids begin to separate

from the liquid, which is known as whey. Both the pasteurization and coagulation

tanks are heated using steam from the boilers. After coagulation,

the cheese is chopped

into curds and salted. The whey is removed

by .vacuum in a packing tower. The packed cheese is then cut into 40-pound

blocks, shrink-wrapped, and packaged

for shipping. According to the U.S. EPA Compilationof

Air Pollutant

Emission

Factors,

Fifth Edition, Volume I: Stationary

Point and Area Sources

("AP-42")

VOCs may be emitted during coagulation and ripening.

However,

emissions

cannot be estimated

at this time because AP-42 does not provide any VOC emission

factors.

It is unlikely that VOC emissions from these process steps would be great enough to cause the Facility to be classified

as a major source of VOCs. Whey Concentration

Processes:

The whey is removed

from the cheese and passed through a whey separator

to remove the butter fat. The whey is then processed

through an ultrafiltration

system to separate

the protein from the permeate.

The whey protein stream is dried in the 8 MMBTU/hr

whey dryer. The whey permeate

stream is condensed in the evaporator

and dried in the 12 MMBTU/hr

whey permeate

dryer.
Page 4 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024

2.3 Description

of Existing

Air Pollution

Control

Equipment See Table 2-1 for a listing of air pollution

control equipment

at the Facility. 2.4 Description

of Compliance

Monitoring

Devices This Facility is equipped

with "broken bag detectors"

on all fabric filters to monitor compliance. The broken bags are designed

to alert the operator

of potential exceedance of the particulate

emission

limit by an audible or visual alarm. 2.5 Proposed

Modifications

to Facility No modifications

were proposed

in conjunction

with the. operating

permit renewal application, 2.6 Proposed

Limitations The Permittee

has proposed

to limit theannual

fuel consumption

in the two Nebraska boilers to 2,200,000

gallons of residual fuel oil with a maximum

sulfur content of 1% by weight. 3. QUANTIFICATION OF POLLUTANTS The quantification

of emissions

from a stationary

source is necessary

in order to establish

the regulatory review process

necessary

for the operating

permit application

and to determine applicability with various air pollution

control requirements.

These determinations

are normally based upon allowable

emissions.

Allowable

emission

is defined as the emission

rate calculated using the maximum

rated capacity

of the source and, if applicable,

either: (a) the applicable emission standard

contained

in the Regulations,

if any, or (b) the emission

rate or design, operational or equipment

standard

specified

in any order or agreement

issued under the Regulations that is state and federally

enforceable.

An applicant

may impose in its application
an emission

rate or design, or an operational

or equipment

limitation

which may be incorporated in the Permit to restrict operation

to.a lower level. Such imitations

may include fuel restrictions or production

limits. 3.1 Designation

of the Facility for the Permit to Operate The designation

of the Facility for the Permit to Operate

is determined

by its allowable emissions following

issuance

of the permit, taking into account any limitations

contained

in the permit that restrict the Facility's

allowable

emissions.

The proposed

Facility has annual allowable

emissions

greater then 10 tpy. The air contaminant

sources at the Facility are presented

in Table 2-1. The calculated

allowable

emissions

for each source are detailed

in Table 3-1, Table 3-2, Table 3-3, Table 3-4 and Table 3-5. An emissions summary is presented

in Table 3-6.

Page 5 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024

Table 3-1: Nebraska

Boiler Estimated

Allowable

Emissions (Two 27 MMBTU/hour

boilers) Emission Factor

Emission

Rate Pollutant (Ibs/1000

gallons)

(Ibs/hr)

(tpy) 2 Source PM 9.19(S) + 3.22

3.1

13.7 S021 157(S)

39.4

172.7 NO, 55

13.8

60.5

A P•-4•2-r•r•..l•._-•(

9/98

VOCs 1.13

0.3

1.2 HAPs 0.155

0.04

0.2

/kP-42-"f•ble-1T3=9"a

n d 1.3-11 (9/98) Fuel Sulfur content 1% by weight (S) 2Based on 8760 hours of operation per year and a facility imposed maximum of 2,200,000

gallons fuel oil per year

Table 3-2: Cummins

Diesel Generator

Set Estimated

Allowable

Emissions

1'2 (100 kW/166 hp and 250 kW/390 hp) Pollutant Emission

Factor

Emission

Rate

Source Ib/hp-hr (Ibs/hr)

(tpy) PM/PMI0 2.2 x 10 -3

1.2

0.1 SO2 2.05x 10 -3

1.1

0.1 NOx 3.1 x 10 .2

17.2

1.7

AP-42. Table 3.3-1 (10/96) CO 6.68 x 10 .3

3.7

0.4 VOCs 2.47 x 10 .3

1.4

0.1 HAPs 6.45 x 10 3

3.6

0.4 AP-42. Table 3.3-2/10/96)o Maximum capacity: (166 hp + 390 hp) x 200 hrs/¥ear

11,200 hp-hr/year 2Based on a facility imposed maximum of 100 hou'rs of operation per year for routine maintenance

and repair, and an estimated

100 hours.of emergency

use per year.

Table 3-3: Allowable

Particulate

Matter Emissions

from Cooling

Towers Maximum Source Design

Solids Flowrate Content (gpm) 2.

(ppm) 3 Lilly Hoffman 4 1100

10000.125

Emission

Factor Ib solid/Ibdrift0.001 EmissionRate Ibs PM drift/gal

(Ib/yr) cooling water 1.90 x 10 "5

11.0

Source Evapco 5

1200 1.25 x 10 .7 1.90 x 10 .5 0.0015 •Based on 8760 hours of operation per year 2gpm gallons per minute 3ppm parts per million 4Maximum solids content of water is controlled by conductivity

meter 5Maximum solids content of water is based on an onginal mineral content of 5000 ppm treated by reverse osmosis (efficiency

of 95%) twice. AP-42. Table 13.4-1 (1/95)

Page 6 of 13Agrimark-Cabot, Inc. Middlebury TAOP-02-024

Table 3-4: Estimated

Allowable

Emissions

from Whey Protein Concentrate

Dryer and Fabric Filters (EP-8, EP-9, EP-10, EP-11, EP-12) Emission Emission

Rate Pollutant Units

Source Factor (tons/year) SO22 0.1.(S)

Ib/1000 gal

AP-42 Table 1.5-1 (10/96)

0.3 NOx 4.5

Ib/1000 gal

Manufacturer

data

1.3 PM 0.01

gridscf

MSER 13 CO 12.6

Ib/1000 gal

Manufacturer

data

3.5 VOC 0.5 AP-42 Table 1.5-1 (10/96)

0.14 Ib/1000 gal 8 MMBTU/hr

propane fired burner. Maximum capacity: 64 gallons per hour, 560,650 gallons propane per year. Potential source of contaminants

from propane combustion:

NO2, CO, SO2, MOO. Whey particulates

are a source of PM 10 emissions. 2Sulfur content of propane (S): 10 grams per.100 cubic feet. 3MSER for dried whey powder emissions

is 0.01 grains Pet dry standard cubic foot. [34,600 dscfm x 0.01 gr/dscf x 7.14x10 .8 ton/g, x 525,600 m•ntyr 13 t°nS/year

Table 3-5:

PollutantSO2 2

PM

VOC

EmissionFactor0.1(S)4.50.02'12.60.5Estimated

Allowable

Emissions

from Permeate

Dryer and Wet Scrubber (EP-13) UnitsIb/1000 gal Ib/1000 galgr/dscfIb/1000 gal Ib/1000 gal

SourceAP-42 Table •.5-1 (10/96) Manufacturer data MSERManufacturer data AP-42 Table 1.5-1 (10/96)

Emission

Rate (tons/year) 0.31.4213.90.16 12 MMBTU/hr

Propane fired burner. Maximum

capacity: 71 gallons per hour, 6210,960 year.Potential source of contaminants

from propane combustion:

NO2, CO, SO2, VOC. Whey particulates

are a source of PM10 emissions. 2Sulfur content of propane (S): 10 grams per 100 cubic feet. 3MSER for dried whey powder emissions

is 0.02 grains pe[ dry standard cubic foot. [28,000 dscfm x 0.02 gr/dscf x 7.14x10 "8 !°n/gr X 525,600 m•n/yr 21 t°nS/year

gallons propane per

Table 3-6:
Pollutant Summary

of Facility Allowable Emissions SO2NOx 65 PM Emission

Rate (tons/year) 173
48 CO 13 VOC 2

3.2 Designation

of Existing

Stationary

Source for the Permit to Construct No modifications

were proposed

as part of the permit renewal application.

Page 7 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024
4. APPLICABLE

REQUIREMENTS The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions

regarding the compliance

status contained

herein are not binding against the state of Vermont

in any future legal or administrative

proceedings.

The Agency will assess compliance

with these standards during any inspections

of the Facility.

The inspections

will include confirmation

of the proper operation

and maintenance

of equipment,

visual observation

of emission

points, and review of written records required

in the permit.

4.1 Vermont

Air Pollution

Control

Regulations

and Statutes §5-211(2) Prohibition

of Visible Air Contaminants

Installations

constructed subsequent to April 30, 1970 This emission

standard

applies to all installations

at the Facility.

Emissions

of visible air contaminants shall not exceed twenty (20) percent opacity for more than a period or periods aggregating

six (6) minutes

in any hour, and at no time shall visible emissions exceed sixty (60) percent opacity. The permeate

wet scrubber

system is subject to periodic monitoring

of visible emissions to demonstrate

compliance

with the visible emission

limits contained

in the permit. §5-221(1)(a) Prohibition

of Potentially

Polluting

Materials

in Fuel; Sulfur Limitation in Fuel (2% by weight) This prohibition

applies to all stationary

fuel burning equipment

at the Facility. The applicant is expected

to comply with this regulation

based on the use of No. 6 oil certified by the supplier to contain no more 1.0% sulfur by weight.

Natural gas and distillate

oil, by their official.fuel

specification

definition,

comply with this requirement. §5-231(1)(a) -Prohibition

of Particulate

Matter; Industrial

Process

Emissions This emission

standard

applies to both the whey protein concentrate

dryer and the whey permeate dryer. For each dryer, the total process weight entering

the dryer is based on the dry weight of the material

entering

the process. For the whey protein concentrate

dryer, the maximum

process

throughput

of 2,250 pounds per hour corresponds

to a particulate

matter emission

limit from Table 1 of the Regulations of 4.4 pounds per hour. For the permeate

whey dryer, the maximum

process throughput

of 5,235 pounds per hour corresponds to a particulate

matter emission

limit from Table 1 of the Regulations

of 6.9 pounds per hour. Particulate matter emissions

from the whey protein concentrate

and whey permeate dryers are subject to a MSER determination.

The MSER emission

limit for particulate matter emissions

from the wet scrubber/venture

control system on the permeate

whey dryer is 0.02 grains per dry standard

cubic foot. The MSER emission

limit for particulate matter emissions

from the fabric filter control device on the whey protein concentrate

and whey permeate

dryers is 0.01 grains per dry standard

cubicfoot.

These emission

limits are below the emission

imit standards

found in Table 1 of the Regulations

and described

Page 8 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024

above. Additional

discussion

of MSER for the Facility can be found in Section 5 of this Technical Support

Document. The Agency will assess compliance,with

this standard

as follows:

(1) The Permittee

is required to properly

operate and maintain

its dust collection

systems

including

fabric filter collectors, fabric filter monitoring

devices and wet scrubbers;

(2) the Permittee

is required to conduct periodic

particulate

matter testing of emissions

from the wet scrubber;

(3) visual observations

of each exhaust will be conducted

during Agency inspections

of the Facility; and, (3) the Facility has performed

stack tests to verify compliance

with the above referenced particulate

matter standard. §5-231(3)(a(i))- Prohibition

of Particulate

Matter; Combustion

Contaminants This emission

standard

applies to emissions

from the installations

where the heat input is 10 million BTU's or less per hour. This standard

applies to the two Cummins

diesel engine generators.

The allowable

particulate

emissions

from the generators

are:
Diesel Engine #1 (250 kw) Diesel Engine #2 (100 kw) 0.5 bs/MMBTU

Ib/hr 0.5 Ibs/MMBTU

0.6 b/hr The Permittee

has stated that they are in compliance

with this regulation. §5-231(3)(a(ii)) Prohibition

of Particulate

Matter; Combustion

Contaminants This emission

standard

applies to em=ssions

from combustion

installations

where the heat input is greater than 10 million BTU's per hour. This standard

applies to the two Nebraska oil-fired boilers. The boilers are rated at 27 MMBTU/hr.

The allowable

particulate emissions from the boilers are calculated

using the formula: EpM-1- 0 I'0.47039(l°g10HI)

+ 0.16936] where:EpM is the particulate

matter emission

limit, expressed

to the nearest hundredth pound per hour per million BTU's; HI is the heat input in millions of BTU's per hour. The allowable

emissions

from the generators

are 0.31 pounds/MMBTU

and 8.5 pounds/hour. The Permittee

has stated that they are in compliance

with this regulation. §5-231(4) Prohibition

of Particulate

Matter; Fugitive

Particulate

Matter This section requires

the use of fugitive PM control equipment

on all process

operations and the application

of reasonable

precautions

to prevent PM from becoming

airborne during the handling,

transportation,

and storage of materials,

or use of roads.. Based on the application

submittal

and information

available

to the Agency,

the Facility is not considered a source of fugitive particulate

matter subject to this regulation.

The Facility is required to take reasonable

precautions

at all times to control and minimize

emissions

of fugitive particulate

matter from the operations

at the Facility.

Page 9 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024 §5-241(1) & (2) Prohibition

of Nuisance

and Odor This requirement

applies to the entire Facility and prohibits

the discharge

of air contaminants that would be a nuisance

to the public or the discharge

of objectionable odors beyond the property-line

of the Facility.

Based on the application

submittal

and information available

to the Agency,

the Facility currently

is in compliance

with this regulation.§5-402 Written Reports

When Required This section gives the Agency authority

to require the Facility to submit reports summarizing records required

to be maintained

by the Agency. §5-403- Circumvention This section prohibits

the dilution or concealment

of an air discharge

in order to avoid air pollution control requirements. §5-502(3) Most Stringent

Emission

Rate ("MSER") As part of obtaining

approval

for modifications

made as part of AOP-99-014a,

the Agency required the Facility to achieve MSER pursuant

to §5-502(3)

of the Regulations.

See Section 5 of this report for more information

regarding

the applicability

of MSER.

4.2 Federal Air Pollution

Control

Regulations

and the Clean Air Act 40 C.F.R. Part 60 Subpart

Kb- Standards

of Performance

for Volatile

Organic Liquid Storage

Vessels

(Including

Petroleum

Liquid Storage

Vessels)

for Which Construction, Reconstruction,

or Modification

Commenced

after July 23, 1984 This regulation

applies to the 30,000 gallon storage tank for No. 6 fuel oil. The Facility is required to keep readily accessible

records showing

the dimensions

of the storage vessel and an analysis

showing

the capacity

of the vessel. In addition,

the Facility is required

to notify the EPA Administrator

within 30 days when the vapor pressure

exceeds

15 kPa. 40 C.F.R. Part 64- Compliance

Assurance

Monitoring Pursuant to requirements

concerning

enhanced

monitoring

and compliance

certification under the Clean AirAct ("CAA"),

EPA promulgated

new regulations

and revised regulation on October

22, 1997. These new requirements

implemented

compliance

assurance monitoring ("CAM") for major stationary

sources of air pollution

that are required

to obtain operating permits under Title V of the CAA. Subject to certain exemptions,

the new regulations require owners or operators

of such sources to conduct

monitoring

that satisfies particular•criteria

established

in the rule to provide a reasonable

assurance

of compliance with applicable

requirements

under the CAA. Monitoring

is proposed

to focus on emissions

units that. rely on pollution

control device equipment

to achieve compliance with the applicable

standards.

