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 498 

Brattleboro, 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) 257-5910 
FiberMark 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 cleaner 

Paper Coating Line #1 na 

Paper Coating Line #2 na 

Two (2) Fuel Storage tanks 25,000 gallon 

1960 

1997 

na unknown 

na unknown 

na 

na 

No, 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 exiting 
FiberMark 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. 3 

Annual 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/PM10 

SO2 

NOx 5 

CO 

NMTOC 

(VOCs) 

HAPs 

23.1 

314 

72.74 

0.76 

0.15 

63,501.9 

863,186.0 

199,962.3 

13,745.0 

2089.2 

412.4 

31.8 

431.6 

100.0 

6.9 

1.0 

0.2 

AP-42, Fuel Oil. 

Combustion, 

Tables 1.3-1 and 

1.3-2, No. 6 oilfired. 10-96 

AP-42, Fuel Oil 

Combustion, 

Tables 1.3-3, 10- 

96 

AP-42, Fuel Oil 

Combustion, 

Tables 1.3-9 and 

1.3-11, 10-96 

Estimated 

annual fuel 

usage of 

2,749,000 

gallons 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/PM10 

SO2 

3.2 

71 

NOx 20 

CO 5 

NMTOC 0.34 (vocs) 

HAPs 0.04 

896.0 

19 880.0 

5,600.0 

11400.0 

95.2 

11.5 

0.45 

9.94 

2.80 

0.70 

0.05 

0.01 

AP-42, Fuel Oil 

Combustion, 

Tables 1.3-1 and 

1.3-2, distillate 

fuel. 10-96 

AP-42, Fuel Oil 

Combustion, 

Tables 1.3-3, 10- 

96 

AP-42, Fuel Oil 

Combustion, 

Tables 1.3-9 and 

1.3-11, 10-96 

Annual fuel 

cap of 

280,000 

gallons 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 inspections 
FiberMa 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 their 
FiberMark 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 ID 

Bigelow Boiler #1 

Size

38.2 MMBTU/hr 

Emission 

Standard 

0.27 

Ib/MMBTU 

Bigelow Boiler #2 38.2 MMBTU/hr 0.27 

Ib/MMBTU 

Supplemental boiler <15 MMBTU/hr 0.43 

Ib/MMBTU 

Allowable 

Emissions 

10.3 Ib/hr 

10.3 Ib/hr 

6.0 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 

Matter 

This 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 the dailyweighted 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; 

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 Safety-Kleen cold cleaning unit and 

solvent used at the Facility has a vapor pressure (0.008 psi) less than the 
FiberMark 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 Small IndustrialCommercial-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") for 
FiberMark 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 chemistry 
FiberMark 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 

Testing 

Results Formaldehyde 

Emission Action Level, 

Rate, Ib/8-hr 

Ibl8-hr 

0.0037 

0.0018 

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 Cp Fapc- 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 pounds 
FiberMark 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 Map 
VERMONT 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 05301-8615 
Cersosimo 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 13 
Cersosl 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 13 
Cersosimo 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 13 
Cersosimo 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 13 
Cersosimo 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 ty 

NOx 0.22 AP-42 Wood Residue Combustion in 19.4 

SO2 

PM 

PM10 • 

voc 

HAP 

0.025 Lb/MMBtu 

0.60 

0.45 gr/dscf 

0.20 

0.017 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) 

2.2 

52.8 

97.2 

17.6 

1.5 

3.4 

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/Ib 

550,000 dscf/hr, Factor Units 

5500 hr/year at max 

capacity 

NOx 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) 

19.4 

2.2 

52.8 

43.2 

17.6 

1.5 

3.4 

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 13 
Cersosimo 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/PM10 

SO2 

NOx 

4900 

Actual fuel use 

during previous 

MSER review 

78.0/t4.1 

1.8 

15.5 

4900 

Previous 

Permit Limit 

#AOP-95-056 

97.5/17.6 

2.2 

19.4 

42.3 52.9 

-VOC 1.2 1.5 

HAP 2.8 3.4 

44OO 

Proposed 

Permit Limit 

97.2/17.6 

2.2 

19.4 

1.5 

3.4 

3-1 3-2 

19.2/3.5 

0.4 

3.9 

10.5 

0.3 

0.6 

0.0 

0.0 

-0.1 

0.0 

0.0 

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 

VOC NCASI Emissions From Lumber Drying: 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 13 
Cersosimo 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 

Kilns 

Boilers 

Wood Waste 

Total 

Significance 

Level 

Exceed 

Significance 

Level? 

