1 New York State Department of Environmental Conservation
Best Available Retrofit Technology Determination

Facility International Paper Ticonderoga Mill

Location Ticonderoga, NY Essex County

Permit ID 5-1548-00008 Source Category Kraft Pulp Mill

I. Introduction

The above referenced facility contains at least one emission source that falls under the requirements of the federal Best Available Retr ofit Technology (BART) rule under 40 CFR Part 51 and Appendix Y, and the New York State BA RT regulation as codified under 6 NYCRR Part 249. These requirements affect an emission s ource which fulfills the following criteria:

1. Falls within one of 26 sp ecific source categories,
2. Was not in operation prior to August 7, 1962 and was in existence on August 7, 1977, or
underwent reconstruction between August 7, 1962 and August 7, 1977, and
3. Has a potential to emit (collectively, with ot her emission sources at the facility which fulfill items 1 and 2) of 250 tons per year or more of any visibility-impairing pollutant.

In accordance with BART requirements, each BART-eligible facility performed a BART analysis of controls for sulfur dioxide, nitrogen oxides and particul ate matter. This analysis took
into account such factors as the cost of c ontrols, energy and non-air quality environmental impacts of compliance, any existing pollution co ntrol technology in use at the source, the remaining useful life of the source, and the de gree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

This document summarizes the reasoning be hind the Department’s BART determination, including the level of cont rols and emission limits that constitute BART for this facility’s eligible emission source(s). Each analysis and BART determination was submitted to the Federal Land Managers (FLMs) for their review in accordance with Regional Haze State Implementation Plan (SIP) requirements. Comments received from the FLMs on this determination will be included
with its official submission to the U.S. Environmental Protection Agency (EPA).

The Department has modified this facility’s Title V permit to include the enforceable BART
limits. The modifications were noticed in Ne w York State’s Environmental Notice Bulletin on December 21, 2011. Upon completion of this pub lic notice period, the modified permit was submitted to EPA for review on February 1, 2012. The final modified permit was issued on March 19, 2012. This permit is now being submitt ed to EPA as a revision to the New York Regional Haze SIP.2 II. BART Analysis Summary

International Paper (IP) submitted a BART analysis for their Ticonderoga Mill dated September, 2010. Supplemental information was provided by IP on December 6, 2011 in response to Federal Land Manager and EPA comments. Th e following emission sources had previously been identified as BART-eligible and were therefore included in the analysis:

Power Boiler – Emission Unit POWERH; Emission Source 10044

• This unit is an Erie City Iron Works multi-fu el fired spreader stoker boiler with a heat input rating of 855 mmBtu/hr. This boiler is permitted to burn a variety of fuels for the purpose of producing steam and electricity via a turbine generator. The fuel mix for this boiler is typically 80 percent residual oil a nd 20 percent wood residue on a heating value basis. Operation of this unit commenced in 1970. Current control equipment includes
low NO
x burners, overfire air, flue gas reci rculation, a wet scrubber with sodium hydroxide injection, and a multicyclone unit.

Recovery Furnace – Emission Unit RECOVB; Emission Source 10001

• This unit is a Babcock & Wilcox kraft recovery furnace. It is used to recover chemicals from spent pulping liquor and to produce steam for the mill. It consists of a low-odor
non-direct contact kraft rec overy furnace and a smelt dissolving tank. The recovery furnace processes black liquor and fires No. 6 o il as an auxiliary fuel (restricted to less than 10 percent based on heat input). Op eration of this unit commenced in 1970. The boiler operates with a three-level staged combustion air supply system, and an electrostatic precipitator (ESP) for PM control.

IP conducted visibility modeling to demonstrate that smaller, lower-emitting BART-eligible emission sources had visibility impacts small en ough that the sources could be omitted from the BART analysis. IP modeled visibility impact s for the lime kiln (EU RCAUST, ES 10005), smelt dissolving tank (EU RECOVB, ES 10003), and mi scellaneous PM emission sources—a starch silo and two wood chip cyclones, which em it approximately 3.4 and 9.9 tons per year, respectively—at the Ticonderoga faci lity in order to show their neg ligible impacts on visibility in
Class I areas.