The regulations

also provide procedures

for coordinating these requirements

with the operating

permits program

regulations: Section 64.2 of 40 C.F.R. specifies

that each pollutant

specific emission

unit at a facility that meets a three-part

test is subject.to

the requirements

for CAM. An emission

unit must: (1) be subject to an emission

limit or standard; (2) use a control device to achieve compliance;

Page 10 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024 (3) have pre-control

emissions

that exceed or are equivalent

to the major
source threshold

in 40 CFR Part.70 (i.e., 10 tpy individual

HAP, 25 tpy total HAP, 50 tpy VOCs, or 100 tpy for any other a•r contaminant). Equipment at the Facility that meets the first criteria are the boilers and the exhausts

for the two whey dryers. As the boilers do not use control devices (criteria #2), the are not subject to CAM. The cyclones

and baghouses

collecting

product from the whey dryers are not considered

pollution

control devices as they are inherent

process-equipment

that collect product (40 CFR §64.1). The wet scrubber

on the whey permeate

line does meet the first two criteria, consequently

the pre-control

emissions

from the wet scrubber

have been calculated

for comparison

to the third criteria. As stated in the 16 November

2001 Agrimark Trip Report from C.E. Rogers Company,

the dry solids flow rate to the wet scrubber are between

17 and 18.8 Ibs/hr. This results in 82 tpy of particulate

entering

the wet scrubber

[(18.8 Ib/hr) x (8760 hr/yr) / (2000 Ib/ton)], which is less than the major source threshold

for particulates

of100 tpy. As none of the equipment

at the Facility meet the three criteria listed above the Facility is currently not subject to CAM. 40 C.F.R. Part 68- Chemical

Accident

Prevention

Provisions

(CAA 112(r): Risk Management Plan) Pursuant to 40 CFR §68.215,

facilities

storing quantities

of chemicals

greather

than threshold amounts

are required

to file a Risk Management

Plan with the EPA.AgrimarkCabot Inc. has filed such a plan for storage of anhydrous

ammonia

at the Middlebury facility.4.3 Non-Applicable

Requirements

For Which a Permit Shield Provision

Has Been Requested Pursuant to §5-1015(a)(14)

of the Regulations,

an owner/operator

may request to be shielded from potentially

applicable

state or federal requirements.

The Facility has not requested a permit shield from any specific,

potentially

applicable

requirement. Accordingly, the Agency has not granted any permit shields for the Facility.

5. CONTROL

TECHNOLOGY

REVIEW

FOR MAJOR

SOURCES

AND MAJOR MODIFICATIONS Pursuant to §5-261 of the Regulations

each new major source and major modification

must apply control technology

adequate

to achieve the Most Stringent

Emission

Rate ("MSER")

with respect to those a•r contaminants

for which there would be a major or significant

emission increase, respectively.

As determined

in AOP-99-014,

the Facility must achieve. MSER for PM/PM10.MSER has been applied to the whey dryer emission

points. The whey protein concentrate ("WPC") dryer has three emission

points: two baghouses

(#1 and #2) and a WPC conveyor/receiver baghouse.

The permeate

dryer also has three emission

points: the permeate fluid bed baghouse,

permeate

conveyor/receiver

baghouse,

and the permeate venturi-style wet scrubber

system.

Except for the permeate

wet scrubber

system, particulate emissions at these points are controlled

by fabric filters. The emissions

from the permeate

wet scrubber system are very hygroscopic

and are controlled

with the venturi-style

wet scrubber followed by a wet cyclonic

scrubber.

Page 11 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024

WPC Baghouse

#1 WPC Baghouse

#2 WPC Conveyor/Receiver

Baghouse

0.010.010.01

•0.810.850.22 Permeate Fluid Bed Baghouse

0.01

1.05 WPC Conveyor/Receiver

Baghouse

0.01

0.21 Permeate Wet scrubber System

0.02

4.02 The mass loading emission

limits were calculated

using average

stack conditions

(flow rate, temperature, percent moisture)

measured

during stack testing of the six emission

points during the late winter and spring of 2001 to convert the MSER emission

rate in grains per dry standard cubic foot (grldscf) to pounds per hour (Ib/hour).

The mass emission

limits were calculated using the following

formula: [Mass emission

limit, Ib/hr]

[Emission

limit,.gr/dscf]

x [Stack flow rate, dscf/min]

x [60 min/hr] [7000 grains/Ib]

The average

conditions

for each emission

unit are presented

in Table 5-2.

wPc Baghouse

#1 WPC Baghouse

#2 WPC Conveyor/Receiver Permeate Fluid Bed Permeate Conveyor/Receiver Permeate Wet Scrubber 164158841178993

94559876258812239247823476

5.65.60.63.10.85.5
6. AMBIENT

AIR QUALITY

IMPACT

EVALUATION An ambient

air quality impact evaluation

is performed

to demonstrate

whether

or not a proposed project will cause or contribute

to violations

of the ambient

air quality standards

and/or significantly deteriorate

existing air quality. The Agency's

implementation

procedures
Page 12 of 13Agrimark-Cabot, Inc., Middlebury TAOP-02-024 concerning the need for an ambient

air quality impact evaluation

under §5-406(1)

of the Regulations, specifies

that such analyses

may be required

when a project results in an allowable emissions

increase

of ten (10) tons per year or more of any air contaminant,

excluding VOCs. Additionally,

the Agency may require an air quality impact evaluation

where theshortterm allowable

emission

rates will significantly

increase

as a result of a project. The Facility is not undergoing

changes

subject to new source review as part of this operating permit renewal,

therefore

an impact evaluation

is not necessary

to assess compliance

with the ambient air quality standards. The Facility performed

extensive

modeling

in order to demonstrate

compliance

with National Ambient Air Quality Standards

("NAAQS")

and Prevention

of Significant

Deterioration

("PSD") increments for modifications

approved

in AOP-99-014.

The results of that modeling

effort were scaled for comparison

with NAAQS and PSD increments

for modifications

approved

in AOP-99- 014a. The model results demonstrated

compliance

with the NAAQS and PSD increments.

7. HAZARDOUS

AIR CONTAMINANTS The emissions

of hazardous

air contaminants

("HACs")

are regulated

under to §5-261 of the Regulations. Pursuant

to §5-261(1)(b)(ii)

of the Regu/ations,

all fuel burning equipment

which combusts virgin liquid or gaseous

fuel is exempt from this section.

Therefore,

Facility boilers are exempt from this regulation.

The facility cooling towers use chemicals

for water conditioning which contain HACs, however

the quantities.used

will not exceed any action level. Based on information disclosed

by the Applicant,

there are no other sources of HACs at the Facility.

8. REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the Agency has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility.

Therefore,

the source is.currently

in compliance with this requirement.

The Agency will notify the source if any applicable

RACT requirement applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency wil ensure that the source complies

with such requirement

at that time.

Page 13 of 13VERMONT AGENCY

OF NATURAL

RESOURCES De partment

of Environmental

Conservation Air Pollution

Control Division

TECHNICAL ANALYSIS

OF AN AIR CONTAMINANT

SOURCE
#AOP-98-015a DEC PIN# RU95-0193 August 25, 1999 (Revised: October

20, 1999) Prepared By: John Perreault,

P.E,

APPLICANTS: OMYA, Inc.Nermont

Marble Power Division of OMYA, Inc. 61 Main Street Proctor, Vermont

05765 SOURCE: East PlantVerpol PlantCogeneration Plan{ Florence Road, P.O. Box 10 Florence, Vermont

05744 RESPONSIBLE OFFICIAL:

Nea Jordan, OMYA, Inc. CONTACT: Neal Jordan OMYA, Inc.Manager of Environmental

and Regulatory

Affairs TEL: (802) 770-7261 FAX: (802) 459-3428 COUNTY: Rutland AREA DESIGNATION: Attainment

for PM10, SO2, NO2, CO, & Pb; Unclassified

for ozone UTM COORDINATES: 655960 m E, 464116° m N (Verpol Plant)OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a 1.0 INTRODUCTION On July 20, 1999, OMYA, Incorporated

(hereinafter

"OMYA, Inc." and also referred to herein as "Owner/Operator"),

a subsidiary

of Pluess-Staufer

Industries,

Inc., informed the Agency of Natural Resources,

Department

of Environmental

Conservation,

Air Pollution Control Division

("Agency"),

of its intentions

to construct

several modifications to its' Verpol Plant located in Florence,

Vermont.

These modifications

are summarized as follows:(1)(2)(3)(4)(5)(6)(7) Construction

of new steel product silos; The existing bulk bagging

system will be replaced

with new bulk baggers

served by new bulk bagger product silos; A new pneumatic

conveyor

will be installed

to supplement

existing systems

for delivering finished product from silos to the new bulk bagger silos; A new vacuum

system will be installed

for cleanup of spilled dry product; Existing fabric filters serving 50-1b bag packaging

machines

(known as "rotopackers") will be modified

to vent to the ambient

air; The burner for Spray Dryer #2 will be replaced

with a larger burner to allow an increase in production

through Spray Dryer #2; Continuation of the use of East Plant after normal startup of Flash Dryer #3 at the Verpol Plant; Other noteworthy

changes

planned

for the.future,

include: a conversion

of existing Deagglomerators A and B to Surface Treaters

Aand C; a reduction

in allowable

sulfur dioxide ("SO2") emission

rates from the flash dryers at the East Plant, and the elimination of some existing equipment

at the Verpol Plant. 1.1 Background The East Plant and Verpol Plant are involved

in the production

of.finely ground calcium carbonate materials.

Various non-metallic

minera processing

operations

are employed in the production

of the ground calcium carbonate

materials.

The processing

of calcium carbonate materials

at OMYA's

facilities

is classified

as a source of air contaminants under §§5-401 (5) and (12) of the Regulations.

Additionally,

located adjacent

to the Verpol Plant is the Cogeneration

Plant operated

by Vermont

Marble Power Division of OMYA, Inc. (formerly

known as Vermont

Marble Company).

The Cogeneration

Plant consists of two combustion

turbines

utilized for the generation

of electrical

power. Exhaust heat from the combustion

turbines

is used in the production

of dried calcium carbonate materials

at the Verpol Plant. The Cogeneration

Plant is classified

as a source of air contaminants

under §5-401 (3) of the Regulations. The Cogeneration

Plant, East Plant, and Verpol Plant are classified

as one single stationary source of air contaminants

within the definition

of stationary,

source (see §5- 101 of the Regulations),

since the facilities

are under common

control and located on contiguous property

(referred

to herein collectively

as "Facility").

This stationary

source currently operates

within the confines

of an existing Air Pollution

Control Permit to Construct and Operate

#AOP-98-015

issued on November

16, 1998. Proposed modifications to any of the three facilities

are subject to Agency review and approval pursuant to Subchapter

V of the Regulations.

The term modification

is defined withinOMYA, Inc./Vermont

Marble Power Division #AOP-98-015a §5-101 of the Regulations

as any physical

change or change in the method of operation of the stationary

source which would result in an actual emissions

increase.

Some of the projects described

in item 1.0 above consist of physical

changes

or changes

in the method of operation

of the stationary

source that have associated

emissions

increases and therefore

meet the definition

of modification.

Consequently,

those proposed projects are subject to Agency review and approval. 1.2 Project Description OMYA proposes

to: (1)(2)(3)(4)(5)(6)(7)(8)(9) Construct

new steel product silos; Replace the existing bulk bagging

system with new bulk baggers

served by new bulk bagger product silos; Install a new pneumatic

conveyor

to supplement

existing systems

for delivering finished product from storage silos to the new bulk bagger silos; Install a new vacuum

system for cleanup of spilled dry product; Existing fabric filters serving 50-1b bag packaging

machines

(known as "rotopackers") will be modified

to vent to the ambient

air; Replace the existing Spray Dryer #2 burner with a new larger burner to. increase production through Spray Dryer #2; Convert the existing Deagglomerators

A and B to Surface Treaters

A and C; Continue the use of the East Plant after normal startup of Flash Dryer #3 at the Verpol Plant; and Reduce the allowable

SO2 emission

rates from the flash dryers at the East Plant.OMYA, Inc./Vermont

Marble Power Division 1.3 #AOP-98-015a Administrative Milestones The administrative

steps completed

in the processing

of the application

are summarized below: Table 1-1: Administrative

Summary

Date Application

Received: Date Application

Fee Received and Amount: Date Administratively

Complete: Date & Location Receipt of Application

Noticed: Date Techn ca y Comp ere: Date Draft Decision: Date & Location Proposed Decision & Public Comment Period & Public Meeting Noticed: Date of Public Meeting: Deadline for Public Comments: Classification of Source Under §5-401

Classification of Operating Permit: New Source Review Classification: 07/20/99 07/20/99 $11,000.00 07/22/99 07/24/99 The Rutland Herald 08/25/99 09/09/99 Approved 09/i 1i99 The Rutland Herald 10/07/9910/20/99 §5-401 (3) Electrical power generation facilities; §5-401 (5) Mineral product industries, including mining, quarrying and crushing operations;

§5-401(6)(a)

Fossil fuel burning equipment with a rated heat input of 10 MMBTU/hr or greater; §5- 401(12) Operations

involving the handling or transferring

of sand or dust producing materials. Title V Subject Source Major Modification

to an Existing Major Stationary Source Facility SIC Code(s) and Description(s): 1422 (Crushed and Broken Limestone) i i. _Future Allowable Aircontaminant

Emissions(tons/year) "PM/PMI°" I'. SO;•-- "1 NOx

NMHC$

Pb Total HAP$

Notes:

2.0 PM total particulate matter, PM10 particulate matter sized 10 microns or smaller, SO2 sulfur dioxide, NOx nitrogen oxides, CO carbon monoxide, NMHCs non-methane

hydrocarbons,

Pb lead, HAPs hazardous pollutants.All individual HAP emissions < 0.1 tpy. BASIS OF REVIEW As was stated previously,

OMYA, Inc. proposes

to install and operate new equipment and modify existing equipment

at its Facility located in Florence,

Vermont.

The Facility

4OMYA, Inc.Nermont

Marble Power Division #AO P-98-015a is classified

as an existing air contaminant

source, and modification

of the source is subject to Agency review and approval

pursuant

to Title 10 Vermont

Statutes

Annotated ("10 V.S.A.")

§556 and Subchapter

V of the Regulations.