19.2/3.5 0.4 

19.2/3.5 0.4 

25/15 40 

No No 

3.9 

NOx CO 

0 0 

10.5 

0 0 

3.9 10.5 

40 50 

No • No 

nination 

VOCs 

3.9 

0.3 

0 

4O 

No 

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 13 
Cersosimo 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 13 
Cersosimo 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 13 
Cersosimo 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 13 
Cersosimo 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 the shortterm 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 13 
Cersosimo 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 13 

VERMONT 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 

Caledonia 

Attainment 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 d 

06/30/97 

07/02/97 

§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 

2 
Ryegate 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, selective 
Ryegate 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 total nonmethane 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 being 
Ryegate 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 0.007 

gr/dscf 

@12% 

CO2 

Auxiliary Boiler 0.005 

Emergency Generator negligible 

Cooling Towers & Deaerator Vents 

Chemical and Fuel Storage Tanks 

Degreasing/Solvent Tanks 

Fugitive Dust from Wood N/Q*** 

Handling/Storage and Haul Roads 

5.0 

0.03 

neg. 

30.0 

0.05 

0.28 

45.0 

0.75 

8.1 

90.0 

0.11 

26.5 

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 

7 
Ryegate 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 during 
Ryegate 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 use 
Ryegate 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. 

10 
Ryegate 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 

11 
Ryegate 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) 

12 
Ryegate 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. 

13 
Ryegate 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 for IndustrialCommercial-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. 

14 
Ryegate 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 

15 
Ryegate 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 

16 
Ryegate 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. 

17 
Ryegate 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 

7782-50-5 

13590-97-1 

64-17-5 

107-21-1 

123-31-9 

67-63-0 

110-91-8 

0.036 1.3 

0.026 0.025 

0.005 2,330 

0.09 

0.01 

53 

0.2 

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 Certification 

18 
Ryegate 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. CONCLUSIONS 

Ryegate 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. 

19 
Ryegate 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 of biennial 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. 

20 
Ryegate 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 Ownerto 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 

21 
Ryegate Associates, Incorporated 

Associates over the re porting period. 

[§ 5-1015(a)(8) of the Regulations] 

#AOP-95-031 

22 
APPENDICES 

Appendix 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] 

24 
Determination 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 Total 

SO2(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-1 
Volatile 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 

Wood 

0.009 

22 

25 

Wood+Propane. 

0.02 

25 

197 

Wood 

0.27 

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-2 
Determination 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 provide makeup 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-3 

VERMONT 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 

Essex 

Attainment for PM10, SO2, NOx, CO, and Pb 

Unclassified for O3 

49209°° m N 

°283600 m E 

Zone 19 
American Paper Mills of Vermont, Inc. 

I. INTRODUCTION 

A. Administrative Milestones 

Table 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) 

11/1/95 

11/14/95 

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 source 

2621 

Paper 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 contaminant 
American 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.), volatile 
American 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. 