The lime kiln and smelt dissolving tank had th eir greatest impacts on the Lye Brook Wilderness area; the maximum impact by the lime kiln was 0.001 dv, a nd that of the smell dissolving tank was 0.017 dv. The PM sources had their greatest impacts on the Great Gulf Wilderness area, with a maximum impact of 0.008 dv. The 8 th highest impacts from these units were <0.0005 dv, 0.007 dv, and 0.003 dv, respectively. These values repres ent the changes in visibility on the 20% best natural background days.

The modeling procedures were reviewed to ensu re conformity with the Department’s modeling protocol. The Department accepts IP’s demonstr ation and conclusion that these units need not be included in the BART analysis as th ey cause negligible visibility impacts.3 A summary of the analysis’ findings for each pollutant are as follows:

Power Boiler

• SO 2

The Ticonderoga Mill’s power boiler curren tly operates with a wet-alkaline scrubber (installed in 1996 and designed for PM removal), which controls SO 2 emissions at a rate of approximately 65 percent (or approximate ly 85 percent when ta king into account the sulfur content of the non-condensable gases th at are also controlled by the scrubber). Upgrades or improvements to increase the control efficiency for SO 2 were ruled out by IP since this unit is designed as a PM c ontrol device, and operational changes may jeopardize the ability to meet PM emission limits.

IP cites the combustion of natural gas or possi bly lower sulfur fuel oil and/or wet or dry scrubbing as potential emission controls. The use of natural gas is ruled out because of the prohibitive distance to the nearest natural gas pipeline (approxima tely 70 miles). IP goes on to compare the existing permitted SO 2 levels for the power boiler to other BART guidelines and policies in order to demonstrat e the effectiveness of the current control and permitted limits.

IP begins by citing the suggested fuel su lfur limit of 1 percent or less by weight established by EPA in Appendix Y for uncontro lled utility boilers. IP notes that for typical residual fuel oil, 1 pe rcent sulfur results in an SO 2 emission rate of 1.05 lb/mmBtu, the equivalent of 900 lb/hr on a 24-hr average for a boiler operating at 855 mmBtu/hr (the maximum rating for the Power Boiler). The power boiler’s current permit
limit is well below this at 309 lb/hr on a 24-hr average.

IP then notes MANE-VU’s BART Workgroup recommendations (from the “Five-Factor Analysis of BART-Eligible Sources,” June 1, 2007) for presumptive SO 2 levels for industrial boilers of 90 percen t control, compliance with the ICI Boiler MACT acid gas control level, or 0.55 lb/mmBtu (0.5 percent fuel sulfur limit). IP commits to complying
with the ICI Boiler MACT acid gas control requirements when they are finalized. As above, IP notes that a 0.55 lb/ mmBtu level is equivalent to 470 lb/hr at a rating of 855 mmBtu/hr, whereas the power boiler alre ady complies with a 309 lb/hr limit.

The Department’s fuel sulfur regulations requi re boilers to use 0.3 a nd 0.37 percent sulfur
residual fuel oil in NYC and Nassau/Rock land/Westchester Counties, respectively. These are equivalent to rates of 0.314 lb /mmBtu and 0.387 lb/mmBtu, or 268 lb/hr and 331 lb/hr for an 855 mmBtu/hr boiler. IP’s permit limit is within the hi gher rate; they cite insignificant visibility improvement (0.02 dv) th at would result from moving to the lower

rate.

Finally, IP notes the federal New Source Performance Standard (NSPS) for industrial oilfired boilers built after February, 2005 is 0.20 lb/mmBtu (40 CFR 60 Subpart Db). This is equivalent to 171 lb/hr at a maximu m rating of 855 mmBtu/hr—lower than the4 permitted 309 lb/hr limit. IP demonstrates th at insignificant visibility improvement of 0.07 dv would result from meeting this NSPS limit.

IP therefore contends that th e current operation of the wet-al kaline scrubber, the existing
SO 2 emission limit of 309 lb/hr as a 24-hour rol ling average, and future compliance with the ICI Boiler MACT acid gas standard represent BART for SO 2 for the Ticonderoga Mill power boiler.

