OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

MEMORANDUM October 12, 2009

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Kendal Stegmann, Senior Environmental Manager

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review, Herb Neumann/Hal Wright, ROAT

FROM: David Pollard, ROAT

SUBJECT: Evaluation of Permit Application No. 99-113-TV (M-9) Georgia-Pacifi c Consumer Products LP Muskogee Mill 4901 Chandler Road, Muskogee Section 33 & W1/2 Section 34, T15N, R19EIM Muskogee County, OK (Lat. 35.741; Long. -95.305) Directions: Muskogee Turnpike to Chandler Exit, East to 45 th Street, South to Harold Abitz Drive, East into facility.

SECTION I. INTRODUCTION

Georgia-Pacific Consumer Products LP (applicant) has submitted an application dated May 6, 2009 and received May 7, 2009 by the Department of Environmental Quality, Air Quality Division (AQD), for a Tier I, minor modification to the operating permit. This request amounts to a simple change of the compliance reporting periods and due dates that are currently tied to the anniversary date of the Title V permit, so th at the permittee can time their process of data gathering and compilation with the due dates of the Annual Compliance Certification and the Semi-Annual Monitoring and Deviation Report. There is no physical change, no change in operations, or no change resulting in emissions, asso ciated with this modification to the permit. The mill is an existing major ma nufacturer and converter of san itary paper products such as tissue, napkins, and paper towels (SIC 2621). Auxiliary operations include flexographic printing, platemaking, and production polyethylene film wrap for the paper products.

The applicant owns and operates the Georgia-Pa cific Consumer Products LP, Muskogee Mill, an existing major manufacturer and conv erter of sanitary pa per products such as tissue, napkins, and paper towels (SIC 2621, paper mills) at the above location. Auxiliary operations include flexographic printing, platemaking, and production polyethylene film wrap for the paper products.

The facility began construction in 1975 and has been in operation si nce 1978. The Title V permit incorporated all effective permit conditions. The facility is currently operating under the originalPERMIT MEMORANDUM 99-113-TV (M-9) 2

Title V permit, No. 99-113-TV and a construction permit, No. 99-113-C (M-3) (PSD), issued as a “Mill Process Improvement Project”. When completed, the project will affect three areas of the plant and is intended to improve energy effi ciency, to allow for papermaking with lower grades of wastepaper, and to reduce dependence on outside vendors of pack aging material. The three areas affected are the paper machine and converting area, the poly ethylene plant, and the System 5 Pulp area. Increased emissions from th is project are expected to trigger Prevention of Significant Deterioration (PSD) si gnificance levels, re quiring full PSD analysis , including Tier II permitting, modeling, and BACT analysis. Perm it No. 99-113-C (M-4) (PSD) was then issued
for clarification of several cond itions of Permit No. 99-113-C (M-3) (PSD). These clarifications did not relax any permit conditions, did not auth orize additional emitting equipment, and did not increase permitted emission amounts. Since the construction work is still ongoing, no further discussion of the construction permit is included in this memorandum or permit.

SECTION II. PROCESS DESCRIPTION

The facility is a major manu facturer and converter of sanitary paper products, i.e., they make parent rolls and they also make finished products such as tissue, napkins, and paper towels. Many of these products are printed with decorative inks durin g the converting process. The main processes involved in papermaking are pulping, de-inking (bl eaching out the inks in th e recycled paper), paper production, and printing. The company’s basic raw material fo r wet papermaki ng is currently recycled wastepaper and a small amount of purchased pulp, which is processed into pulp using a proprietary process. The facility ty pically recycles over a thousand to ns of wastepaper per day. The applicant has indicated that future products may be made from other sources of fiber. Since this may result in different emissions from the material s or the use of different additives and also the applicability of add itional regulations and/or MACT standards, the facil ity will need to evaluate
these issues to de termine the ne eds for submitting a pe rmit application.

Pulping and Pulp Processing The derivation, rationale, and technical justificati on for the emission calculations are presented in
the section for emissions. Follow ing is a description of the equipm ent used in the pulping process.

Pulpers - Use mechanical agitation and water to convert wastepaper to a pulp slurry. Stock Blend Tank - Used to blend pulp. Screens - Separate solid contam inants from th e pulp slurry. Washers - Separate solid contam inants from the pulp slurry.
Stock Presses - Used to de water the pulp slurry an d increase consistency. Mixer - Used to mix the pulp slurry with proc ess water, dilution water, chemicals, etc.
Flotation Cell Washers - Remove soli d contaminants from the pulp slurry. Cleaners - Remove solid particle contaminants.
Bleach Towers - Provide residence time to allow th e bleach medium to reac t with the pulp slurry.
Thickeners - Used to increas e pulp slurry consistency.