4 
American 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 

PROCESS 

NPUT 

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 Boilers 

Paper 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 chips 

ahd 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: 

Model SP-JX4B8 

2 Radar Long 

Cone Design 

Cyclones 

Uncontrolled 

50,000 acfm 

482 acfm 

5720 acfm 

each 

HE GriT (FT •TEMP. ("F) 

-•:Grade) •-r 

225 ft.(Stack 

Dia. 9.17 

ft.) 

see Table 3 

55.1 feet 

50feet 

each 

450oF 

350°F 

ambient 

ambient 

ambient 
American 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 #23 

In 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 Unit 

Paper Machine Dryer 1- Section 

Paper Machine Dryer 2- Main Section 

Paper Machine Dryer 4 -Section 3 

50 

Paper Machine Dryer 3- Main Section 50 

5O 

Room Vent -Section 

Room Vent Section 2 (1) 

Room Vent Section 2 (2) 

Room Vent Section 3 

Winder Vent (1) 

Winder Vent (2) 

50 

50 

50 

120,000 

30,000 

30,000 

30,000 

30,000 

20,000 

17,000 

17,000 

50 17,000 

50 12,000 

8,000 

20,000 

20,000 

6,000 

7,000 

50 

50 

50 

5O 

Sky Vent (1) 

Sky Vent (2) 

Exhaust Fan 

Room Vent 

PM Vacuum Pump 

50 

5O 18,OOO 

6 
American 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 

Area 

Diesel Tractors 

No. 2 Fuel Oil 1968 

.No. 2 Fuel Oil i975 

No. 6 Fuel Oil 

Diesel Fuel 

1967 

1993 

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. 

9 
American 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 

Oil 

Fuel Wood Cyclones 

Starch Silo 

7 

78 

Degreasers 

Paper Machine 

Totals 85 

237 

13.6 

251 

366 19 4 

t.2 9.6 0.1 0.03 

26 

2366 

1.1 

414 

49 

-69 

10 
American 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 will verifycompliancewith 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. 

11 
American 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. 

12 
American 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 EpM [hr.•-MBt•/I [• HOB 0.16936] 

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 

13 
American 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 

14 
American 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 

15 
American 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: 

Oxygen 

Overfire/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 

Emission 

Monitoring 1 hour average System 

Rolling 24 hour Continuous 

Emission 

Monitoring 

system 

At all times 

except start up 

and shutdown 

Start up and 

shutdown 

At all times 

except.start up 

and shutdown 

16 
American 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. 

17 
American 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). 

18 
American 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. 

19 
American 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 for IndustrialCommemial 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, 

1989 

No 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 no 

incinerators at the 

Facility 

This is too broad a 

request.* 

This is too broad a 

request.* 

20 
American 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 

Emissions 

Prohibition 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 

Granted 

Granted 

Granted 

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. 

21 
American 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 Denied 

Control of Ozone Depleting Chemicals: Denied 

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 

22 
American 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. 

Sodium 

Hypochlorite 

Blue GDF 

Saf-T-Brite II 

Sodium Hydroxide 

Diethanolamine 

D-Limonene 

0.17 

hydroquinone 

0.10 

0.09 

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 

23 
American 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) 

24 
American Paper Mills of Vermont, Inc. #0P-95-032 

This page was intentionally left blank. 

25 
American Paper Mills of Vermont, Inc. #0P-95-032 

APPENDIX A 

Site Map 

Plot Plan 

Process Flow Diagram 

APPENDIX B 

Emissions Calculations 
American 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-1 
American Paper Mills of Vermont, Inc. #0P-95-032 

NOx 

CO 

SO× 

Table B.2: Zurn Boiler Wood Firin 

54 Ibs/hr 

540 Ibs/hr 

NO RACT Administrative Order, 1/9/96 

NOx PACT Administrative Order, 1/9/96 

237 

2,365 

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-2 
American Paper Miffs of Vermont, Inc. #0P-95-032 

Table B.3: Allowable emissions from Babcock and Wilcox Boilers. 