Additionally,

considering

its allowable emissions

(See Table 4-1 below), the Facility is classified

as a "Title VSubject Source" (see §5-1002

of the Regulations)

and is subject to the operating

permit requirements of 10 V.S.A. §556a and Subchapter

X of the Regulations,

as well as the federal operating

permit regulations

in Title 40 Code of Federal Regulations

("40 CFR") Part 70. OMYA, Inc. was granted an Air Pollution

Control Permit to Operate

("Permit to Operate") in conjunction

with a previous

construction

permit amendment

for a third flash dryer (issued on November

16, 1998). Pursuant

to 10 V.S.A. §556(e),

the Agency proposes to combine

its review for approval

of the proposed

projects with an operating permit modification. 3.0 FACILITY

DESCRIPTION

AND LOCATION 3.1 Description

of Plant Layout and Surrounding

Area The Facility operated

by OMYA, Inc. is located approximately

65 kilometers

("km") north of the Lye Brook Wilderness

Area, 9.4 km southwest

of Mount Nickwaket

(the nearest designated Vermont

sensitive

area) and 170 km southwest

of the Great Gulf and Dry River Wilderness

areas. The geographical

area surrounding

the Facility property

is depicted

in Figure

of Appendix B of this Technical

Analysis. 3.2 Equipment

and Stack Information 3.2.1 Description

of Equipment Tables 3-1, 3-2, and 3-3 below describe

the specific air contaminant

emission

points at the Verpol Plant, East Plant, and the Cogeneration

Plant, along with their existing or proposed air pollution

control strategies. 3.2.2 Description

of Compliance

Monitoring

Devices No devices have been proposed

to continuously

monitor emissions

produced

from the source. Note, however,

as part of its approval

for the construction

of three flash dryer systems at the Verpol Plant and the issuance

of a Permit to Operate,

the Agency required the installation

and use of continuous

measurement

systems

on the fabric filter exhausts serving the flash dryers and Surface Treater B. These measurement

systems
were designed

to provide OMYA, Inc. with information

concerning

the degradation

of particulate matter control in the collectors

over time, and thus assist the operator

in scheduling preventative

maintenance

repairs to the control system.

Additionally,

the combustion turbines

present at the Cogeneration

Plant are equipped

with devices to monitor the water injection

rates and fuel flow into the turbines

in order to monitor the water to fuel ratio used as a means of reducing

NOx emissions.Table 3-1: Emission

Points and Control

Strategies

at the Verpol Plant

Surface Treater A (formerly Deagglomerator

A) Surface Treater C (formerly Deagglomerator

B) Deagglomerator C Storage Silos and Associated

Conveying Systems Surface Treater B SPray Dryer #1

Spray Dryer #2

19.7 MMBTU/hr Boiler 24 MMBTU/hr Boiler Flash Dryer #1 System

Flash Dryer #2 System

Flash Dryer #3 System fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions

0.01 gr/dscf fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions < 0.0• gr/dscf; broken bag detector ESP; PM emissions _< 1.7 Ibs/hr, 80% reduction in uncontrolled

fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 2.4 Ibs/hr (full direct-fire mode) and < 0.5 Ibs/hr (cogen./limited supplemental

direct-fire mode) multiple cyclones in series with an ESP; PM emissions < 2.3 Ibs/hr,80% reduction in uncontrolled

fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 2.7 Ibs/hr (full direct-fire mode) and < 1.4 Ibs/hr (cogen./limited supplemental direct-fire mode) low sulfur distillate oil fuel (0.3% S by wt.) low sulfur distillate oil fuel (0.3% S by wt.) I•abric filter; PM emissions _< 0.01 gr/dscf; 80% reduction in uncontrolled fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 0.7 Ibs/hr; broken bag detector fabric filter; PM emissions _< 0.01 gddscf; 80% reduction in uncontrolled fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 0.7 Ibs/hr; broken bag detector fabric filter; PM emissions < 0.01 gr/dscf; 80% reduction in uncontrolled fuel burning SO2 emissions due inherent scrubbing effect of drying nprocess SO2 emissions < 0.7 Ibs/hr; broken bag detector
FD #1, #2 and #3 Product Conveyors Proposed Finished Product Silos Proposed Bulk Bagger Stations/Bulk

Bagger Product Silos Proposed New Product Transfer System Proposed House Vacuum System Rotopackers

Use existing fabric filter collectors located on product silos; PM emissions < 0.01 gr/dscf fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions < 0.01 gr/dscf

fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions < 0.01 gr/dscf fabric filter; PM emissions

0.01 gr/dscf

6Table 3-2: Emission

Points and Control

Strategies

at the East Plant

Raymond Mill fabric filter; PM emiss=ons < 0.02 gr/dscf Flash Dryer #1 fabric filter; PM emissions < 0.02 gr/dscf; 80% reduction in uncontrolled fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 1.0 Ibs/hr Flash Dryer #1 Recycle fabric filter; PM emissions _< 0.02 gddscf Flash Dryer #2 fabric filter; PM emissions < 0.02 gr/dscf; 80% reduction in uncontrolled fuel burning SO2 emissions due inherent scrubbing effect of drying process SO2 emissions < 1.0 Ibs/hr Silos #1-#4 fabric filter (each silo); PM emissions < 0.02 gr/dscf Bins A and B fabric filter (each bin vent); PM emissions _< 0.02 gr/dscf Bins C and D fabric filter (each bin vent); PM emissions _< 0.01 gr/dscf
Bin C & D Receiver fabric filter; PM emissions < 0.01 gr/dscf
Manual Packaging Dust Relief fabric filter; PM emissions < 0.02 gr/dscf Automatic Packaging Dust Relief fabric filter; PM emissions < 0.02 gr/dscf fabric filter; PM emissions < 0.02 gr/dscf 40 Mesh Unloading 10.5 MMBTU/hr Boiler low sulfur distillate oil fuel (0.5% S by wt.) Table 3-3: Emission

Points and Control

Strategies

at Vermont

Marble Power Division

56 MMBTU/hr Combustion

Turbines #1 & #2 Combustion Turbines Starting Engines #1 & #2 (136 bliP each) Emergency Diesel-Fired

Engine Generator (145 bliP) natural gas or distillate oil fuel (0.3% S); water injection
low sulfur diesel fuel (0.3% S,by wt.); operation restricted to less than 100 hours per year each low sulfur diesel fuel (0.3% S by wt.); operation restricted to less than 100 hours per year

4.0 QUANTIFICATION

OF POLLUTANTS Emissions must be calculated

for the Facility in order to establish

the regulatory

review process necessary

for the construction

and operating

permit portions

of the application and to determine

applicability

with various air pollution

control requirements.

These

7OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a determinations are normally

based upon allowable

emissions.

Allowable

emission

is defined as the emission

rate calculated

using the maximum

rated capacity

of the source and, if applicable,

either: (a) the applicable

emission

standard

contained

in the Regulations, if any, or (b) the emission

rate or design, operational

or equipment

standard specified in any order or agreement

issued under the Regulations

that is.state and federally enforceable.

In addition,

{}5-101 of the Regulations

defines a "stationary source" as any structures,

equipment,

installations,

or operations,

or combination thereof, which emit or may emit any air contaminant,

which is located on one or more contiguous or adjacent

properties

and which is .owned or operated

under common control. Based upon this definition,

all of the equipment,

operations,

and structures

at Facility are grouped

together

as one stationary

air contaminant

source. Under the Agency's

construction

permit program

(see Subchapter

V of the Regulations), a source is classified

as a major stationary

source if allowable

emissions

of any air contaminant equal or exceed fifty (50) tons per year ("tpy"), except the air contaminant lead which is five (5) tpy. Additionally,

any modification

to an existing stationary

source which results in an emissions

increase

equal to or greater than the "significant"

levels identified in {}5-101 of the Regulations,

is classified

as a major modification

and subject to the same review requirements

as a new major source. Under the Agency's

operating

permit program,

a source is classified

as a "Title V Subject Source" and subject to federal review of the Permit to Operate

if the Facility satisfies any one of the following

criteria: The source has allowable

emissions

of oxides of nitrogen

("NOx"), sulfur dioxide ("SO2"), carbon monoxide

("CO"), particulate

matter ("PM/PM10")

or any other air contaminant, except volatile organic compounds

("VOCs"),

of 100 tpy or greater; 2. The source has allowable

emissions

of VOCs of fifty (50) tpy or greater; The source is subject to a federal emission

standard

pursuant

to {}111 of the Clean AirAct ("CAA") and promulgated

in 40 CFR Part 60 (Standards

of Performance for New Stationary

Sources); The source is subject to a federal.emission

standard

pursuant

to {}112 .of the CAA and promulgated

in z•0 CFR Part 61or 63 (National

Emission

Standards

for Hazardous Air Pollutants);

or The source has allowable

emissions

of any one hazardous

air pollutant

("HAP") regulated by the U.S. EPA often (10) tpy or greater, or allowable

emissions

of a combination of HAPs regulated

by the U.S. EPA of twenty-five

(25) tpy or greater. The HAPs regulated

by the U.S. EPA are identified

in {}112 of the CAA. Note: Non-major

stationary

sources

subject to a requirement

in §111 or §112 of the CAA are currently

not subject to the Title V operating

permit program,

since the U.S. EPA has deferred the requirement

for a Title V operating

permit for non-major

sources pursuant

to 40 CFR Part 70 #70.3(b)(1)

and the fact that the U.S. EPA has not completed rulemaking establishing

how the program

should be structured

for non-major

sources.OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a Based upon its allowable

emissions

(see Table 4-1 below), the Facility is currently classified as a "major stationary

source" under the construction

permit program,

and a "Title V subject source" under the operating

permit program

requirements.

Upon completion of the proposed

modifications,

the Facility wil retain these classifications. 4.1 Designation

of the Existing

Stationary

Source §5-101 of the Regulations

defines a major stationary

source as a source with allowable emissions of any air contaminant

equal to or greater than 50 tpy.(except

for lead, which is 5 tpy). Allowable

emissions

are determined

using applicable

emission

standards

in the Regulations

permit conditions,

or published

emission

estimates.

OMYA, Inc.,is currently operating

under the restrictions

of Air Pollution

Control Permit to Constr•ct

and Operate #AOP-98-015

issued on November

16, 1998. Existing allowable

emissions have been determined

using the emission

limits stated in this Permit. In some cases for fuel burning equipment,

the permit limit was expressed

in terms of a fuel usage limit. This fuel usage limit was converted

to an allowable

emissions

value through the application of emission

factors published

by the United .States Environmental

Protection Agency ("U.S. EPA") in AP-42 Compilation

of Air Pollutant

Emission

Factors,

Volume I: Stationary Point and Area Sources

(5th Edition). Table 4-1 below summarizes

the existing allowable

emissions

for the East Plant, Verpol Plant, and the Cogeneration

Plant. A breakdown

of the estimated

allowable

emissions on an equipment

specific basis is contained

in Table 1: Existing Allowable

Emission Estimates located in Appendix

A of this Technical

Analys•s. Table 4-1 Summary

of Existing

Allowable

Emissions*

East PlantVerpol Plant Co•leneration Plant Total

22

21

6

2 61/60 28

39

10 26 143

104

93 109 149 192

<1

<0.01

<1 <1 <0.01

<1 11 <0.01

<1 104 13

<0.01

<1

4.2 Based on allowable emissions contained in Air Pollution Control Permit #AOP-98-015a.

Assumes the Cogeneration Plant is operating at Full Load and supplying heat for Spray Dryers #1 & #2 (limited supplemental

firing of spray dryers). As summarized

in Table 4-1 above, total allowable

emissions

for the OMYA Plants (East and Verpol) and Cogeneration

Plant result in the classification

of this stationary

source as major for particulate

matter ("PM/PMIo"),

sulfur dioxide ("SO2"), oxides of nitrogen ("NOx"), and carbon monoxide

("CO"). Designation of the Proposed

Modification The designation

of an existing stationary

source determines

the appropriate

levels for comparison when attempting

to classify the size of the modification

for new source review purposes.

As an existing major source, any emissions

increase

resulting

from
9OMYA, Inc.Nermont

Marble Power Division #AOP-98-015a modifications must be compared

to the Significant

Levels described

in §5-101 of the Regulations in order to determine

whether

or not the proposed

modifications

are subjected to the new source review requirements

of §5-502 of the Regulations

(Major Source and Major Modifications).

If a proposed

modification

or aggregation

of minor modifications at the source equal or exceed the "significant"

levels, then the modification is classified

as major and subject to the requirements

of §5-502 of the Regulations. Pursuant to §5-502(1),

two forms of increases

must be compared

to the "significant" levels. First, the allowable

emissions

attributable

to the proposed

modification.

Second, the emission

increases

attributable

to the proposed

modification

in addition to the increase in emissions

from prior minor modifications

at the source since July 1, 1979. Prior modifications

at the source which have been reviewed

under §5-502 are not aggregated for the purposes

of determining

the applicability

of major modification.

This determination is performed

on a pollutant-by-pollutant basis. 4:2.1 New Allowable

Emissions The allowable

emissions

increase

associated

with the proposed

project is summarized in Table 4-2 below. The increase

in emissions

accounts

for the following

equipment additions or changes

to existing equipment:

(1) new bulk baggers

served by new bulk bagger product silos; (2) a new pneumatic

conveyor;

(3) a new vacuum

system for cleanup of spilled dry product;

(4) ambient

exhausting

of the existing "rotopackers";

and (5) a increase

in production

through Spray Dryer #2. No emissions

were associated

with the new steel storage silos, since the silos will be served by existing conveying equipment, and emissions

from this equipment

have already been included.

Table 2: New Allowable

Emissions/Aggregated Emissions

Increase,

found in Appendix

A of this Technical Analysis,

gives a breakdown

of the derivation

of these emission

estimates. Table 4-2: New Allowable

Emissions

& Comparison

to Significant

Levels

Significant Levels

25/15

40

40

50

40

0.6

N/A

4.2.2 Based on the projected

allowable

emissions

summarized

in Table 4-2 above, the proposed modification

is classified

as a major modification

and subject to the requirements in §5-502 of the Regulations. Aggregated Emissions

Increase

Addition

of prior minor modifications

with proposed modification, Although the project has already been established

to be subject to §5-502 of the Regulations, the aggregated

emissions

increase

must still be performed

in order to establish if any other pollutants

will be significantly

increased

as a consequence

of prior minor modifications.

§5-502(1)(b)

of the Regulations

requires

minor modifications

be aggregated with prior minor modifications

for the determining

the applicability

of major 10OMYA, Inc./Vermont

Marble Power Division #AO P-98-015a modification review requirements.

The purpose

of this calculation

is to prevent the circumvention of major modification

review through the continued

processing

of minor modifications. A brief discussion

of the permitting

activity associated

with the three facilities follows: (1) OMYA was granted approval

by the Agency to modify and operate the Verpol Plant on March 7, 1986. This Air Pollution

Control Permit approved

the installation and operation

of Surface Treater B, an associated

product storage silo and bagging

equipment,

and an increase

in production

through the existing spray dryer (Spray Dryer #1 formerly

known as Spray Dryer A).. (2) An amendment

was issued on January

14, 19871 to restrict the production

rates through four processes

(i.e., Surface Treater B, Spray Dryer #1, Deagglomerator A, and the Product Bagging

System)

based upon the results of compliance emission testing. (3) On March 8, 1988, OMYA's

Air Pollution

Control Permit was again amended

to approve the modification

of Ball Mill A, the addition

of a new pneumatic

product conveying system, and the reactivation

of the existing Cone Crusher,

Roller Mil Feed Silo, and Roller Mills A and B. (4) In November

1989, OMYA proposed

the installation

of a second spray dryer (Spray Dryer #2 formerly

known as Spray Dryer B), a deagglomerator (Deagglomerator C), and new pneumatic

product conveying

equipment.

This proposed modification

coincided

with the proposal

by Vermont

Marble Power Division of OMYA, Inc. for the construction

of a cogeneration

project on OMYA's property in Florence.

The addition

of OMYA's

new processing

equipment

and the cogeneration

project were reviewed

as a major modification

for PM/PM10, SO2, NOx, and CO. The Agency issued an Air Pollution

Control Permit (#AP-89- 049) on July 27, 1990, approving

the projects.