The pulping and pulp processing sy stems process and bleac h wastepaper for use in the manufacture of tissue, towel, and napkin paper. This proprietary process uses bleaching agents on most grades of paper. Recycled wastepaper is re-pulped by physical and chemical processes into a pulp slurry toPERMIT MEMORANDUM 99-113-TV (M-9) 3

recover usable fiber, blended w ith various de-inking and bleaching compounds, and processed into paper stock to make the paper products. At the pulpers, recycled wastepaper is blended with hot water while mechanical agitation is used to convert the mixture into pulp slurry. Generally, the incoming slurry is screened to remove debris and impurities. C ontaminants are removed in this step, as well. Additional contam inant removal is accomplished by me ans of processes performed by other equipment described above. Bleaching agen ts are added to the slurry for the purpose of increasing brightness. The facility uses no chlorine or chlorine diox ide to bleach pul p. As noted in the permit chronology above, the ch lorine dioxide plant was not constructed. Bleached pulp is stored in storage tanks for later use on paper machin es to make paper. VOCs and organic pollutants are released during pulp processing as a re sult of chemical and me chanical processes.

The Low Consistency Washers aerate the pulp slur ry, which results in bu bbles on top of the material. A rotating vacuum arm removes the bub bles from the top of th e material and into a separator where liquids and vapors are separated. The vent from the No. 2 flotation unit vacuum system was tested by The National Council for Air and Stream Improvement (NCASI). The vapors are vented to the atmosphe re. Two vented bleaching towers were also tested by NCASI. The applicant has indicated that bleach ing agents and aids other than th ose currently used, may be used
in PP-1 in the future. The fac ility will need to eval uate emission impacts to determine permitting requirements.

Paper Production The processed secondary pulp fiber is pumped to the paper machines, PM-11, PM-12, PM-13, PM14, and PM-15, where the parent roll s are produced. Much of this paper is converted to finished product at the facility. Water is removed from the incoming pulp stock by a screen. The pulp is then sprayed onto a belt where a vacu um is pulled from below to remove additional water. Residual moisture is removed from the pro duced paper as it is dried in th e Yankee Dryers by steam and/or fuel-burning hoods. These drying processes result in emissions of VOCs from the pulp and paper. Natural gas is the primary fuel and propane, as me ntioned earlier, was designated in an application submitted on December 1, 2000, as a secondary fuel. PM -11 and PM-12 have af ter-dryers that use steam from the po wer plant. Combustion emissions an d some additional VOC emissions are generated from the fuel-burning processes. Emissions were measured from building vents and equipment vents for PM-12 and PM-14 by NCASI. Additional emissions from the additives incorporated into the process subs equent to the NCASI testing are es timated by the ap plicant to be 60% of the VOC content, with 20% retained in wastewater and th e other 20% is consumed (i.e., used up or reacts with latex contam inants). These values are based on testing done at other facilities. Following is a descripti on of each paper machine.

PM-11 is a 209-inch, wet crepe/dry crepe twin-wir e periformer, manufactured by KMW, with a suction forming roll, single-felted press sectio n, two pressure rolls, an 18-foot Yankee dryer equipped with two 24 MMBTUH gas- fired hoods, and five after-dryers. No. 2 fuel oil and propane can be used as backup fuels. Th e stock system is conv entional, utilizing a dr um save-all for fiber recovery and an air flotation clarifier for water recycling.
PM-12 is a 209-inch, wet crepe twin-wire periform er, manufactured by KMW, with a suction forming roll, single-felted press s ection, two pressure rolls, an 18 -foot Yankee dryer equipped with two 16.5 MMBTUH gas-fired hoods, and fourteen after-dryers. No. 2 fuel oil and propane can bePERMIT MEMORANDUM 99-113-TV (M-9) 4

used as backup fuels. The stock system is conventional, utilizing a drum save-a ll for fiber recovery
and an air flotation clarif ier for water recycling.

PM-13 is a 209-inch, wet crepe/dry crepe S-wrap twin-wire periformer, manufactured by KMW, with a solid forming roll, single-felted press section, two pres sure rolls, an 18-foot Yankee dryer equipped with two burners rated at 16.5 MMBTUH gas-fired hoods, and eight after-dryers. No. 2 fuel oil and propane can be used as backup fuels. Th e stock system is conv entional, utilizing a drum save-all for fiber recovery and an ai r flotation clarifier for water recycling.