• NO
x

The power boiler presentl y operates with low NO
x burners, overfire air, and flue gas
recirculation which limit NO
x emissions to 0.25 lb/mmBtu. Maximum baseline emissions during the 2005 to 2009 period were 178 lb/hr as a 24-hour average; at the maximum capacity of 855 mmBtu/hr, maximum permitted NO
x emissions are 214 lb/hr. IP again compares the existing permitted NO
x levels for the power boiler to other BART guidelines and policies in order to demonstrat e the effectiveness of the current control and permitted limits. IP notes that EPA’s BA RT rule did not set specific presumptive
NO
x limits for oil-fired boilers, but that stat es should generally consider “current combustion control technology.”

The NSPS for industrial oil-fired boilers bui lt after February 28, 2005 is 0.20 lb/mmBtu (40 CFR 60 Subpart Db). At a maximum cap acity of 855 mmBtu/hr, this equates to 171 lb/hr. IP sites insignificant visibility improvement by meeting this standard—i.e., maximum and eighth-highest visibility improvements of only 0.08 to 0.09 dv and 0.03 to 0.04 dv, respectively.

The Department’s recently revised NO
x RACT regulation, Part 227, sets a presumptive
NO
x emission rate of 0.15 lb/mmBtu for the pow er boiler. This relates to a 128 lb/hour rate at maximum capacity. IP again sites mi nimal visibility improve ment by meeting this standard: maximum and eighth-highest vi sibility improvements of 0.17 - 0.18 dv and 0.07 dv, respectively. IP, however, is required to comply with the new 0.15 lb/mmBtu emission rate by July 1, 2014 under Part 227, and is currently conducting its required control analysis.

Based on these arguments, IP conten ds that the current maximum NO
x emission rate of 0.25 lb/mmBtu and future compliance with the Department’s NO
x RACT regulation
should be considered BART.

• PM

IP cites EPA’s upcoming ICI Boiler and Pro cess Heaters MACT standard (40 CFR 63 Subpart DDDDD), which would establish partic ulate limits applicable to the power boiler. Compliance with this upcoming MA CT is proposed as sufficient for BART compliance.5 Recovery Furnace

• SO 2

The recovery furnace at the Ticonderoga Mill processes black liquor and uses No. 6 oil as an auxiliary fuel. In gene ral, black liquor contains a significant amount of sulfur, nominally 3 to 5 percent by weight of the di ssolved solids. Operat ion of the recovery furnace, however, differs from that of conve ntional steam boilers in that the primary objective is to recover and re-use the sulfur. Proper operation of a recovery furnace itself
results in consider able control of SO 2 emissions. Additionally, this unit is a non-direct evaporation recovery furnace whic h inherently results in low SO 2 emissions. The last stack test performed on the recovery furnace revealed SO 2 emissions of less than 1 lb/hr.

The available retrofit technologies for SO 2 control from kraft mill recovery furnaces are staged combustion systems and wet scrubbers. The Ticonderoga Mill ’s recovery furnace is already equipped with a three-level staged combustion air control system. Regarding the installation of a wet scrubbing device, IP s ites the technical infeas ibility of installation downstream of the existing ESP. The r eaction products from dry scrubbing would necessitate collection in the ESP, but would contaminate the sodium sulfate (salt cake) that the ESP collects and recycles back to the pulping process.

IP also notes that only three recovery furnaces in the U.S. are equipped with wet
scrubbers in addition to ESPs, though none were installed for the purpose of SO 2 removal; instead, two were installed for h eat recovery purposes and the third was installed on a unit equipped with a direct c ontact evaporator to prevent liquid droplets from being entrained and emitted to the atmosphere. The inherent SO 2 concentration in recovery furnace flue gas is also much lowe r than that of emission units to which wet scrubbers are routinely applied (e.g., fo ssil fuel-fired steam generators).

IP proposes that existing operation of the re covery furnace through the use of three-level staged combustion air control system with ESPs be considered as BART.