At the same time as the Agency
was taking action on the major modification,

the Agency combined

the conditions for the East Plant, Verpol Plant, and Cogeneration

Plant together

under one stationary source air pollution

control permit. OMYA, Inc. had purchased

the adjacent White Pigment

Plant and renamed

the facility, East Plant, in 1988. (5) An administrative

amendment

of Permit #AP-89-049

was issued on July 18, 1991 to incorporate

minor revisions

to the permit conditions. (6) The Permit was again amended

on July 12, 1993, to incorporate

minor modifications at the East Plant and to performed

administrative

revisions

of various conditions,

of the Permit. The minor modifications

at the East Plant included: adding a dust collector

onto Silo #1, extending

the pneumatic conveying system feeding Silos #3 and #4 to also serve Silos #1 and #2; and provide the ability to convey product from the Roller Mill to either Bins A through D or the 40 Mesh Feed Silo. Previously,

the Agency incorrectly

calculated

an emissions increase

resulting

from these minor modifications.

However,

the modifications involved

only changes

in the routing of the existing pneumatic conveyors. No new pneumatic

conveying

capacity

was installed

with these minor modifications. Therefore,

emission

rates from the East Plant did not increase

as 11OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a

a result of these minor modifications. (7) On August 24, 1994 and February

23, 1996, the Agency received

an application requesting an increase

in the permitted

level of distillate

fuel oil usage at the East Plant. The fuel consumption

limit was increased

from 445,000

gallons annually to 600,000

gallons, and reviewed

as a m•nor modification.

A permit amendment was issued on March 29, 1996, approving

the increase

in the permitted

fuel consumption limit. (8) On September

13, 1996, the Agency approved,

as a minor modification,

the installation and operation

of two flash dryers and associated

product conveying equipment at the Verpol Plant. (9) On December

2, 1997, the Agency approved,

as a minor modification,

the installation and operation

of a replacement

boiler at the Verpol Plant. The Agency's approval

also allowed the transference

of approved

fuel use (480,000 gallons per year) from the flash dryers to the boilers at the Verpol Plant, and increased the permitted

emission

limit for Spray Dryer #1 from 1.32 pounds per hour ("lbs/hr")

to 1.7 Ibs/hr. (10) The Agency granted approval

for the installation.of

a third flash dryer and associated product conveying

system at the Verpol Plant on November

16, 1998. As stated in item (4) above, all modifications

permitted

prior to 1991 have been reviewed under §5•502 for PM/PM10,

SO2, NOx, and CO. Therefore,

with the exception

of volatile organic compounds

("VOCs")

[classified

as non-methane

hydrocarbons

("NMHCs")

for fuel burning equipment]

and lead, only emission

increases

since 1991 must be aggregated with the proposed

modification

for determining

the applicability

of §5-502 of the Regulations.

These modifications

include: (a) The minor modification

of East Plant in 1996 to increase

the permitted

fuel consumption limitation; (b) The minor modification

of the Verpol Plant in 1996 to allow the installation

and operation to two (2) flash dryers and associated

product conveying

systems; (c) The minor modification

of the Verpol Plant in 1997 to allow the installation

and operation of a repla.cement

boiler and transference

of approved

fuel use to the boilers, and increased

PM/PM10

emission

rate for Spray Dryer #1;and (d) The minor modification

of the Verpol Plant in 1998 to allow the installation

and operation of a third flash dryer and associated

product conveying

system. It should be noted that site-wide

allowable

emissions

of lead and VOCs, including

NMHC emissions from fuel burning equipment,

are less than the "significant"

levels for these pollutants. Additionally,

HAPs do not have an applicable

"significant"

level. Consequently, it is unnecessary

to document

the aggregated

emissions

increase

of lead, VOCs, and HAPs at the stationary

source, since it is impossible

for prior modifications

to exceed the "significant"

level for lead and VOCs at the Facility or it is irrelevant. 12OMYA, Inc.Nermont

Marble Power Division #AOP-98-015a

Table 4-3 below summarizes

the aggregated

emissions

increase

since 1991. Table 2: New Allowable

Emissions/Aggregated Emissions

Increase,

found in Appendix

A of this Technical Analysis,

gives a breakdown

of the derivation

of these emission

estimates. Table 4-3:

Proposed

Modification Prior Minor Modifications Aggregated Modifications Significant LevelsAggregated Emissions

Increase

& Comparison

to Significant

Levels

,•,•:,,,,:,: ,•:! •:,,,,::, .,,, •,,• :3.6 27,5 6.1

14.3 16.6 18.7

25.0

6.3 44.1 24.8

39.3

9.9 25/15 40

40

50

4.3 As summarized

Table 4-3 above, the proposed

modification,

in combination

with prior minor modifications,

wil generate

an emissions

increase

above the "significant"

level for PM and PM•0. Therefore,

the proposed

modification

retains its classification

as a major modification to a major stationary

source for PM/PM•0,

but does not involve a "significant" increase

for any other air contaminant. Designation of the Future Stationary

Source The designation

of the stationary

source in the future is determined

by the allowable emissions that it will be limited to in the future. The future allowable

emissions

are quantified based on proposed

equipment

specifications,

applicable

emission

standards in the Regulations,

prop.osed

operating

conditions,

or published

emission

estimates. Future allowable

emissions

include the emissions

associated

with the proposed modification. Table 4-4 below summarizes

the future allowable

emissions.

Table 3: Future Allowable

Emissions

Estimates,

found in Appendix

A of this Technical

Analysis, provides a breakdown

of these emissions

on an equipment

specific basis. Table 4-4: Summary

of Future Allowable

Emissions

Verpol Plant East Plant

8O22 Co•leneration Plant

26 Total 129

143178

44104
154

112

105

1112

<0.1<0.1
<0.1<0.1

<1<1<1 As summarized

in Table 4-4 above, the Facility will retain its classification

as a major
13OMYA, Inc./Vermont

Marble Power Division stationary source of PM/PMIo,

SO2, NOx, and CO.

#AOP-98-015a

4.5

4.6 Enforceable

Operating

Restrictions In addition to the control strategies

identified

in Tables 3-1 through 3-3 above, OMYA, Inc. and Vermont

Marble Power Division of OMYA, Inc. have proposed

operational restrictions for their facilities.

These are summarized

as follows: (1) Whenever

the combustion

turbines

are in use, distillate

oil firing in Spray Dryers #1 and #2 will not exceed 62 and 169 gallons per hour, respectively; (2) Annual distillate

fuel oil usageat

the Verpol Plant will not exceed 11,235,000 gallons (based upon worst case fuel use scenario)

and in addition

annual limitations for the combustion

turbines,

dryers, boilers, and diesel engines at 6,815,280; 5,500,000;

680,000;

and 18,516 gallons, respectively; (3) Sulfur content of distillate

fuel oil used at Verpol Plant will not exceed 0.3 percent by weight ("% by wt."); (4) Annual distillate

fuel oil usage at the East Plant will not exceed 600,000

gallons; and(5) Sulfur content of distillate

fuel oil used at East Plant will not exceed 0.5 % by wt. Identification of Insignificant

and Exempt

Activities Activities which qualify as an "insignificant

activity" pursuant

to {}5-1002(h)

of the Regulations need not be considered

when determining

the applicability

of Subchapter

X of the Regulations

and must only be listed as such within the operating

permit application. Additionally,

guidance

provided

by the U.S. EPA (entitled

"White Paper for Streamlined Development

of Part 70 Permit Applications")

lists activities

which are considered as "trivial" sources of air contaminants,

and may be presumptively

omitted from operating

permit applications. Although not required

for determining

applicability

with Subchapter

X, quantifiable emissions from "insignificant

activities"

must be included

for the purposes

of establishing whether or not a source is subject to other air pollution

control requirements,

including, but not limited to: reasonably

available

control technology,

major source status, and Title V operating

permit applicability. OMYA, Inc. has identified

the below listed equipment/activities

as insignificant

activities pursuant to {}5-1002(h)

of the Regulations: (1)(2)(3) 0.35 MMBTU/hr

distillate

oil (formerly

waste oil) out-building

space heater at the Verpol Plant; Diesel-fired engine generator

set which operates

less than 100 hours per year at the Cogeneration

Plant; and Two start-up diesel-fired

engines which each operate less than 100 hours per 14OMYA, Inc.Nermont

Marble Power Division #AOP-98•015a year at the Cogeneration

Plant. In addition to the above insignificant

activities,

emissions

of VOCs are considered negligible from the storage and transfer of fuel oil into OMYA's

two storage tanks (270,000 gallon tank and 500,000

gallon tank). With the exception

the diesel generator

sets which have been previously

quantified

for the purposes

of new source review, emissions

have not been quantified

from the above insignificant activities

because

they are considered

negligible

or not quantifiable.

The exclusion of emissions

produced

by the insignificant

and trivial activities

does not alter the applicability

status of the Facility under Subchapter

X of the Regulations. 5.0 MOST STRINGENT

EMISSION

RATE §5-502(3) of Regulations

requires

that applicable

new major sources and major modifications achieve the Most Stringent

Emission

Rate ("MSER")

with respect to those air contaminants

for which it would have a "significant"

increase

in actual emissions. MSER must be achieved

for each proposed

physical

or operational

change which contributes to the increased

emissions

of the air contaminant.

As calculated

in item 4.2 above, OMYA, Inc. must achieve MSER for PM/PM10. MSER is defined as: A rate of emissions

which the Secretary,

on a case-by-case

basis, determines is achievable

for a source based on the lowest emission

rate achieved in practice by such category of source, unless the source demonstrates it cannot achieve such a rate due to economic

impacts and costs. Costs of achievement

of MSER will be accorded

less weight for sources or modifications

locating in non-attainment

areas than for sources or modifications

locating in attainment

areas for the applicable

air contaminant. In no event shall application

of MSER result in emissions

of any contaminants

in excess of any federal emission

standard or any emission standard contained

in these regulations.

If the Secretary determines that imposition

of an emission

standard is infeasible,

a design, equipment,

work practice or operational

standard,

or combination thereof, may be prescribed

instead as constituting

MSER. MSER is established

following

the procedures

identified

in the Agency's

"Air Pollution Control Permitting

Handbook,"

NESCAUM's

"BACT Guideline,"

and the U.S. EPA's "New Source Review Workshop

Manual."

Essentially,

the process of determining

MSER begins by listing all available

options for reducing

emissions

first and then ranking the alternatives in order of effectiveness

from topto bottom (top being the most effective). MSER requires

the application

of the top option unless it can be demonstrated

based upon costs (economic,

energy, and environment)

or technical

constraints

that such an option is not achievable

for the proposed

project.

If the Agency concurs with the applicant that an option is not achievable,

then the next most effective

option is selected as MSER. Again, the same arguments

may be presented.

If found unacceptable,

the next most stringent

option is considered.

Depending

on the circumstances,

this process may take several iterations

before MSER is established.

15OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a As stated previously,

MSER applies to each physical

change or change in the method of operation of the source which caused or contributed

to the significant

increase.

MSER will be applied to the following

equipment

at the Verpol Plant: (1)(2)(3)(4)(5)(6)(7)(8) Spray Dryer #2; Three flash dryers and associated

product conveying

systems; 24 MMBTU/hr

Boiler; New steel storage silos; Bulk bagging

stations/silos; House vacuum

system; New product transfer conveyor;

and Rotopackers. Except for the spray dryers and boiler at the Verpol Plant, the Agency has previously established MSER as the application

of a fabric filter achieving

an emission concentration of 0.01 grains per dry standard

cubic foot ("grldscf")

of undiluted

exhaust air from equipment

processing

dry calcium carbonate

product.

It is the Agency's

opinion that such control equipment

and emission

concentration

still achieves

MSER for PM/PM•0 from non-metallic

mineral processing

operations.

The proposed

Spray Dryer #2 emission

limit is expressed

in Ibs/short

ton of material

processed

and •s equivalent

to 0.01 gr/dscf, but will be achieve via the existing multiple cyclones

in series with an electrostatic precipitator

("ESP").

MSER for the boiler is the use of a low sulfur distillate oil and proper operation

and maintenance

of the device. The application

of additional PM/PM10 control on the boiler cannot be justified,

and has not been required

for distillate oil-fired boilers of this size. MSER for mineral processing

equipment:

0.01 gr/dscf of undiluted

exhaust MSER for boiler:

0.35 pounds per million British Thermal

Units ("Ibs/MMBTU")

of heat input 6.0 APPLICABLE

REQUIREMENTS 6.1 Citation

and Description

of all Applicable

Requirements {}5-1006(e)(4) of the Regulations

requires

the Owner/Operator

of a stationary

air contaminant source to submit a complete

application

including,

but not limited to a demonstration of compliance

with all applicable

air pollution

control requirements. Additionally, pursuant

to 10 V.S.A. {}556 and Subchapter

V of the Regulations,

a source must demonstrate

compliance

with all applicable

requirements

prior to receiving approval for the construction

or modification

of a source. Applicable

requirements include both state and federal regulations,

and the conditions

of any permit. Note that compliance relative to {}5-261 and {}5-1010

of the Regulations

will be discussed separately under items 7.0 and 8.0 below. The compliance

analyses

and determinations

in this technical

analysis

rely on data and representations provided

by the Owner/Operator.

Any statements

and conclusions regarding the compliance

status contained

herein are not binding against the state of Vermont in any future legal or administrative

proceedings. Vermont Air Pollution

Control

Regulations16OMYA, Inc./Vermont

Marble Power Division #AO P-98-015a §5-211(1) Prohibition

of Visible Air Contaminants

Installations

constructed subsequent to April 30, 1970. This standard

applies to any equipment

installed subsequent to April 30, 1970, and specifies

that visible emissions

may not exceed twenty (20) percent ("%") opacity for a period or periods aggregating

to six (6) minutes

or more in any hour, and at no time may they exceed sixty (60) % opacity.

Compliance with this standard

is based upon the procedures

contained

in proposed

Reference Method F-1 (51 Federal Register,

page 31076, August 29, 1986). OMYA,,.Inc. has stated that it complies

with this standard. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. §5-221(1)(a) Prohibition

of Potentially

Polluting

Materials

in Fuel. This section prohibits the use of any fuel, in fuel burning equipment,

with a sulfur content more than 2.0% by weight. This prohibition

applies to all fuel burning equipment

at the Facility. Compliance with this standard

is based on fuel analyses

following

the procedures prescribed by the American

Society for Testing and Materials

("ASTM"). OMYA, Inc. has stated that it complies

with this standard

based upon their use of distillate oil having a maximum

sulfur content of 0.3 % by wt. at the Verpol Plant and 0.5 % by wt, at the East Plant, and their contract(s)

with fuel suppliers. The continued

use of these methods

are sufficient

to ensure compliance

with this limitation in the future. §5-231 (1) Prohibition

of PM; Industrial

Process

Emissions.

This section limits the discharge of PM from industrial

processes.

An emission

limit is derived based upon the limitations established

in Table 1 of the Regulations,

or depending

upon the circumstances, a concentration

limit of 0.06 grains per dry standard

cubic foot ("gr/dscf") of undiluted

exhaust gas. Table 1 of the Regulations

specifies

a maximum

PM discharge rate based upon the maximum

processing

rate in units of pounds per hour ("lbs/hr'!) for any given piece of process

equipment.

Where the processing

rate is not considered an appropriate

measure

of pollution

potential,

such as wood processing equipment, Table 1 is substituted

by the concentration

standard.