PM-14 is a 271-inch, dry crepe twin -wire periformer, manuf actured by Beloit, w ith a solid forming roll, single-felted press section, two pressure rolls, and an 18-f oot Yankee dryer equipped with two 24 MMBTUH gas-fired hoods. No. 2 fuel oil can be used as a backup fuel. The stock system is conventional, utilizing a drum save -all for fiber recovery and an ai r flotation clarifier for water recycling.

PM-15 is a 273-inch, dry crepe twin -wire periformer, manuf actured by Beloit, w ith a solid forming roll, single-felted press section, two pressure rolls, and an 18-f oot Yankee dryer equipped with two 25 MMBTUH gas-fired hoods and hi gh temperature hot wate r. The stock system is conventional, utilizing a disc save-all for fibe r recovery and an ai r flotation clarifier for water recycling.

Emissions were measured from Pa per Machine Nos. 12 and 14 by NC ASI. Emission measurements for Paper Machine No. 12 were ta ken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum Systems Vent, the After Dryer Vent No. 1, the Yankee Drye r Vent, and the After Dryer Vent No. 2. Emission measurements for Paper Machine No. 14 were taken at the Fan Pump Silo Vent, the Yankee Wet-Side Dryer, the Yankee Dry-Side Drye r, the Vacuum Systems Vent, and the Wet End
Roof Vents.

The table below summarizes the equipment used in each system line and the point of entry in the process for additives in the order they are utilized. Items in italics represent chemic al additives and
items in bold represent emission units th at were tested by NCASI.

Process Flow – Paper Machines

PM-11 PM-12 PM-13 PM-14 PM-15 Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific)

Sheet Texture (Grade Specific) Sheet Texture (Grade Specific)

Machine Chest Machine Chest Machine Chest Machine Chest Charge Control Dry Strength (Grade Specific) Dry Strength (Grade Specific) Dyes (Grade Specific) Dyes (Grade Specific) Dyes (Grade Specific) Dyes (Grade Specific Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific)PERMIT MEMORANDUM 99-113-TV (M-9) 5

PM-11 PM-12 PM-13 PM-14 PM-15

Flow Box Flow Box Flow Box Flow Box Flow Box

Biocide Biocide Biocide Biocide Biocide Defoamer Defoamer Defoamer Defoamer Defoamer

Silo Silo Silo Silo Silo

Wire

Passivation Wire Passivation (Normally off) Wire Passivation Wire Passivation Wire Passivation

Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Solvent (As Needed) Solvent (As Needed) Solvent (As Needed) Solvent (As Needed) Solvent (As Needed)

Felt Cleaner Felt Cleaner Felt Cleaner Felt Cleaner

Wires & Felt Wires & Felt Wires & Felt Wires & Felt Wires & Felt Yankee Coating Yankee Coating Yankee Coating Yankee Coating Yankee Coating

Yankee Release Yankee Release Yankee Release Yankee Release Yankee Release Yankee Dryer Yankee Dryer Yankee Dryer Yankee Dryer Yankee Dryer Charge
Additive Charge Additive Charge Additive Charge Additive

Polymer Polymer Polymer Polymer Krofta (part of water system) Krofta (part of water system) Krofta (part of water system) Krofta (part of water system) Krofta (part of water system)

Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed)

Acid Felt Cleaner (As Needed) Acid Felt Cleaner (As Needed)

Felt
Guardboard Felt Guardboard Felt Guardboard

Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system)

Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) After Dryers After Dryers After Dryers Slimicide (Batch Use)

White Water Tanks (Part of water system)

Vacuum System (not Vacuum System (not part of the Vacuum System (not part of the Vacuum System (not part of the Vacuum System (not part of thePERMIT MEMORANDUM 99-113-TV (M-9) 6

PM-11 PM-12 PM-13 PM-14 PM-15 part of the
direct flow of paper) direct flow of paper) direct flow of paper) direct flow of paper) direct flow of paper)

Wet End Roof Vents (not in the
direct flow of paper)

Solvent Cleaning of Paper Machines
SC-1 is the designation of emissions generated from solvent cleanup of the paper machine clothing (felts and wires). Cleanup solven t is pumped from tanks or totes to paper machines PM-11, PM-12, PM-13, PM-14, and PM-15 for application on the ma chine clothing. The purpose of this cleanup is to rid the machine clothing of any contaminants , commonly known as s tickies, which may be deposited from the paper stock going to the machin es. These contaminants would adversely affect product from the machine by formi ng small holes or creating inconsistencies in the paper if not cleaned regularly. Additionally, smaller amounts of solvent are used occasionally for cleaning equipment at the pulp processing mill, PP-1.