• NO
x

The current permitted NO
x emission rate for the recovery furnace is 100 ppm (by volume) corrected to 8% O 2 . The majority of NO
x formed in the recovery furnace is believed to be primarily fuel NO
x due to the low temperatures in the furnace’s
combustion zone. Fuel NO
x emissions from recovery furnaces are typically low due to the low nitrogen content of black liquor solids. The furnace’s three-level staged combustion system can also be operated to minimize NO
x formation/emissions.

Due to the unique nature of recovery furnace operation, IP is able to rule out traditional boiler controls such as selective cataly tic reduction (SCR), sele ctive non-catalytic reduction (SNCR), low NO
x burners, and flue gas recirc ulation as being technically
infeasible. IP’s recommended compliance with BART for NO
x is the currently installed three-level staged combustion air control system with ESPs.6 • PM

Particulate emissions from the recovery fu rnace are currently controlled with a threechamber ESP. In addition to ESPs, IP iden tified wet scrubbers and fabric filters as potential PM controls. IP previously disc ounted the feasibility of a wet scrubber on the recovery furnace. Fabric filters have not been applied to recovery furnaces at kraft pulp
mills and are not considered to be an available control alternative.

IP notes that it complies with the Chemi cal Recovery MACT standard (40 CFR 63 Subpart MM) and that EPA states in its BART rule, “...you may rely on the MACT standards for purposes of BART” (70 FR 39164). IP therefore proposes that current PM
controls and emission levels satisfy BART.

III. BART Determination

The Department finds that the following sha ll constitute BART for the International Paper Ticonderoga Mill emission sources:

Power Boiler

• SO 2

The Department accepts that the current SO 2 permit limits of 309 lb/hr (rolling 24-hr avg.) and 435 lb/hr (rolling 3-hr avg.) represen t BART for SO 2 . IP adequately demonstrated that the existing limit compares favorably to other benchmarks, and that lowering the limit would have negligible im pact on visibility. IP’s December 2011 follow-up demonstrated that upgrades/impr ovements to the existing scrubber were technically infeasible.

It should be noted that the Department is pursuing a regulatory re vision to 6 NYCRR Part 225-1 to lower the acceptable sulfur limit in no. 6 fuel oil to 0.5 percent statewide (not including the New York City and lower H udson Valley areas, which are already subject to more stringent limits). This revision is tentatively scheduled to be effective for 2014, and may supersede proposed BART and MACT limits.

• NO
x

The Department accepts that the use of curre nt combustion control technology represents
BART for NO
x . The Department is also requir ing IP to conduct a top-down NO
x control analysis pursuant to the updated NO
x RACT limits of Part 227-2. The Department accepts the existing 0.25 lb/mmBtu NO
x emission limit as BART, and will require IP to meet the updated 0.15 lb/mmBtu NO
x emission limit by July 1, 2014, unless this
emission limit is unattainable due to technical or economic infeasibility.7 • PM

IP will be required to comply with the ICI Boiler and Pro cess Heaters MACT standard. Compliance with the final MACT emission standa rds is expected to be required in 2015. The Department deems compliance with the MACT limit as acceptable for BART. This unit is also currently subject to a pa rticulate emission limit of 0.1 lb/mmBtu.

Recovery Furnace

• SO 2

The Department finds that the staged co mbustion system and operational practices currently employed on the recovery furnace represent BART for SO 2 . Alternative control options considered by IP were determined to be technically infeasible. As noted, SO 2 emissions are inherently low from this unit; the most recent stack test revealed SO 2 emissions to be less than one pound per hour.

As discussed above, the Department is intending to revise its Part 225-1 fuel sulfur limit regulations, with a target effective date in 2014. This would reduce the recovery furnace’s no. 6 fuel sulfur content from 1.5 percent to 0.5 percent.

• NO
x

The Department accepts that the existing stag ed combustion system represent BART for
NO
x . Alternative control opti ons are considered technica lly infeasible due to the recovery furnace’s unique design. The rec overy furnace will retain its current 100 ppm
NO
x limit.

• PM

The Department accepts the current use of an ESP as BART for PM. Alternative options are considered technically infeasible. This unit complies with the Chemical Recovery MACT standard (40 CFR 63 Subpart MM) wi th a limit of 0.03 grains/dscf, which is deemed adequate for BART.