Compliance

with this standard is based upon the use of Reference

Method 5 (40 CFR Part 60, Appendix

A). OMYA, Inc. has stated that it complies

with this standard. The Agency will assess compliance

with this section in the future as follows:

(1) OMYA, Inc. will be required

to properly

operate and maintain

its dust collection

systems including fabric filter collectors

and electrostatic

precipitators

("ESP");

(2) visual observations of each exhaust will be conducted

during Agency inspections

of the Facility; and, (3) if visible emissions

are determined

to be in excess of the limits specified in §5-211 of the Regulations

or the conditions

of OMYA's

permit, the Agency may require the performance

of a stack test to verify compliance

with the above referenced PM standard

or that other corrective

measures

be taken. Additionally,

the Agency has required

the use of continuous

measurement

systems

on the flash dryer
17OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a systems and Surface Treater B to assist OMYA's

operators

in monitoring

the dust emitted from these systems. §5-231(3)(a)(i) Prohibition

of PM; Combustion

Contaminants.

This standard applies to each fuel burning device with a heat input rating of 10 MMBTU/hr

or less, and specifies that PM emissions

may not exceed 0.5 Ibs/hr/MMBTU

of heat input. The emission standard

in this regulation

applies to installations

in which fuel is burned for the primary purpose

of producing

steam, hot water, hot air or other liquids, gases, or solids, and in the course of doing so, the products-of

combustion

do not come into direct contact with the process material.

Therefore,

the above standard

does not apply to dryers. Compliance

with this standard

is based upon the procedure

s contained

in Reference Method 5 (40 CFR Part 60, Appendix

A). OMYA, Inc. has stated that it complies

with this requirement. The Agency will assess compliance

with this standard

in the future as follows:

(1) OMYA, Inc. will be required

to properly

operate and maintain

all fuel burning equipment Used on-site; (2) visual observations

of the exhausts

will be conducted

during any Agency inspection

of the Facility; and, (3) if visible emissions

are determined

to be in excess of the limits specified

in §5-211 of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standard or that other corrective

measures

be taken. §5-231 (3)(a)(ii)

Prohibition

of PM; Combustion-Contaminants. This standard applies to each fuel burning device with a rated heat input greater than 10 MMBTU/hr but equal to or less than 250 MMBTU/hr.

The actual value of the standard

is based upon the heat input of the unit and calculated

using a formula.

The emission

standard

in this regulation

applies to installations

in which fuel is burned for the primary purpose

of producing steam, hot water, hot air or other liquids, gases, or solids, and in the course of doing so, the products

of combustion

do not come into direct contact with the process material. Therefore,

the above standard

does not apply to dryers. Compliance

with the standards identified

above is determined

usingthe

procedures

contained

in Reference Method 5 (40 CFR Part 60, App. A). OMYA, Inc. has stated that it complies

with this requirement. The Agency will assess compliance

with this standard

in the future as follows:

(1) OMYA, Inc, will be required

to properly

operate and maintain

its fuel burning equipment; (2) visual observations

of each exhaust will be conducted

during anyAgency inspections of the Facility; and, (3) if visible emissions

are determined

to be in excess of the limits specified

in §5-211 of the Regulations,

the Agency may require the performance of a stack test to verify compliance

with the above referenced

PM standard or that other Corrective

measures

be taken. §5-231(4} Prohibition

of PM; Fugitive

PM. This section specifies

that each process operation must be equipped

with a fugitive PM control system.

Additionally,

this section requires the use of reasonable

precautions

to prevent the discharge

of fugitive PM from any handling,

storage,

or transportation

of materials,

or the construction

of buildings,

or use of roads. This section applies to the Facility, including:

the handling,

processing, 18OMYA, Inc./Vermont

Marble Power Division #AO P-98-015a storage, disposal

and transportation

of marble ore and material

collected

by the fabric filter collectors

and ESPs. OMYA, Inc. has stated that it complies

with this requirement. The Agency will assess compliance

with this standard

in the future as follows:

(1) OMYA, Inc. will be required

to properly

operate and maintain

its dust collection

systems including fabric filter collectors

and ESPs; (2) OMYA, Inc. will be required

to comply with the fugitive PM control measures

specified

within its permit; (3) visual observations

of each exhaust will be conducted

during Agency inspections

of the Facility, and if visible emissions are determined

to be in excess of the limits specified

in §5-211 of the Regulations or the conditions

of OMYA's

permit, the Agency may require the performance of a stack test to verify compliance

with the applicable

PM/PM10

standard or that other corrective

measures

be taken; and, (4) require the implementation

of additional reasonable

precautions

based upon the results of an Agency inspection. Additionally, the Agency has required

the use of continuous

measurement

systems

on the flash dryer systems

and Surface Treater B to assist OMYA's

operators

in monitoring the dust emitted from these systems. §5-241(1) & (2) Prohibition

of Nuisance

and Odor. This requirement

appliesto

the entire Facility and prohibits

the discharge

of air contaminants

that would be a nuisance to the public or be source of ob.lectionable

odors beyond the property-line. OMYA, Inc. has stated that it complies

with this requirement. The Agency will verify comp!iance

with this requirement

in the future during any inspections of the Facility.

Additionally,

the Agency investigates

all complaints

that it receives in order to determine

whether

or not there is a violation

of this requirement. §5-502(3) Most Stringent

Emission

Rate. As part of obtaining

approval

for the installation of.Spray

Dryer #2, Deagglomerator

C with pneumatic

conveying,

and the Cogeneration Plant, the Agency required

OMYA, Inc. to achieve the MSER pursuant

to §5-502(3) of the Regu/ations.

See item 5.0 above for more information

regarding

the applicability of MSER for the proposed

project. OMYA, Inc. has stated that it complies

with this requirement. The Agency will verify compliance

with this standard

in the future during any inspections of the Facility. Subchapter VIII Registration

of Air Contaminant

Source.

This Subchapter

requires the registration

of a stationary

source, with the Agency,

if it produces

five (5) tons per year or greater of actual emissions

during the preceding

calendar

year. The Owner or Operator of a source is required

to submit information

regarding

their operations

and pay a fee based on the quantity of emissions

they produce

and the fuels that they use. Based upon its past actual emissions,

OMYA, Inc. is subject to the registration requirements of Subchapter

VIII of the Regulations.

OMYA, Inc. currently

registers

it's Facility, and proposes

to continue

to comply with this requirement

in the future. 19OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a
The Agency will ensure compliance

with this requirement

in the future during any inspections of the Facility. Air Pollution

Control

Permit #AP-98-015

(Issued November

16, 1998) OMYA, Inc. currently

operates

within the confines

of an Air Pollution

Control Permit to Construct and Operate

issued on November

16, 1999. Although

the conditions

of this permit are currently

applicable

requirements,

the Agency is reviewing

each condition

to determine whether

or not it will be incorporated

into any future permit for this Facility as part of its approval

for the proposed

modifications. Federal Air Pollution

Control

Regulations Clean AirAct,

Title Air Pollution

Prevention

and Control,

Part A Air Quality and Emission Limitations,

§111 Standards

of Performance

for New Stationary Sources. OMYA, Inc. is subject to three applicable

federal new source performance standards established

under §111 of the federal Clean AirAct and promulgated

within Title 40 Code of Federal Regulations

("CFR") Part 60. 40 CFR Part 60 Subpart

Dc The replacement

boiler (24 MMBTU/hr

boiler at Verpol Plant) approved

by the Agency in 1997 is considered

an affected

facility subject to 40 CFR Part 60 Subpart Dc Standards

of Performance

for SmallIndustrial-CommercialInstitutional Steam Generating

Units. Subpart Dc specifies

emission

limitations

for PM/PM10, SO2, and opacity, as well as monitoring,

record keeping,

notification

and reporting requirements.

Applicability

to Subpart

Dc also subjects

OMYA, Inc. to the general notification,

record keeping,

and other requirements

of 40 CFR Part 60 Subpart A.OMYA, Inc. has stated that it complies

with these requirements. The Agency will incorporate

the applicable

requirements

of 40 CFR Part 60 Subpart A and Dc within any permit issued to OMYA, Inc. approving

the proposed

modifications. 40 CFR Part 60 Subpart

GG The design rated heat input of each combustion

turbine at the Cogeneration

Plant exceeds

10.7 gigajoules

per hour. Each turbine is actually rated at 54 gigajoules

per hour. Therefore,

the combustion

turbines

are subject to the federal regulations

contained

in 40 CFR Part 60 Subpart GG Standards

of Performance for Stationary

Gas Turbines.

This new source performance

standard

sets limits for emissions

of NOx and SO2, specifies

maximum

sulfur contents

of fuels, requires continuous monitoring

of fuel consumption

and ratio of water to fuel injected

into the turbine (if NOx emission

are controlled

using water injection),

monitoring

of sulfur and nitrogen contents

in the fuel, and reporting

requirements.

Emissions

of NOx and SO2 may not exceed 176 and 150 parts per million on a volume and dry basis ("ppmvd") corrected to 15 % oxygen ("02") at ISO standard

conditions,

respectively.

The maximum sulfur content in fuel cannot exceed 0.8% by weight. OMYA, Inc. has stated that it complies

with these requirements.

20OMYA, Inc./Vermont

Marble Power Division #AO P-98-015a The Agency will incorporate.the

applicable

requirements

of 40 CFR Part 60 Subpart GG which have not been superceded

by more stringent

state requirements

or which have not already been completed

(i.e., initial performance

testing).

See item 6.2 for more information. 41) CFR Part 61) Subpart

OOO On August 1, 1985, a federal new source performance standard was promulgated

which applied to non-metallic

mineral processing

operations such as those operated

by OMYA, Inc. at its Verpol and East Plants. This federal standard is contained

in 40 CFR Part 60 Subpart OOO and is entitled Standards

of Performance for Non-metallic

Mineral Processing

Plants. This new source performance standard applies to new or modified

affected

facilities

commencing

construction

or modification after August 31, 1983. The federal standard

sets limits on emissions

of PM and visible air contaminants

from non-metallic

processing

plants and requires compliance testing.

Affected

equipment

at the OMYA facilities

include the following: East Plant:

Product Bin C, Product Bin D, and Bin C.& D Receiver; Verpol Plant: Surface Treater B, with product conveying; Deagglomerator C, with product conveying; Finished Product Silos 9 through

16; and Deagglomerator mills associated

with Flash Dryers #1, 2, and #3. Additionally, the following

new equipment

at the Verpol Plant will be subject to the requirements in 40 CFR Part 60 Subpart OOO: New finished product silos; Bulk Bagger Silos; and Rotopackers. OMYA, Inc. has stated that it complies

with these requirements

for its affected equipment. The Agency will incorporate

the applicable

requirements

of 40 CFR Part 60 Subpart OOO which have not been superceded

by a more stringent

state requirements

or which have not already been completed

(i.e., initial performance

testing).

See item 6.2 for more information. Section 112 of the Clean Air Act National

Emission

Standards

for Hazardous

Air Pollutants (NESHAPs) No promulgated

NESHAPs

in 40 CFR Part 61 currently

are applicable

to the Facility. There are currently

no promulgated

NESHAPs

in 40 CFR Part 63 that apply to the Facility. The NESHAPs

in 40 CFR Part 63 identify the "maximum

achievable

control technology" ("MACT")

standards

for major sources of hazardous

air pollutants

("HAPs"). Although there is currently

no MACT standard

that applies to OMYA, Inc., the U.S. EPA has identified

the following

source categories

at the Facility as potentially

regulated

by MACT standard

to be promulgated

on or before November

15, 2000: 21OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a

• Industrial

Boilers, Institutional/Commercial

Boilers,

• Process

Heaters, Stationary Internal Combustion

Engines,

and

• Stationary

Turbines. Althoug'h the above source categories

exist at the Facility, it is not anticipated

that the MACT standards

will apply to OMYA, Inc. due to the fact that total emissions

of HAPs have been estimated

to be less than 1 tpy from the Facility (including

operational restrictions). See item 7.3 for more information. 40 CFR Part 64 Compliance

Assurance

Monitoring.

Pursuant

to requirements concerning enhanced

monitoring

and compliance

certification

under the C/ean AirAct ("CAA"), EPA promulgated

new regulations

and revised regulations

on October

22, 1997. These new requirements

implemented

compliance

assurance

monitoring

("CAM") for major stationary

sources of air pollution

that are required

to obtain operating

permits under Title V of the CAA. Subject to certain exemptions,

the new regulations

require owners or operators

of such sources to conduct monitoring

that satisfies

particular criteria established

in the rule to provide a reasonable

assurance

of compliance

with applicable requirements

under the CAA. Monitoring

is proposed

focus on emissions units that rely on pollution

control device equipment

to achieve compliance

with applicable standards.

The regulations

also provide procedures

for coordinating

these new requirements

with the operating

permits program

regulations. As a result of comments

received

during the rule making process and the lengthy delay in the adoption

of theCAM

rule, U.S. EPA provided

an extended

implementation schedule for this rule. Facilities

which had submitted

a complete

operating

permit application prior to April 20, 1998, were not required

to address

CAM as part of their initial operating

permit application

unless they proposed

to make significant

changes

to the facility subsequent

to this date. OMYA, Inc. was previously

not required

to address CAM because

it had submitted

an administratively

complete

operating

permit application prior to April 20, 1998. However,

with the proposal

of further modifications

to the facility and the reopening

of the operating

permit, OMYA, inc. must• address

the applicability

of these req uirements

for the pollutant-specific

emissions

units affected

by the permit reopen ing.§64.2 in 40 CFR Part 64 specifies

that each pollutant

specific emission

unit at.a facility the meets a three-part

test is subject to the requirements

for CAM. An emission

unit must:(A)(B)(C) be subject to an emission

limitation

or standard, use a control device to achieve compliance,

and have pre-control

emissions

that exceed or are equivalent

to the major source threshold in 40 CFR Part 70 (i.e., 10 tpy individual

HAP, 25 tpy total HAPs, 50 tpy VOCs, or 100 tpy for any other air contaminant). Note that the term "control device" means equipment,

other than inherent

process equipment, that is used to destroy or remove air pollutant(s)

prior to discharge

to the 22OMYA, Inc.Nermont

Marble Power Division #AOP-98-015a atmosphere. The term "control device" does not include passive methods

such as lids or .seals or inherent

process

equipment

provided

for safety or material

recovery. Additionally, the CAM rule provides

some exemptions,

such as an exemption

forany affected facility subject to an NSPS or NESHAP

promulgated

after November

15, 1990. Equipment affected

by the proposed

project and possibly

subject to CAM now rather than at renewal of the operating

permit include: Spray Dryer #2, bulk bagging stations/silos, rotopackers,

new product conveying

system, new finished product silos, and the new vacuum

cleaning

system.

Spray Dryer #2 is equipped

with multiple cyclones in series with an ESP, while the remaining

equipment

is serviced

by fabric filter collectors. The cyclones

and ESP serving Spray Dryer #2 are generally

considered control devices,

but due to the design of the process,

the noted devices are primarily designed for dry product recovery,

and therefore

do not meet the definition

of "control device" as stated in the CAM regulations.

The remaining

process

equipment

each have pre-control potential

emissions

less than 100 tpy. Therefore,

OMYA, Inc. has been determined .to not be subject to CAM for the affeCted

equipment

noted above at this time.Clean Air Act, Title VI Stratospheric

Ozone Protection.

The requirements

of Title VI of the Clean Air Act are implemented

through regulations

and standards

within 40 CFR Part 82 Subparts

A through F. Of these regulations,

OMYA, Inc. is subject to Subpart

F Recycling and Emissions

Reduction.