Flexographic Paper Printing Designs are printed on the tissue products by fl exographic paper printer systems FP-1 and FP-7. Both systems use water-based inks for printing. At the time of the inspection, it was stated that the
inks contain less than 0.03 % VOCs by weight content.

FP-1 consists of six flexographic printing presses th at print paper parent rolls to produce printed parent rolls. These printed parent rolls become paper towel and napkin products.

FP-7 is a 101.5-inch, four color, in -line flexographic printing press and re-winder that also prints paper parent rolls to produce printed to wel products at th e end of the unit.

FP-8 is a 4-color, 78-inch wide, flexographic printing press, manu factured by Bretting. It was
custom built and has no number. FP-8 is situ ated in Building No. 31 and was in operation by
June of 2005.

Polyethylene Extruding and Flexographic Printing (polyethylene film) The polyethylene extruder, the plate-making r oom, and the flexographic printing room are all housed in the Poly Plant Building. Flexo-plate making is conducted in the plate-making ro om. The plates are produced for use with all of the mill plant’s flexographic printers. VOC-c ontaining solvents are used in the finishing step of plate-making. VOC emissions from a plate wa shing process are discharged from the building through a horizontal vent. A sma ller amount of fugitives leave the room through two door openings into the Poly Plant build ing. The Poly Plant building has numer ous vents, the most prominent being three 5’ x 5’ exhaust vents down the center-line peakof the building roof. These vents have hingedflap rain caps which result in some what of a horizontal discharge. Some of the solvent is recovered and recycled.PERMIT MEMORANDUM 99-113-TV (M-9) 7

PO-1 is the designation of the polyethylene extruding plant. The paper products are ultimately wrapped with polyethylene over-wrap and other materials, pack aged, and distributed to customers. Plastic over-wrap is produced on-site from the polyethylene and extruding plant. Polyethylene pellets, stored in silos, are pn eumatically conveyed to the extrud er. The extruder produces a polyethylene tube which is elongated by take-off ni p rollers, air cooled, solidified, passed through a corona treater, and wound onto takeoff rolls. Ozone generated in the corona treating process is discharged through a horiz ontal vent. Once a full roll is produ ced, it is taken from the takeoff roll, rewound into rolls of unprinted polyethylene film, and stored in the same building until needed for printing.

Flexographic printing of the polyethylene film is conducted in the fl exographic printing room. The polyethylene rolls are fed into a six-color, central impression flexographic printing press and dried through the tunnel dr yer to produce printed parent rolls of polyethylene film. The finished
rolls are stored and tran sferred to locations with in the facility where the product may be needed. Emissions from the plant are solvent and ink VO Cs and combustion produc ts from the catalytic oxidation incinerator and the dryer. The applicant has estimated that approximately 70% of the VOCs from the solvent and inks are captured by the recovery hood and discharged into an incinerator, and the remaining 30% of the VOCs leave the room through large openings into the main building and are ultimately discharged through the three main exhaust vents located on the roof. The incinerator temperatur e is monitored before and afte r exposure to the catalyst media and recorded daily. The inlet gas temperature shall be continuously monitored by a shutdown switch that will shut down the press should the temperature drop below 550 ° F. To document proper operation, the permittee is required to reco rd the before (Thermocouple T/C 1) and after (Thermocouple T/C 2) cataly tic cell temperature daily.

Steam and Electricity Co-generation (power plant) The facility has a power pl ant utilizing four boilers , identified as em ission units B-1, B-2, B-3, and B-4, which co-generate mo st of the electrical and steam needs of the facility. They are fueled by
coal and other fossil fuels. Th e ash residue generated from this operation is landfilled in an approved on-site landfill. Opacity of the boiler emissions is moni tored continuously and recorded by the use of strip charts. Following is a description of each boiler.

B-1 is primarily a natural gas-fired package boiler rated at 310 MMBTUH. It is capable of firing No. 2 fuel oil as a backup fuel. The unit co-generates steam and electricity for use on-site. It shares
a common stack with boiler B-2.

B-2 is primarily a pulverized coal-fired boiler rated at 440 MMBTUH. It is capable of firing natural gas and No. 2 fuel oil as backup fuels. The unit co -generates steam and electr icity for use on-site. It uses an electrostatic precipitator for particulate control and shares a comm on stack with boiler B-1.