NOx 

CO 

SOx 

VOC 

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 78 

0.28 Ibs/10 • gallons AP-42, Table 1.3-3, 9/98 0.07 

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} 3 
American 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 GDF 

Elvanol 71-30 

Protocol WB 8000 

Caratarex FL 

Yorksize 1030 

Latex DL 233NA 

Yellow Rw Liq 

Blue 2AL 

251 

323,663 

23,321 

26,943 

223,436 

34,984 

713 

10.9 

5 

20.3 

27 

16,183 

4,734 

566 

5,971 6 

Leucophor B302 272,630 0.4 1,091 

Perform PC 8138 64,074 30 19,222 

2,1 

8 17,875 

0.05 17.5 

3.2 23 

358 

18,798 44 8,271 

354 10 35 

2,882 5 144 

WSM-935 

Spectrum RX 8700 

Saf-t-Brite 

Total (34 tpy) 68547 

B-4 
American 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) 

Sodium 

Hypochlorite 

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 

Styrene 

Methanol 

9,573 

231,193 

.O5 

3.2 

0.004 

6.8 

42.5 

322 

B-5 
VERMONT 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 

Caledonia 

Attainment 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 Milestones 

Table 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, on 
EHV 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. 

4 
EHV 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 to 
EHV 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 

6 
EHV 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. 

11 
EHV 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. 

12 
EHV 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 

See 

Note 2 

42 410 

89 

131 410 

0.2 

•-- 42 (+/-) 

See 

Note 

<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 

13 
EHV 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 

22.0 

4O 

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. 

14 
EHV 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 I VOCsProposed Modification 5.1 

Emission Due to Prior Modifications 4.9 

Aggregated Emissions Increase 

Significant Level 

[per § 5-101 of the Regulations] 

10.0 

25115 

21.8 

13.4 

35.2 

4O 

22.0 1.7 0.4 

5.9 

27.9 

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 (+/-) 

See 

Note 

<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 

15 
EHV 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, 

and 

Emission 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 

16 
EHV 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 

17 
EHV 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 

18 
EHV 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 

19 
EHV 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 

20 
EHV 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 

21 
EHV 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 

22 
EHV 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 

23 
EHV 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. 

24 
EHV 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. 

25 
EHV 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. 

26 
EHV Weidmann Industries, Inc. #AOP-O0-024 

27 
EHV 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 

28 
EHV 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 

29 
EHV 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 for noncompliance 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 

30 
EHV 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 

Granted 

Granted 

Granted 

Granted 

Granted 

Granted 

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. 

31 
EHV 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 

32 
EHV 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. 

33 
EHV 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 acetate 

Styrene 

Acetone 

108-05-4 0.3 14.7 

100-42-5 24 42.5 

67-64-1 68 7,480 

34 
EHV 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) 

Antimony 

Arsenic 

Benzene 

Beryllium 

Cadmium 

Chromium 

Cobalt 

Ethylbenzene 

Formaldehyde 

Lead 

Manganese 

Mercury 

Naphthalene 

0 

0 

71-43-2 0.00027 

0 0.000036 

0 

0 

0 

0.0067 

0.0017 

0.00051 

0.00083 

0.0077 

100-41-4 0.00082 

50-00-0 0.001 

0 

0 

91-20-3 

0.0019 

0.0039 

0.00015 

0.0015 

35 
EHV Weidmann Industries, Inc. #AOP-O0-024 

Nickel 

o-Xylene 

Polycyclic Organic Matter (POM) 

Selenium 

Styrene 

1,1,1-Trichloroethane 

Toluene 

Vinyl acetate 

TOTAL 

1330-20-7 

0 

0 

100-42-5 

71-55-6 

108-88-3 

108-05-4 

0.11 

0.00014 

0.0017 

o.00088 

7* 

0.00030 

0.0080 

0.07" 

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. 

9.0 

9.1 

COMPLIANCE PLAN 

Description of the Compliance Status for Each Applicable Requirement 

See paragraph 5.0 above. 

36 
EHV 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 a nonmajor 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. 