This requirement

is applicable

to any facility that owns, services,

maintains,

repairs, and disposes

of appliances

containing

ozone depleting substances.

OMYA, Inc. utilizes a refrigeration

unit which employs

R-22 (an HCFC) and regulated

ozone depleting

chemical.

The Agency will incorporate

the applicable requirements

of 40 CFR Part 82 Subpart F into any permit issued to OMYA. 6.2 Equivalency

and Streamlining Particulate Matter Emission

Standards The federal standard

for non-metallic

mineral processing

plants specifies

a limit of 0.05 grams per dry standard

cubic meter [equivalent

to 0.022 grains per dry standard

cubic foot ("gr/dscf")]

for affected

facilities

equipped

with fabric filter collectors.

Due to major modification applicability

in1990,

as well as for the proposed

modifications,

the Agency has specified

an emission

limit of 0.01 gr/dscf for the affected

facilities

noted previously (See item 6.1 above) as part of achieving

the Most Stringent

Emission

Rate ("MSER"). The emission

concentrations

specified

by MSER are more stringent

and therefore overrule the federal emission

standards

in 40 CFR Part 60 Subpart OOO for the affected facilities noted in item 6.1 above.

Additionally,

the same equipment

is subject to a PM/PM10 emission

limit in §5-231(1)(a)

and Table 1 of the Regulations.

The requirements of §5-231(1)(a)

and Table 1 of the Regulations

are also less stringent

than MSER and are also overruled

by the MSER concentration

of 0.01 gr/dscf. Sulfur Dioxide Emission

Standards The federal standard

for SO2 specified

in 40 CFR Part 60 Subpart

GG is overruled

by the sulfur in fuel restrictions

specified

for the Cogeneration

Plant as part of achieving MSER. The combustion

turbines

may not burn distillate

oil with a sulfur content greater than 0.3 % by weight (corresponds

to an emission

concentration

of 58 ppm), which is more stringent

than the federal limit of 0.8 % by wt. and 150 ppmvd corrected

to 15% 02 23OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a at ISO conditions.

Additionally,

the MSER sulfur in fuel restriction

is also more stringent and therefore

overrules

the sulfur in fuel restriction

in §5-221(1)(a)

of the Regulations (2.0% by wt. or less). Nitro.qen Oxides Emission

Standards The federal standard

for NOx specified

in 40 CFR Part 60 Subpart GG is overruled

by the NO× limit specified

for the Cogeneration

Plant as part of achieving

MSER. The combustion turbines

may not emit NOx in excess of 60 ppmvd corrected

to 15% O2 and ISO conditions,

which is more stringent

than the federal limit of 176 ppmvd corrected

to 15% O2 and ISO conditions. 6.3 Citation

and Identification

of Requirements

For Which a Permit Shield Provision Has Been Requested Pursuant to §5-1015(a)(11

of the Regulations,

OMYA, Inc. has requested

to be shielded from several potentially

applicable

requirements.

The Agency's

determinations

are based upon the information

submitted

by the Owner/Operator

in its application.

The resulting permit shield shal be binding only with respect to activities

disclosed

in the Owner/Operator's application. OMYA, Inc. has requested

a permit shield from the requirements

of 40 CFR Part 60 Subpart OOO [Standards

of Performance

for Non-metallic

Mineral Processing

Plants] for various pieces of process equipment

installed

prior to August 31, 1983 (except where noted), and located at the East and Verpol Plants, including: [East Plant(1) 40 Mesh Silo, (2) Raymond

Mill w/product

conveying, (3) Flash Dryer #1 w/product

conveying; (4) Flash Dryer #1 recycle collector, (5) Flash Dryer #2 w/product

conveying, (6) Product Silos 1-4, (7) Product Bins A and B, (8) Manual and Automatic

Packaging, Verpol(1)(2)(3)(4)(5) PlantSpray Dryer #1, Spray Dryer #2 (constructed

in 1990/91,

but not an "affected

facility" per U.S. EPA definition), Surface Treaters

A and C (formerly

Deagglomerators

A and B) with product conveying,Finished Product Silos through 8, and Bulk truck/railcar

Ioadout. OMYA, Inc. has also requested

a permit shield for the Cogeneration

Plant from the regulations promulgated

under Title IV of the 1990 Clean Air Act Amendments

pertaining to acid rain. The U.S. EPA identified

the Cogeneration

Plant as a potential

source to be regulated by the requirements

of Title IV. However,

based upon information

supplied

by the Vermont

Marble Power Division of OMYA, Inc., the U.S. EPA sent a letter (Letter from Brian J. McLean,

Director,

Acid Rain Division,

U.S. EPA to William Gleason

of 24OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a Vermont Marble Power Division of OMYA, Inc. dated September

18, 1996) to OMYA, Inc. notifying

them that the requirements

of Title IV do not apply to the Cogeneration Plant. However,

pursuant

to §5-1015(a)(11)(vii)

of the Regulations,

the Agency may not grant a permit shield from the requirements

of Title IV of the CAA. The Agency will grant a permit shield from 40 CFR Part 60 Subpart OOO for above noted equipment. 6.4 Description

of Alternative

Operating

Scenarios

and Related

Applicable Requirements Not Previously

Identified OMYA, Inc. has not identified

any alternative

operating

scenarios

within its application. 7.0 HAZARDOUS

AIR CONTAMINANTS §5-261 of the Regulations

addresses

the release of hazardous,

air contaminants ("HACs") into the ambient

air. Unless exempted

from {}5-261, the owner/operator

of a source must quantify

its emissions

of HACs regulated

by this rule. Any source whose emission rate of a HAC exceeds

its respective

Action Level ("AL")is

subject to the rule for that HAC, and the owner/operator

must then demonstrate

that the emissions

of the HAC are minimized

to the greateSt

extent practicable

and achieve the Hazardous

Most Stringent Emission

Rate ("HMSER").

An air quality impact evaluation

may be required to further assess the ambient

impacts that may be attributable

to the source.

The evaluation of the-air quality impacts is performed

using the Hazardous

Ambient

Air Standards ("HAAS")

or Stationary

Source Hazardous

Air Impact Standard

("SSHAIS") contained in the Regulations. 7.1 Applicability

of §5-261 Pursuant to {}5-261(1)(b)

of the Regulations,

all fuel burning equipment

burning virgin fossil fuel is exempted

from review pursuant

to this section,

However,

OMYA, Inc. was required to assess it compliance

with §5-261 for its non-metallic

mineral processing operations. Based upon information

supplied

in the application,

OMYA, Inc. has determined that its emissions

of crystalline

silica exceed the AL of 0.010 pounds per e•ght hours ("lbsl8-hrs").

Laboratory

analysis

performed

by OMYA, Inc. has indicated the silica content of its products

is typically

0.16%. Assuming

the silica content of its PM emissions are the same percentage

as the product reporting

to the air pollution

control equipment, OMYA, Inc. has estimated

its actual emissions

of crystalline

silica are 0.07 Ibs/8-hrs. Consequently,

it was determined

that OMYA, Inc. is subject to §5-261 of the Regulations for emissions

of crystalline

silica. 7.2 Hazardous

Most Stringent

Emission

Rate OMYA, Inc. has proposed

that HMSER

for crystalline

silica is the use Electrostatic Precipitators on the spray dryers and fabric filter control on the remaining

non-metallic mineral processing

equipment.

The Agency concurs with OMYA's

determination

of HMSER for crystalline

silica. No further review of emissions

of crystalline

silica will be required by the Agency.

25OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a 7.3 Federal

Hazardous

Air Pollutants Although not subject to {}5-261 of the Regulations,

the federal EPA has listed fossil fuel burning equipment

as a potentially

regulated

source category

for emissions

of hazardous air pollutants

("HAPs")listed

in Section 112(b)of

the federal Clean Air Act. Non-metallic mineral processing

plants have not been identified

as a source category that will be regulated

by the U.S. EPA for emissions

of HAPs. A major HAP source is defined pursuant

to the federal thresholds

of 10 tpy (individual HAP) and 25 tpy (total HAPs). Major sources of HAPs are regulated

within 40 CFR Parts 61 and 63. Although,

OMYA, Inc. has the potential

to emit some of the HAPs listed in Section 112(b) from its fuel burning equipment,

estimates

of the HAP emissions assuming the proposed

fuel limits result in less than 1 tpy of total HAP emissions

(See emission factors published

by U.S. EPA in AP-42 Section 1.3), and therefore,

.OMYA, Inc. is not classified

as a major source of HAPs. 8.0 REASONABLY

AVAILABLE

CONTROL

TECHNOLOGY At this time, the Agency has not established

a Reasonably

Available

Control Technology ("RACT") requirement

applicable

to this Facility.

Therefore,

the source is currently

in compliance with this requirement.

The Agency will notify OMYA, Inc. if any applicable RACT requirement

applies to this Facility in the future. If such RACT should apply to the source in the future, the Agency will ensure that OMYA, Inc. complies

with such req uirement

at that time. 9.0 COMPLIANCE

PLAN 9.1 Description

of the Compliance

Status for Each Applicable

Requirement See Part 6.1 above. 9.2 Compliance

Schedule

For Each Applicable

Requirement

for Which the Source is Not in Compliance Not applicable

to the-East,

Verpol and Cogeneration

Plants. 10.0 AMBIENT

AIR QUALITY

IMPACT

EVALUATION

(Criteria

Pollutants) For modifications,

§5-502(4)(a)

of the Regulations

and Agency procedures

require an evaluation of impacts on air quality for each air contaminant

that is predicted

to increase by 10 tpy or greater (exception:

no evaluation

required

for VOCs).

An air quality impact evaluation is performed

to demonstrate

whether

or not a proposed

project will cause or contribute to violations

of the ambient

air quality standards

("AAQS")

and/or.significantly deteriorate existing air quality. In 1990, as part of its application

for Cogeneration

Plant, OMYA, Inc. demonstrated

compliance

with the AAQS and PSD increments. Comparison of the proposed

future allowable

emissions

and the allowable

emissions modeled in 1990 indicate emissions

of PM10 and NOx (as nitrogen

dioxide) are proposed to increase

by greater than 10 tpy. Consequently,

OMYA, Inc. was required

to perform an air quality impact evaluation

for these two air contaminants. 26OMYA, Inc.Nermont

Marble Power Division #AOP•98-015a

Air quality impact evaluations

rely on the use of mathematical

dispersion

models to simulate the operation

of the source and assess the affects of meteorology,

distance, topography, and time on pollutant

dispersion.

Output generated

by the models is used to determine

resultant

air quality pollutant

concentrations

in the vicinity of the source. Important factors influencing

pollutant

concentrations

include: source operation, meteorological conditions,

distance

to point of impact (commonly

referred to as "receptors"), and nearby terrain and buildings. 10.1 General

Information The basic component

of an air quality impact evaluation

is the dispersion

model. Acceptable dispersion

models for use in regulatory

application

are identified

by the U.S. EPA in Guideline

on Air Quality Models found in Appendix

W to 40 CFR Part 51. The dispersion model simulates

the operation

of the emission

source(s)

and takes into account the affects of meteorology,

distance,

nearby buildings

and terrain, and time on pollutant dispersion.

Results of the dispersion

modeling

estimate

the source impact as. ambient concentrations

at given locations

and periods of time in the vicinity of the source. The estimated

impacts are combined

with existing pollutant

concentrations and/or concentrations

produced

by other nearby sources to determine

the potential

air quality impact once a project is built. Of particular

importance

to the air quality impact evaluation is the dispersion

model selected

and the assumptions

utilized to simulate

the operation of the source and meteorology. Dispersion models vary in complexity

and required

input. Typically,

applicants

will make their first attempt to document

compliance

with air quality standards

by using the most simple techniques,

referred to as screening

models.

These models require a minimum of data input and provide the applicant

will a conservative

assessment

of their potential impact. Conservative

default meteorological

conditions

are used as input in the screening models in order to ensure a worst case analysis.

Screening

models are often used to define the impact area of a source.

The impact area is used to select other nearby sources of the same pollutants

that should be implicitly

included

in the air quality analysis. If an applicant

cannot rely on a screening

analysis

to demonstrate

compliance with air quality standards,

then they may progress

to a more refined dispersion

model. Refined dispersion

models require a greater level of data input and usually present a more realistic assessment

of potential

im pacts.

10.2 Data Inputs Attached Figure 1 in Appendix

B depicts the geographical

area in the vicinity of the Verpol Plant. Figure 2 depicts the location of OMYA's

emission

points and the building layouts of the East Plant, Verpol Plant, and Cogeneration

Plant. Appendix

F of the application includes

several tables which summarize

the various dispersion

model inputs for each emission

point at the Facility. As part of its evaluation,

OMYA, Inc. was required

to determined

the "good engineering practice" ("GEP") stack height for each emission

point. The GEP analysis

relied on plant
27OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a layout and elevation

drawingsto

establish

GEP for each emission

point. Where a stack height is less than GEP, OMYA was required

to consider

the influence

of any nearby buildings or terrain on pollutant

dispersion.

Summarized

in Table F-1 and F-2 of the application are the results of the stack height analysis. Meteorological data input into the refined dispersion

model was obtained

from the National Weather

Service.

Surface data was taken for Burlington,

VT, while upper air data was for Albany, NY. The meteorological

data covered the period 1987 to 1991. 10.3 Site Description

and Receptor

Locations The East Plant, Verpol Plant, and Cogeneration

Plant are located on one contiguous parcel of property

in the town of Pittsford,

Vermont.

The Facility is located approximately 65 kilometers

("km") north of the Lye Brook Wilderness

Area, 9.4 km southwest

of Mount Nickwaket (the nearest designated

Vermont

sensitive

area) and 170 km southwest

of the Great Gulf and Dry River Wilderness

areas. Terrain located to West and Southwest

is predominately

above stack top. The closest complex terrain is approximately

1200 feet in the southwest

direction

from the Verpol Plant (series low rolling hills). Terrain to the East gradually

drops below the Facility elevation for approximately

2 kilometers

(just before the village of Pittsford).

From thereon the terrain rises significantly

above stack top. Terrain to the North mainly consists of rolling hills with some points being consider

complex

terrain. The nearest location above stack top in the northerndirection

is approximately

1.5 kilometers

from the Verpol Plant. As was stated previously,

Figure

in Appendix

B depicts the geographical terrain in the vicinity of the Facility, including

terrain elevations. For its screening

analysis,

OMYA, Inc. utilized a Cartesian

grid system based uPon the Universal Transverse

Mercator

("UTM") coordinate

system.

Receptors

were placed at ground level at a 50 meter spacing between

receptors

up to a.distance

of 1,000 meters from the Facility property

boundary.

Spacing

between

receptors

was increased

to 100 meters to a distance

of 2,000 meters from the property

boundary,

and 250 meters between receptors

to a distance

of 5 kilometers

from the property

boundary.

Receptors were placed 50 meters apart along the property

boundary.

No receptors

were modeled inside the property

boundary,

since the area is not generally

accessible

by the public. For its refined analysis,

OMYA, Inc. modified

the grid system to increase

the number of receptors in the immediate

area of anticipated

highest concentrations

(southeast

of the property boundary).

Additionally,

receptor

spacing in other directions

was set at 100 meters between

receptors

to a distance

of 2 kilometers

from the property

boundary,

and 500 meters to a distance

of 8 kilometers

from the property

boundary.