B-3 is primarily a pulverized coal -fired boiler rated at 557.11 MMBT UH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse fo r particulate control and shares a common stack with boiler B-4.PERMIT MEMORANDUM 99-113-TV (M-9) 8

B-4 is primarily a pulverized coal -fired boiler rated at 557.11 MMBT UH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse fo r particulate control and shares a common stack with boiler B-3.

Emergency Backup Power Generators The facility has two emer gency backup power gene rators used only for emergency power in the event of a complete power loss. Otherwise they are operated only for pe riodic capab ility tests.

DG-1 is a 1,200 KW, Marathon Electr ic, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/20, with a diesel-fueled Ca terpillar engine, Se rial # 24Z00499.

DG-2 is a 1,200 KW, Marathon Electr ic, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/13, with a diesel-fueled Ca terpillar engine, Se rial # 24Z00501.

Coal Preparation Plant The coal preparation plant supplies the boilers with pulverized coal fuel. All emission units except the coal pile and preceding unloading/co nveying equipment are subject to the provisions of 40 CFR, Part 60, Subpart Y, “Standards of Perf ormance for Coal Preparation Plants.” Initial performance testing was completed. Subpart Y does not contain monitoring requirements. More detail on the applicability criteria is f ound in the NSPS discussion of Section VIII.

Coal Storage
Coal fuel used in the boilers is stored in an ou tdoor storage pile (FS-1) prior to processing into pulverized coal. Solid, bituminous and sub-bituminous coal is de livered by railcar and unloaded into a below-grade receiving bin. Some coal is also occasionally receiv ed by truck and unloaded into the coal pile. A conveyor moves the coal from the receiving bin to a radial stacker. The
radial stacker unloads the coal into an aboveground stockpile.

Coal Processing and Conveying Equipment A front-end loader is then used to transfer coal from the storage stockpile to the grizzly feeder. A conveyor transfers the coal from the grizzly feeder to the sizer /crusher for sizing, which also separates debris such as rocks. Except fo r the outlet chute opening to the conveyor, the
sizer/crusher is enclosed and housed in a small building. There are openings on two sides of the building for the ingoing and outgoing conveyors. From the sizer/crusher, a conveyor transfers
the sized coal to the coal bunkers ahead of the coal feeders, which in turn feed the pulverizers and subsequently the boilers. Th e coal feeders and pulverizers are enclosed processes. Dust suppression systems are located at the railcar unloading, the grizzly feeder, and the sizer/crusher.

Wastewater Treatment Plant The facility also operates its own wastewater treatment plant consisting of primary and secondary treatment stages. The majority of the solid wastewater residues are landfilled on-site.

PM-11 is a 209-inch, wet crepe/dry crepe twin-wir e periformer, manufactured by KMW, with a suction forming roll, single-felted press sectio n, two pressure rolls, an 18-foot Yankee dryer equipped with two 24 MMBTUH gas- fired hoods, and five after-dryers. No. 2 fuel oil and propanePERMIT MEMORANDUM 99-113-TV (M-9) 9

can be used as backup fuels. Th e stock system is conv entional, utilizing a dr um save-all for fiber recovery and an air flotation clarifier for water recycling.

PM-12 is a 209-inch, wet crepe twin-wire periform er, manufactured by KMW, with a suction forming roll, single-felted press s ection, two pressure rolls, an 18 -foot Yankee dryer equipped with two 16.5 MMBTUH gas-fired hoods, and fourteen after-dryers. No. 2 fuel oil and propane can be used as backup fuels. The stock system is conventional, utilizing a drum save-a ll for fiber recovery
and an air flotation clarif ier for water recycling.

PM-13 is a 209-inch, wet crepe/dry crepe S-wrap twin-wire periformer, manufactured by KMW, with a solid forming roll, single-felted press section, two pres sure rolls, an 18-foot Yankee dryer equipped with two burners rated at 16.5 MMBTUH gas-fired hoods, and eight after-dryers. No. 2 fuel oil and propane can be used as backup fuels. Th e stock system is conv entional, utilizing a drum save-all for fiber recovery and an ai r flotation clarifier for water recycling.

PM-14 is a 271-inch, dry crepe twin -wire periformer, manuf actured by Beloit, w ith a solid forming roll, single-felted press section, two pressure rolls, and an 18-f oot Yankee dryer equipped with two 24 MMBTUH gas-fired hoods. No. 2 fuel oil can be used as a backup fuel. The stock system is conventional, utilizing a drum save -all for fiber recovery and an ai r flotation clarifier for water recycling.