37 
EHV Weidmann Industries, Inc. #AOP-O0-024 

38 
APPENDICES 

Appendix 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] 

40 
Table 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 North 

Boiler #1 

No. 2 Oil 

Boiler 

Peerless 

Fab North 

Boiler #2 

No. 2 Oil 

[•oiler 

Peedess 

Fab North 

Boiler #3 

No. 2 Oil 

Boiler 

Recycle 

Heater #1 

No. 2 Oil 

Heater 

Training 

Boiler #1 

No. 2 Oil 

Boiler 

Recycle 

Duct Heater 

No. 2 Oil 

Heater 

Cox 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 

43.0 

410.4 

100.1 

14.7 

7.5 
EPA 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 

0 

0 

CO VOCs 

14.7 

0 

0 

7.5 

0 

+/- 42.5 

Acetone Total HAPs 

0 0.19 

0 0 

49 24 

TOTAL 130.4 410.4 100.1 14.7 <50 <50 <25 
Table 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/PM10 

SO2 

Nox 

CO 

NMHCs 

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 0.4 
Table 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/year 
Table 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 North 

Eioiler #1 

No. 2 Oil 

Boiler 

Peerless 

2.67 

0.5 

0.14 

19 

8,760 

100 

165,440 

Fab Nortl• 

Boiler #2 

No. 2 Oil 

Boiler 

Peerless 

2.67 

0.5 

0.14 

19 

8,760 

100 

166,440 

Fab North 

Boiler #3 

No. 2 Oil 

Boiler 

25 

1.05 

0.5 

0.14 

7.58 

8,76O 

100 

66,401 

Recycle 

Heater #1 

No. 2 Oil 

Heater 

Training 

Boiler #1 

No. 2 Oil 

Boiler 

0.1 

0.5 

0.14 

0.85 

8,76O 

100 

7,446 

0.13 

0.5 

0.14 

1.15 

8,76O 

100 

10,074 

Recycle 

Duct Heater 

No. 2 Oil 

Heater 

Cox Manuf. 

0.525 

0.5 

0.14 

4.5 

8,760 

100 

39,420 

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 5.7 
EPA 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 <25 
VERMONT 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 

Windham 

Attainment for PM10, SO2, NOx, CO, & Pb 

Unclassified for O3 

UTM COORDINATES: 7021°° m E, 47609°° m N, Zone 18 Boiler Room Stack 
Putney Paper Company, Inc. 

1.0 INTRODUCTION 

1.1 Administrative Milestones 

Table 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 

2 
Putney 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 fiber 
Putney 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. 
Putney 

3.0 

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. 

5 
Putney 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 

6 
Putney 

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 

Boilers 

Paper Production 

TOTAL 

55.2 

55.2 

361.1 

361.1 

83.7 

83.7 

5.8 

5.8 

0.3 

25.7 

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 

7 
Putney 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 

8 
Putney 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 in 
Putney 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. 

10 
Putney 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. 

11 
Putney 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 

12 
Putney 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 

13 
Putney 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 for noncompliance 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 

14 
Putney 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. 

15 
Putney 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 

7.0 

7.1 

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 

16 
Putney 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. 

17 
Putney Paper Company, Inc. #0P-95-066 

APPENDICES 

Appendix A 

Table 2-1" Equipment Information 

Table 2-2: Stack Information 

18 
Putney 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 

655-600 

L-42356 

Steam production 

Fire tube 

25 

600 

76% 

150/120 

20,000/18,400 

No. 6 Fuel Oil 

0.15 

2.0 

0.5 

Cleaver Brooks 

655-600? 

L-42356? 

Air atomizing (tow 

pressure) nozzle 

167.5 

Forced draft 

7,097 

30-50% 

4.4% 

13% 

N/A 

No 

No 

No 

No 

2 times per day 

No 

Cleaver Brooks 

655-600 

L-36070 

Steam production 

Fire tube 

25 

600 

76% 

150/120 

20,000/18,400 

No. 6 Fuel Oil 

0.15 

2.0 

0.5 

Cleaver Brooks 

655-6O0 

L-42356? 

Air atomizing (low 

pressure) nozzle 

167.5 

Forced draft 

7,097 

30-50% 

4.4% 

13% 

N/A 

No 

No 

No 

No 

2 times per day 

No 

19 
Putney Paper Company, Inc. #0P-95-066 

Table 2-2: Stack Information 

PARAMETER Stack #1 

Stack height above base, feet: 60 

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) 

3 

5,089 

7,097? 