A discrete receptor was also placed at the closest point in the Lye Brook Wilderness

Area (closest Class area to the Facility). Elevations for the receptors

were imported

from the United States Geological

Survey's Digitized Elevation

Model ("DEM") 10.4 Ambient

Background

Concentrations The town of Pittsford

and surrounding

areas are considered

attainment

for the air 28OMYA, Inc./Vermont

Marble Power Division #AO P-98-015a contaminants, PM10 and nitrogen

dioxide ("NO2").

Consequently,

OMYA, Inc. must demonstrate the proposed

modification

will not cause a violation

of the AAQS for these contaminants. Compliance

with the AAQS is based upon a comparison

of the total estimated concentration

to the AAQS for a particular

pollutant

and averaging

period. The AAQS are contained

in Subchapter

III of the Regulations,

and the PM10 and NO2 AAQS are summarized

in Table 10-1 below. The total estimated

concentration

is the sum of existing air quality concentrations

and the estimated

impact created by the Facility. Existing air quality concentrations

consist of representative

monitored concentrations (commonly

referred to as "background")

and the predicted

impact concentrations from nearby sources.

Impact concentrations

from nearby sources are obtained through dispersion

modeling

of their emissions. Table 10-1: AAQS for PMlo and NO•

PM10 Annual 50 ug/m

50 ug/m NO2 24-hourAnnual 150 ug/m100 ug/m

150 ug/m100 ug/m Notes:a Standard is attained whenthe expected annual arithmetic mean is less than or equal to 50 ug/m •. b Standard is attained when the expected number of exceedance

is less than or equal to 1. c Never to be exceeded. Representative monitored

data is defined as the typical concentration

expected

at the point of predicted

maximum

impact from the source.

Possible

origins of monitoring

data are the Agency's

air monitoring

network,

the network of another agency or private concern, or a source specific network.

In circumstances

where non-source

specific monitoring data will be used to determine

existing concentrations,

the latest three (3) years of data must be employed

for determining

the highest annual ambient concentrations for PM10 and NO•, and the highest four highest 24-hour ambient Concentrations. The Agency currently

operates

and maintains

an ambient

monitoring

site in downtown Rutland, Vermont.

This site is approximately

15 kilometers

from the Facility.

The Agency has allowed the use of this monitoring

data in establishing

background concentrations for OMYA's

application.

Given the area in the vicinity of the Facility is rural, and the degree of human activity near the monitoring

site, its proximity

to the Facility, the Agency believes

the use of this monitoring

site data conservatively

satisfies the criteria noted in the preceding

paragraph.

Summarized

in Table 10-2 are the ambient concentrations

of PM10 and NO2 which are considered

background

for the AAQS evaluation. Table 10-2: Representative

Ambient

Monitored

Concentrations

PMI0 Annual 24 ug/m
29OMYA, Inc.Nermont

Marble Power Division 24-hour NO2 Annual #AOP-98-015a

55 ug/m24 ug/m

10.5 As was stated previously,

existing concentrations

must include the im pact of nearby source(s), and thus may necessitate

the evaluation

of other sources using dispersion modeling. A nearby source must be included

in the air quality impact evaluation

if it produces a significant

concentration

gradient

in the Facility's

significant

impact area. Due to the number of emission

points present at the source, OMYA, Inc. utilized the U.S. EPA dispersion

model, ISCST3,

to assess its significant

impact area. Based upon this dispersion model, OMYA, Inc. predicted

a significant

impact area ("SIA") out to 3 kilometers from the Facility.

A review of the Agency's

database

indicates

no facilities located within 3 kilometers

of the Facility with the potential

to generate

a s•gnificant concentration gradient.

Therefore,

no additional

nearby stationary

sources were directly included in the impact evaluation. Modeling Approach OMYA, Inc. performed

its air quality impact evaluation

in two steps: first, a screening level analysis;

and second, a refined analysis

to complete

the compliance demonstration. The screening

analysis

utilized the U.S. EPA model, ISCST3,

with a standard set of meteorological

conditions.

The resultant

concentrations

were then adjusted to various averaging

periods using adjustment

factors.

Based upon this technique, OMYA, Inc. was. unable to document

compliance

with the AAQS and PSD increments. Consequently,

OMYA, Inc. conducted

a refined impact evaluation. The refined impact analysis

also relied on the use of the U.S. EPA model, ISCST3,

but included the input of five (5) years of meteorological

data for Burlington,

Vermont

and Albany, NY. Results of Air Quality Impact Evaluation Ambient Air Quality Standards The AAQS are summarized

in Table 10-1 above. The results of refined air quality impact evaluation

demonstrating

compliance

with the AAQS are summarized

in Table 10•3 below.

Table 10-3: Results

of the AAQS Demonstration

PMI0 31 ug/m

50 ug/m Annual24-hour 104 ug/m

150 ug/m NO2 Annual 31 ug/m

100 ug/m

30OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a 10.6.2 Prevention

of Significant

Deterioration

Increments The prevention

of significant

deterioration

("PSD") increments

are contained

in Table 2 of the Regulations.

Additionally,

§5,502(5)

of the Regulations

specifies

an increment allocation system for major sources

and major modifications.

New major sources and major modifications

may not consume

more than 25% of the annua and 75% of the short-term PSD increment

values. The results of refined air quality impact evaluation demonstrating compliance

with the PSD increments

are summarized

in Table 10-4 below. Table 10-4: Results

of the PSD Demonstration

Class Area PMI0 Annual

4 ug/m

4 ug/m

1.0 ug/m

<011 ug/m 24-hour NO2 Annual

PMIo

NO2

8 ug/m2.5 ug/m

8 ug/m

6.0 ug/m2.5 ug/m

<0.1 ug/m 2.5 ug/m <0.1 ug/m Class II Areas

3.4 ug/m

2.7 ug/m 15.0 18.7 ug/m 11.5 15.7 ug/m (15.8 ug/m 3) (15.5 ug/m •) 25 ug/m

7 ug/m Annual 17 ug/m

13.6 ug/m 24-hour 30 ug/m

20- 24.9 ug/m (worstcase) (21 ug/m •) Annual 25 ug/m

25 ug/m

10.7

11.0 Notes: (1)Total PSD increment values are stated in Table 2 of the Regulations.

Pursuant to §5-502(5) of the Regulations, a new major source or major modification

may not consume more than 25)/o and 75 % of the remaining annual and 24- hour PSD increment values, respectively,

for each significantly

increasing air contaminant. Special Modeling

Considerations §5-502(4)(d) of the.Regulations

specifies

that the increase

in allowable

emissions caused by a •ew major source or major modification

may not cause an adverse

impact on visibility

•n any sensitive

area or in any Class Federal area and will not interfere

with reasonably progress

toward remedying

of existing man-made

visibility

impairment

in a sensitive area. OMYA presented

in its application

an analysis

following

the procedures in the U.S. EPA's "Workbook

for Plume Visua Impact Screening

and Analysis,"

that no such adverse

impact would occur as a consequence

of their proposed

modifications. PUBLIC PARTICIPATION The proposed

project is classified

as a major modification

with emissions

increase

of all air contaminants

in excess of ten (10) tpy, and consequently,

the application

is subject to the public participation

requirements

of 10 V.S.A. §556. Additionally,

based upon its allowable emissions,

any operating

permit for this Facility is subject to the public participation requirements

of §5-1007

of the Regulations.

Therefore,

the Agency

31OMYA, Inc./Vermont

Marble Power Division #AOP-98-015a published noticed on July 29, 1999 in the Rutland Herald that it had received

an administratively complete

application

from OMYA, Inc. for the proposed

projects and operating permit modification.

Additionally,

the affected

states were also notified of the receipt of the administratively

complete

operating

permit application

on August 25, 1999. On August 25, 1999, the Agency determined

the application

satisfied

the requirements for technical

completeness. Public notice was published

in the Rutland Herald on September

11, 1999, of the Agency's plans to.issue a draft decision

approving

the issuance

of an amended

Air Pollution Control Permit. This notification

solicited

comments

on the application,

the Agency's review, and draft decision

for a minimum

of thirty (30) days. The notice also notified the public of an informational

meeting

scheduled

on Thursday,

October

7, 1999. The affected

states of New York, Massachusetts,

and New Hampshire,

the Federal Land Manager,

and U.S. EPA were notified of the Agency's

draft decision

on September 9, 1999. The comment

period closed on October

20, 1999, with the Agency receiving comments from OMYA, Inc. and the U.S. EPA. 12.0 CONCLUSIONS Based on the foregoing

technical

analysis

of the proposed

modification,

the following conclusions are made: The proposed

modification,

subject to the recommended

permit conditions,

will meet the applicable

emission

standards

contained

in state and federal regulations. Furthermore,

it is expected

that emissions

from the proposed modification will not significantly

deteriorate

air quality, nor will they cause or contribute to a violation.of

an ambient

air quality standard. Pursuant to regulatory

definition,

the proposed

project is designated

as a maior modification to an existing major stationary

source. C. Recommended

Permit Conditions

See draft permit. Consistent with 10 V.S.A. s•556(e) and for the purposes

of reducing

the administrative burden of enforcing

two separate

permits,

the Agency proposes

to issue the Air Pollution

Control Perm# to Construct

(approving

the proposed projects) in conjunction

with the Air Pollution

Control Perm# to Operate

(OMYA 's facilities). The result will be a combined

Air Pollution

Control Permit to Construct and Operate

("Combined

Permit").

32OMYA, Inc./Vermont

Marble Power DivisionAPPENDIX

A

#AOP-98-015a

Table 1: Existing Allowable

Emission

Estimates Table 2: New Allowable

Emissions/Aggregated Emissions

Increase Table 3: Future Allowable

Emission

Estimates Figure 1" Plant Location

(USGS Map)

33Table Existing Allowable Emission Estimates EAST PLANT Process equipment controlled using fabric filters: Maximum PM concentration limited to 0.02 grains/dry standard cubic foot of undiluted exhaust ("gr/dsc£'), unless otherwise noted; Unrestricted houm of operation; Only three of eight silos/bins discharge at any one.time, since only three pneumatic conveying systems feeding the bins/silos (Use highest emission rates and air flow rates for three bins/silos to determine allowable emissions). Combustion emissions based AP-42 emission factors for distillate oil firing: SO2 142(S)]bs/1000

gals, S % sulfur in fuel by wt., limited to 0.5% less; NO, 20 Ibs/1000 gals; CO 5 Ibs/1000 gals: NMHCs 0.34 Ibs/1000 gals. Combustion emissions from Raymond Mill, Flash Dryer #1, Flash Dryer #2. and Boiler based existing permitted fuel consumption limit of 600,000 gpy, and following approximate breakdown of usage: Raymond Mill (1% of total limit); Flash Dryer #1 (47.5%); Hash Dryer #2 (47.5%); and Boiler (4%). Control Max. Exhaust

PM

PM SO2 NO× CO NMHCs Pb HAPs • •

Flow Rate, dscfm Ibs/hr

t_#..y tpv t_p_..y • tpv tl3v t•v Raymond Mill

FF

2000

0.34

1.50 0.21 0.06 0.02 <0.01 <0.01 <0.01 Flash Dryer #11

FF

7530

1.29

5.65 10.12 2.85 0.71 0.05 <0.01 0.01 Flash Dryer #1 (Recycle)

FF

1560

0.27

1.17 Flash Dryer #2 (w/HE)

FF

8310

1.42

6.24 10.12 2.85 0.71 0.05 <0.01 0.01 Silo #1

FF

1700

0.29

1.28 Silo #2

FF

1700

0.29

1.28 Silo #3

FF

1700

0.29

1.28 Silo #4

FF

1700 Bin A

FF

1700 Bin B

FF

1700 Bin C

FF (0.01 gr/dscf)

1700 Bin D

FF (0.01 gr/dscf)

1700 Bin C & D Receiver

FF (0.01 grldscf)

800

0.07

0.30 Man. Packaging Dust Relief FF

1400

0.24

1.05 Auto. Packaging Dust Relief FF

2700

0.46

2.03 40 Mesh Unloading

FF

900

0.15

0.68 • #1('i• MMB3U/hr)

Uncontrolled 0.15

0.02 0.85 0.24

<0.0'1 <0.01 <0.01 TOTAL EAST 22.47 21.30 6.00 1.50 0.10 <0.01 0.02 VERPOL PLANT Process equipment controlled using fabric filters, unless otherwise noted; Maximum PM concentration limited to 0.01 gr/dscl, unless otherwise noted; Unrestricted hours of operation: Combuslion emissions based AP-42 emission factom for dislillate oil firing: SO2 142(S)1bs/1000

gals, S % sulfur in fuel by wt., limiled to 0.3% less; NOx 20 Ibs/1000 gals; CO 5 Ibs/1000 gels; NMHCs 0.34 Ibs/1000 gels. Spray Dryer #1 limited to 0.07 Ibs/short ton of total solids entering the spray dryer houdy basis and Spray Dryer #2 limited to 0,060 Ibs/short ton. SOz emissions from flash dryer systems

80% reduction in SOz emissions due to calciumcarbonate

powder. Spray dryer combustion emissions

the of exhaust heat from the turbines and limited supplemental firing in the spray dryers to 62 gph less each. Combustion emissions from the boilers is based upon fuel consumption limit of 680,000 gpy and the buming of this fuel within the largest boiler, Control Max. Exhaust

PM/PMI0 • •

Flow Rate, dscfm Ibs/hr Flash Dryer #3

FF

10,000

0.86/0.77 FD#3 Prod. Conveying

FF

2,700

0.23/0.21 Flash Dryer #1

FF

10,000

0.86/0.77 Flash Dryer #2

FF

10,000

0.86/0.77 FD#1 & FD#2

FF

2,700

0,23 Product Conveying

FF

2,700

0.23 Raw Product Silos (2) FF

1200 per silo 0.10 Deaggl0merator A Feed Silo FF

1200

0.10 Deagglomerator B Feed Silo FF

1200

0.10 Deagglomerator A

FF

16,700

1.43 Deagglomerator B

FF

16,600

1.42 Deagglomerator C

FF

16,200

1.39 Prod. Conveying

FF

1200

0.10 Prod. Conveying

FF

1200

0.10 Prod. Conveying

FF

1200

0.10 Surface Treater B

FF

24,400

2.09 Finished Product Conveying

FF

2650

0.23 Bulk Bagging Station

FF

3300

0.28 Spray Dryer #1

ESP 1.70 Spray Dryer #2

cyclone/ESP 1.32 (•4 MMBTU/hr)

Uncontrolled 0.34 •(t"9.7 MMB•U/h r) Uncontrolled 0.28 TOTAL VERPOL

PM/PMlo SO2 NO, CO NMHCs Pb HAPs 3.8/3.4 2.98 7.0 1.75 0.12 <0.01 0.02 1.0/0.913.8/3.4 2.98 7.0 1.75 0.12 <0.01 0.02 3.8/3.4 2.98 7.0 1.75 0.12 <0.01 0.02 1.01.0

0.45 0.900.450.456.276.236.080.450.45 9.160.991.247.45 2.31 5.78 2.31 0.68 14.48 O O 61.34/60.12 28.06 5.43 1.36 0.09 <0.01 0.01 5.43 1.36 0.09 <0.01 0.01 6.8 t.70 0.12 <0.01 0.02 O O O O O 38.66 9.67 0.66 <0.01 0.10 COGENERATION PLANT Emissions based continuous operation at maximum capacity and emission data provided by the equipment manufacturer, NOx from turbines controlled using water injection; diesel engines uncontrolled. Diesel-fired equ=pment hours of operation limited to 100 hours per year less each and sulfur in fuel limit of 0.3% by weight. PM/PM10 SO2 NO, CO NMHC Pb HAPs Equipment tl3v t_p__y t_.p_y t_9_.y t.p_y t_12.y tl3V Turbine #1 13.1 71.4 51.7 46.0 5.7 <0.01 <0.01 Turbine #2 13.1 71.4 51.7 46.0 5.7 <0.01 <0.01 Diesel Engine #1 (136 BHP) 0.01 0.02 0.18 0.07 0.01 <0.01 <0.01 Diesel Engine #2 (136 BHP) 0.01 0.02 0.18 0.07 0.01 <0.01 <0.01 Diesel-Fired Emergency

Generator Set (145 BHP) 0.01 0.02 0.22 0.42 0.01 <0.01 <0.01 TOTAL COGENERATION

PLANT 26.3 142.8 104.0 92.5 11.4 <0.01 <0.01 TOTAL FOR SOURCE

110.1/108.9

192.2 148.6 103.7 12.8 <0.01 0.1 34Table 2 NewAIIowable

Emissions/Aggregated

Emissions Increase NEW ALLOWABLE

EMISSIONS Allowable Emissions

Assumptions: Bulk bagger stations/silos,

new product transfer conveyor, house vacuum system, and rotopackers

each limited to PM/PMI0 emission concentration of 0.010 gr/dscf of undiluted exhaust, respectively.

Emissions calculated based on emission concentration

and maximum rated exhaust air flow rate for fabric filter sewing each orocess. Increase in emissions from Spray Dryer #2 associated with production increase, except PM/PMIo, based upon AP-42 emission factors for distillate oil-fired boiler. SO2 emiss=on rate also assumes 80% reduction from uncontrolled

emission rate due to inherent scrubbing of SO2 which occurs within the spray dryer by the calcium carbonate powder. PM/Pi•110 emissions based upon limit of 0.07 Ibs/short ton of product introduced into the dryer and increase in production rate. Increase in production is the difference between current actual emissions (CY '98) and future potential emissions assuming no heat is being supplied by the cogeneration

plant and 90% availability of the spray dryer. SPRAY DRYER #2

PM/PMI0

SOz Emission Limit:

0.07

142(S)=142(0.3)=42.6 Emission Limit Units:

Ibs/short ton Ibs/1000 gals. Factor assuming 80% control efficiency: 8.5 Ibs/1000 gals.

NOx CO NMHCs

Pb 20 5 0.34

Total Indiv. HAPsHAPsINCREASE IN EMISSIONS

FROM SPRAY DRYER #2 Emission Rate (Ibs/hr): 0.99

0.91

2.14 0.54 0.04

<0.01 0.01 <0.01 (tpy): 5.4

6.08

14.28 3.57 0.24

<0.01 0.04 0.02 BULK BAGGING STATION/SILOS Emission Rate (Ibs/hr): 0.96 (total) (tpy): 4.2 (total) NEW PRODUCT CONVEYING

SYSTEM Emission Rate (Ibs/hr): 0.23 (tpy): 1.0 HOUSE VACUUM SYSTEM Emission Rate (Ibs/hr): 0.21 (tpy): 0.9 ROTOPACKERS Emission Rate (Ibs/hr): 3.65 (total) (tpy): 16.0 (total) TOTALEmission Rate (Ibs/hr): 6.04

0.91

2.14 0.54 0.04

<0.01 0.01 <0.01 (tpy): 27.5

6.08

14.28 3.57 0.24

<0.01 0.04 <0.01

AGGREGATED EMISSIONS

INCREASE:

Since future allowable emissions of Pb & VOCs (including NMHCs from fuel burning) are less than significant levels not necessary to consider these emissions.

Additionally,

no significant level of HAPs, and therefore not relevant to aggregated

emissions calculation process.Step a) Calculate allowable emissions for new equipment Air Contaminant

Emissions, tpy PM/PMlo SO2 NOx CO 27.5 6.08 14.28 3.57 Step b) Calculate allowable emissions for all existing processes that are affected by the modification.

Included in Step a) for Spray Dryer #2. Step c) Calculate actual emissions for existing equipment that are affected by the modification

but which were installed prior to 7/1/79 or have been previously reviewed under § 5-502. Included in Step a) for Spray Dryer #2. Step d) Calculate allowable emissions from all otherequipment

at the site added since 7/1/79 which have not been reviewed under § 5-502. Modifications prior to 1991 reviewed as major modification

for PM/PM 1o,.SO•, NOx, and CO. Therefore, no longer necessary to consider minor modifications prior to 1991 for the previously identified air contaminants

for major source applicability. In 1996 Modifications

to East Plant to increase the permitted fuel consumption

limit from 445,000 gpy to 600,000 gpy. Calculations

provided in Technical Analysis dated March 29, 1996, with one change (must consider 80% SO• removal due to inherent scrubbing of SO2 in drying process by calcium carbonate) and summarized

as follows:

Air Contaminant

Emissions, tpy Modification PM/PMIo

SO• NO× CO Increase in Fuel Consumption

Limit

<0.1 1.1 1.6 0.4 35(Continued) In 1996 Addition of new flash dryer systems and associated product conveying equipment at Verpol Plant. The emission increase for this modification has been changed to reflect a reduction in the permitted fuel consun•ption

limit for the Flash Dryers #1 and #2 from 1,880,000 gpy to 1,400,000 gpy as requested by OMYA, Inc. in 1997, and again proposed to be reduced from 2,100,000 to 1,900,000 gpy for all three dryers (Flash Dryer #1, Flash Dryer #2, and Flash Dryer #3 633,333 gpy each). Calculations

as.provided

in Technical Analysis dated September

13, 1996, with two other changes [(1) assume 80% reduction in SO2 emissions rather than original estimate of 50% based upon emission testing; (2) flash dryer and conveyor PMIo emissions based on % of product handled being 10 um in size (FD#1 for Omyacarb 5 at 70% and FD#2 for Omyacarb 3 at 90%] and summarized

as follows: Air Contaminant

Emissions, tpy Modification PM/PMIo

SO2 NOx CO FD#1, FD#2, & prod.' conveying 9.6

5.4 12.7 3.2
Addition of replacement

boiler at Verpol Plant approved in 1997. Emissions equivalent to the new allowable emissions identified in Technical Analysis dated December 2, 1997, minus actual emissions associated with operation of boilers which pre-exist 1991. Air Contaminant

Emissions, tpy Modification PM/PMlo

SO• NOx CO New 24 MMBTU/hr Boiler 0.5

9.5 4.4 1.1

Increase in emissions associated with increasing the allowable PM/PMIo emission rate for Spray Dryer #1 at Verpol Plant from 1.32 Ibs/hr to 1.7 Ibs/hr in 1997. Air Contaminant

Emissions, tpy Modification PM/PMlo

SO2 NO× CO Increase in PM/PM10 emission limit for Spray Dryer #1 1.7

Addition of Flash Dryer #3 system and Flash Dryer #3 product conveying system in 1998. Emissions equivalent to the new allowable emissions identified in Technical Analysis revised November 6, 1998. The emission increase for this modification

has been changed to reflect a reduction in the permitted fuel consumption

limit for the Flash Dryer #3 from 700,000 gpy to 633,333 gpy as requested by OMYA, Inc. as part of this modification. Three flash dryers limited to 1,900,000 gpy (Flash Dryer #1, Flash Dryer #2, and Flash Dryer #3 633,333 gpy each). Air Contaminant

Emissions, tpy Modification PM/PM•o

SO2 NO× CO Flash Dryer #3 3.8 Flash Dryer #3 Product Conveying System

1.0

2.7 6.3 1.6
Total for Modification 4.8

2.7 6.3 1.6

Step e) Calculate TOTAL PRIOR MINOR MODIFICATIONS:

16.6

18.7 25.0 6.3
size of modification

Step a) + Step b) Step c) + Step d) Aggregated PM/PMlo Emissions Increase, tpy 27.5 tpy + 0 tpy 0 tpy + 16.6 tpy 44.1 tpy Aggregated SO2 Emissions Increase, tpy 6.1 tpy + 0 tpy 0 tpy + 18.7 tpy 24.8 tpy Aggregated NO, Emissions Increase, tpy 14.3 tpy + 0 tpy 0 tpy + 25.0 tpy 39.3 tpy Aggregated CO Emissions Increase, tpy 3.6 tpy + 0 tpy 0 tpy + 6.3 tpy 9.9 tpy

36Table 3 Future Allowable Emission Estimates EAST PLANT Process equipment controlled us=ng fabric filters: Maxim(•m PM concentration limited to 0.02 grains/dry standard cubic foot of undiluted exhaust ("gr/dscP), unless otherwise noted; Unrestricted hours of operation; Only three of eight silos/bins discharge at any time, since only three pneumatic conveying systems feeding the bins/silos (Use highest emission rates and air flow rates for three bins!silos to determine allowable emissions). Combustion emissions based AP-42 emission factors for distillate oil firing: SO2 142(S)1bs/1000

gals, S % sulfur in fuel by wt., limited to 0.5% less; NOx 20 Ibs/1000 gals; CO 5 Ibs/1000 gals; NMHCs 0.34 Ibs/1000 gals. Combustion emissions from Raymond Mill, Flash Dryer #1, Flash Dryer #2, and Boiler based existing permitted fuel consumption limit of 600,000 gpy, and following approximate breakdown of usage: Raymond Mill (1% of total limit); Flash Dryer #1 (47.5%); Flash Dryer #2 (47.5%); and Boiler (4%). SO2 emissions from dryer systems 80% reduction in SO2 emissions due to calcium carbonate powder. Control Max. Exhaust

PM PM SO2 NOx CO NMHCs Pb HAPs Process Equipment

Flow Rate, dscfm

Ibs/hr • t_p_y t•v • t•v t_p_y t•v Raymond Mill

FF

2000

0.34 1.49 0.04 0.06 0.02 <0.01 <0.01 <0.01 Flash Dryer #11

FF

7530

1.29 5.65 2,02 2.85 0.71 0.05 <0.01 0.01 Flash Dryer #1 (Recycle)

FF

1560

0,27 1.18 Flash Dryer #2 (w/HE)

FF

8310

1.42 6.22 2.02 2.85 0.71 0.05 <0.01 0.01 Silo #1

FF

1700

0.29 1.27 Silo #2

FF

1700

0.29 1.27 Silo #3

FF

1700

0.29 1.27 Silo #4

FF

1700 Bin A

FF

1700 Bin B

FF

1700 Bin C

FF {0.01 gr/dscf)

1700 Bin D

FF I0.01 gr/dscf)

1700 Bin C & D Receiver

FF (0.01 gr/dscf)

800

0.07 0.31 Man. Packaging Dust Relief FF

1400

0,24 1.05 Auto. Packaging Dust Relief FF

2700

0.46 2.01 40 Mesh Unloading

FF

900

0.15 0.66 Boiler #1 (10.5 MMBTU/hr)

Uncontrolled 0.15 0.02 0.85 0.24 0.06 <0.01 <0.01 <0.01 TOTAL EAST 22.4 4.94 6.00 1.50 0.10 <0.01 0.02 VERPOL PLANT Process equipment controlled using fabric filters, unless otherwise noted; Maximum PM concentration limited to 0.01 gddscf, unless otherwise noted; Unrostdcted hours of operation; Combustion emissions based AP-42 emission factors for distillate oil firing: SO2 142(S)1bs/1000

gals, S % sulfur in fuel by wt,, limited to 0.3% less; NOx 20 Ibs/1000 gals; CO 5 Ibs/1000 gals; NMHCs 0.34 Ibs/1000 gals. Spray Dryer #1 limited to 0.07 Ibs/short ton of total solids entedng the spray dryer hourly basis and Spray Dryer #2 limited to 0.060 Ibs/short ton. SO• emissions from all dryer systems

80% reduction in SO2 emissions due to calcium carbonate powder. Spray dryer combustion emissions

the of exhaust heat from the turbines and limited supplemental firing in the spray dryers (i.e.. SD #1 62 gph and SD #2 169 gph). Combustion emissions from the boilers based upon fuel consumption limit of 680,000 gpy and the buming of this fuel within the largest boiler. Control

Max. Exhaust

PM/PMlo PM/PM10 SO2 Process E_.q.•_pment

Flow Rate, dscfm

Ibs/hr • t_p_..y Bulk Bagger Stations/Silos

FF

800 each

0.07 ea. 4,2 total Product Transfer Conveyor

FF

2,700

0.23 1.0 House Vacuum System

FF

2,450

0.21 0.9 Rotopackers FF

14,200 each

1.22 ea. 16.0 total

NOx CO NMHCs Pb HAPs

Flash Dryer #1

FF

10,000

0.86 3.8 Flash Dryer #2

FF

10,000

0.86 3.8 Flash Dryer #3

FF

10,000

0.86 3.8 FD#1 & FD#2

FF

2,700

0.23 1.0 Product Conveying

FF

2,700

0.23 1.0 FD#3 P'rod. Conveying

FF

2,700

0.23 1.0 Surface Treater A

FF

10,000

0.86 3.8 Surface Treater C

FF

10,000

0.86 3.8 De•gglomerator C

FF

16,200

1.39 6.09 Prod. Conveying

FF

1200

0.10 0.44 Prod. Conveying

FF

1200

0.10 0.44 Prod. Conveying

FF

1200

0.10 0.44 Surface Treater B

FF

24,400

2.09 9.15 Finished Product Conveying

FF

2650

0.23 1.01 Bulk Bag. Transfer Hopper FF

1200

0.10 0.45 Spray Dryer #1

ESP 1.70 7.45 Spray Dryer #2

cyclone/ESP 2.31 10.1 Boiler #2 (24 MMBTU/hr)

Uncontrolled 0.35 0.7 Boiler #1 (19.7 MMBTU/hr)

Uncontrolled 0.28 O TOTAL VERPOL

80.2 30.4 2.7 6.3 2.7 6.3 2.7 6.3

2.1 4.9 1.2 5.7 13.3 3.3 14.5 6.8 1:7 o. o. o. 44.0 11.0 1.6 0.11 <0.01 0.02 1.6 0.11 <0.01 0.02 1.6 0.11 <0.01 0.02

0.08 <0.01 0.01 0.23 <0.01 0.01 0.12 <0.01 0.02 0. 0. o 0.75 <0.01 0.1(]

37(Continued) COGENERATION PLANT Emissions based continuous operation at maximum capacity and emission data provided by the equipment manufacturer. NOx from turbines controlled using injection: diesel engines uncontrolled, Diesel-fired equipment hours of operation limited to 100 hours per year less each and sulfur in fuel limit of 0.3% by weight.

Turbine #1 Turbine #2 Diesel Engine #1 (136 BHP) Diesel Engine #2 (136 BHP) Diesel-Fired Emergency

Generator Set (145 BHP) PM SO2 NOx CO NMHC Pb HAPs 13.1 71.4 51.7 46.0 5.7 <0,01 <0.01 13.1 71.4 51.7 46.0 5.7 <0.01 <0.01 0.01 0.02 0.18 0.12 0.01 <0.01 <0.01 0.01 0.02 0.18 0.12 0.01 <0,01 <0.01 0.01 0.02 0.20 0.40 0.01 <0.01_ <0.01 TOTAL COGENERATION

PLANT 26.2 142.8 104,0 92.6 11.4 <0.01 <0.01 TOTAL FOR SOURCE

129 178 154 105 12,3 <0.01 0.1

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