394 

N/A 

12 

N/A 

702100 m E, 4760900 m N, Zone 18 

No rain cap 

Vertical 

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 05485 
Rock-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 

5 

2.98 

Steam supplied from Boilers 

3.264 

Natural Gas 

Natural Gas 

1.67 

89 Fuel Oil 

80 Natural Gas 

27 

33 

31 

Fuel Oil 

Fuel Oil 

Natural Gas 

Fuel Oil 

Natural Gas 

)er hour maximum rated heat input. 

1969 

2001 

1996 

"1998 

2001 

1950 

Page 2 of 22 
Rock-TennConverting Company #AOP-05-018a 

(B) 

(c) 

Equipment Specifications 

Diesel Emergency 

Generator 16 Diesel 

bhp Brake Horsepower 

FACILITY CLASSIFICATION 

•lon 

1950 

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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 are nonapplicable. 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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-Tenn Converting Company #AOP-05-018a 

(8) 

(9) 

Polychlorinated Bephenyls (PCBs) 

Total Halogens 

Arsenic 

Cadmium 

Chromium 

<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 22 
Rock-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 22 
Rock-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 2.98 

3.264 

Coating Dryer #2b 

Wickes Boiler #1 

Wickes Boiler #2 

B&W Boiler #3 

B&W Boiler #4 

Diesel Emergency Generator 

1.67 

89 

27 

33 

31 

16 

0.5 

0.18 

0.31 

0.29 

0.29 

0.40 

2,5 

1.49 

1.632 

0.835 

16.0 

8.8 

9,6. 

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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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 22 
Rock-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/jr 

A2 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 05902-0217 
Ethan 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 12 
Ethan 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) 

3.6 

94.9 

Total MMBTU/yr (x8760) 831,324 

Max possible fuel usage 94,468 wet/54,692 dry 

(tons/yr or gal/yr) 

2.5 

67.9 

594,804 

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 12 
Ethan 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 

242 

245 

 ̧11 

40 

73 

<100 

<100 

<100 

251 

252 

7 .16 

16 

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 

158 

56 

157 <100 167 5 i0 

154 <100 81 3 5 

Page 4 of 12 
Ethan 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 12 
Ethan 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 

48,800 

31,300 

0.06 

58,200 

0.02 

0.02 

1.4 

8.4 

5.4 

6.1 

36.8 

23.7 

50,400 0.02 8.7 38.1 

0.06 29.9 131.0 

35,200 0.06 18.1 

Na air returned to SyStem B Pneumafil #4 

79.3 

Na green material only 

30,450 0.02 5.3 

3,000 0.06 1.5 

13.3@5000hrs 

6.6 

334.9 

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 12 
Ethan 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 2532 

1988 2682 

1989 2922 

1990 2842 

1991 

1992 

1993 

1994 

2662 

3002 

255.6 

251.6 4.4 

1995 264.2 11.8 

1996 224.7 40.3 

1997 239.1 54.9 

1998 

i999 a 

222.8 

219:4 

2000 4 219.0 

2001 184.1 45.9 

177.0 44.0 

146.6 

2002 

2003 

48.2 

51.6 

47.0 

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 12 
Ethan 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 12 
Ethan 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 12 
Ethan 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 

:ActionLevel 

0.011 

0.0132 

294 

98 

Annual 

Annual 

8 hr 

8 hr 

24 hr 

34.0 

280 

76000 

77800 

4380 

24.0 

170 

64000 

64200 

42 

36 

61200 

55000 

Butyl propasol 7.4 3440 3220 

Isobutan01 63 8 hr 16720 16580 16160 

43565 

41832 

2658 

12688 

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 12 
Ethan 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 12 
Ethan 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 12 
VERMONT 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) 229-9361 
Agrimark-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 13 
Agrimark-Cabot, Inc., Middlebury TAOP-02-024 

Page 3 of 13 
Agrimark-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 13 
Agrimark-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 13 
Agrimark-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 1000 

0.125 

Emission Factor 

Ib solid/Ib 

drift 

0.001 

Emission 

Rate 

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 13 
Agrimark-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 Ib/1000 gal AP-42 Table 1.5-1 (10/96) 0.14 

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: 

Pollutant 

SO2 2 

PM 

VOC 

Emission 

Factor 

0.1(S) 

4.5 

0.02 

'12.6 

0.5 

Estimated Allowable Emissions from Permeate Dryer and Wet Scrubber 

(EP-13) 

Units 

Ib/1000 gal 

Ib/1000 gal 

gr/dscf 

Ib/1000 gal 

Ib/1000 gal 

Source 

AP-42 Table •.5-1 (10/96) 

Manufacturer data 

MSER 

Manufacturer data 

AP-42 Table 1.5-1 (10/96) 

Emission Rate 

(tons/year) 

0.3 

1.4 

21 

3.9 

0.16 

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 

SO2 

NOx 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 13 
Agrimark-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 13 
Agrimark-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 13 
Agrimark-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 13 
Agrimark-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 13 
Agrimark-Cabot, Inc., Middlebury TAOP-02-024 

WPC Baghouse #1 

WPC Baghouse #2 

WPC Conveyor/Receiver Baghouse 

0.01 

0.01 

0.01 

•0.81 

0.85 

0.22 

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 

164 

158 

84 

117 

89 

93 

9455 

9876 

2588 

12239 

2478 

23476 

5.6 

5.6 

0.6 

3.1 

0.8 

5.5 

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 13 
Agrimark-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 the shortterm 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 13 
VERMONT 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 Plant 

Verpol Plant 

Cogeneration 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 within 
OMYA, 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 

10/07/99 

10/20/99 

§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 

4 
OMYA, 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 

6 
Table 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 

40 Mesh Unloading fabric filter; PM emissions < 0.02 gr/dscf 

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 

7 
OMYA, 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 Plant 

Verpol Plant 

Co•leneration Plant 

Total 

22 21 6 2 

61/60 28 39 10 

26 143 104 93 

109 192 149 

<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 

9 
OMYA, 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 

10 
OMYA, 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 

11 
OMYA, 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. 

12 
OMYA, 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 Levels 

Aggregated 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 

8O 

22 

Co•leneration Plant 26 

Total 129 

143 

178 

44 

104 

154 

11 

2 

105 

11 

12 

<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 

13 
OMYA, 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 

14 
OMYA, 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. 

15 
OMYA, 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 Regulations 

16 
OMYA, 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 

17 
OMYA, 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, 

18 
OMYA, 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. 

19 
OMYA, 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 Small Industrial-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. 

20 
OMYA, 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: 

21 
OMYA, 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 

22 
OMYA, 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 

23 
OMYA, 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) 

Plant 

Spray 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 

24 
OMYA, 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. 

25 
OMYA, 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. 

26 
OMYA, 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 

27 
OMYA, 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 

28 
OMYA, 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-hour 

Annual 

150 ug/m 

100 ug/m 

150 ug/m 

100 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 

29 
OMYA, Inc.Nermont Marble Power Division 

24-hour 

NO2 Annual 

#AOP-98-015a 

55 ug/m 

24 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 Annual 

24-hour 104 ug/m 150 ug/m 

NO2 Annual 31 ug/m 100 ug/m 

30 
OMYA, 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/m 

2.5 ug/m 

8 ug/m 6.0 ug/m 

2.5 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 

31 
OMYA, 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"). 

32 
OMYA, Inc./Vermont Marble Power Division 

APPENDIX 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) 

33 
Table 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 

1.0/0.91 

3.8/3.4 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 

1.0 

1.0 

0.45 

0.90 

0.45 

0.45 

6.27 

6.23 

6.08 

0.45 

0.45 

9.16 

0.99 

1.24 

7.45 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 

34 
Table 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. 

HAPs HAPsINCREASE 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) 

TOTAL 

Emission 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 

36 
Table 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 

38