PM-15 is a 273-inch, dry crepe twin -wire periformer, manuf actured by Beloit, w ith a solid forming roll, single-felted press section, two pressure rolls, and an 18-f oot Yankee dryer equipped with two 25 MMBTUH gas-fired hoods and hi gh temperature hot wate r. The stock system is conventional, utilizing a disc save-all for fibe r recovery and an ai r flotation clarifier for water recycling.

Emissions were measured from Pa per Machine Nos. 12 and 14 by NC ASI. Emission measurements for Paper Machine No. 12 were ta ken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum Systems Vent, the After Dryer Vent No. 1, the Yankee Drye r Vent, and the After Dryer Vent No. 2. Emission measurements for Paper Machine No. 14 were taken at the Fan Pump Silo Vent, the Yankee Wet-Side Dryer, the Yankee Dry-Side Drye r, the Vacuum Systems Vent, and the Wet End
Roof Vents.

The table below summarizes the equipment used in each system line and the point of entry in the process for additives in the order they are utilized. Items in italics represent chemic al additives and
items in bold represent emission units th at were tested by NCASI.

PM-11 PM-12 PM-13 PM-14 PM-15 Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific) Wet Strength Resin (Grade Specific)

Sheet Texture (Grade Specific) Sheet Texture (Grade Specific)

Machine Chest Machine Chest Machine Chest Machine Chest Charge Control Dry Strength (Grade Specific) Dry Strength (Grade Specific) Dyes (Grade Dyes (Grade Dyes (Grade Dyes (GradePERMIT MEMORANDUM 99-113-TV (M-9) 10

PM-11 PM-12 PM-13 PM-14 PM-15 Specific) Specific) Specific) Specific Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific) Absorbency Aid (Grade Specific)

Flow Box Flow Box Flow Box Flow Box Flow Box

Biocide Biocide Biocide Biocide Biocide Defoamer Defoamer Defoamer Defoamer Defoamer

Silo Silo Silo Silo Silo

Wire

Passivation Wire Passivation (Normally off) Wire Passivation Wire Passivation Wire Passivation

Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Inner & Outer
Wire Solvent (As Needed) Solvent (As Needed) Solvent (As Needed) Solvent (As Needed) Solvent (As Needed)

Felt Cleaner Felt Cleaner Felt Cleaner Felt Cleaner

Wires & Felt Wires & Felt Wires & Felt Wires & Felt Wires & Felt Yankee Coating Yankee Coating Yankee Coating Yankee Coating Yankee Coating

Yankee Release Yankee Release Yankee Release Yankee Release Yankee Release Yankee Dryer Yankee Dryer Yankee Dryer Yankee Dryer Yankee Dryer Charge
Additive Charge Additive Charge Additive Charge Additive

Polymer Polymer Polymer Polymer Krofta (part of water system) Krofta (part of water system) Krofta (part of water system) Krofta (part of water system) Krofta (part of water system)

Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed) Caustic Felt Cleaner (As Needed)

Acid Felt Cleaner (As Needed) Acid Felt Cleaner (As Needed)

Felt
Guardboard Felt Guardboard Felt Guardboard

Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system) Dye Neutralizer (Grade Specific & part of water system)

Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) Chlorine Neutralizer (Grade Specific & part of water system) After Dryers After Dryers After Dryers Slimicide (Batch Use)PERMIT MEMORANDUM 99-113-TV (M-9) 11

PM-11 PM-12 PM-13 PM-14 PM-15

White Water Tanks (Part of water system)

Vacuum System (not part of the
direct flow of paper) Vacuum System (not part of the
direct flow of paper) Vacuum System (not part of the
direct flow of paper) Vacuum System (not part of the
direct flow of paper) Vacuum System (not part of the
direct flow of paper)

Wet End Roof Vents (not in the
direct flow of paper)

Solvent Cleaning of Paper Machines
SC-1 is the designation of emissions generated from solvent cleanup of the paper machine clothing (felts and wires). Cleanup solven t is pumped from tanks or totes to paper machines PM-11, PM-12, PM-13, PM-14, and PM-15 for application on the ma chine clothing. The purpose of this cleanup is to rid the machine clothing of any contaminants , commonly known as s tickies, which may be deposited from the paper stock going to the machin es. These contaminants would adversely affect product from the machine by formi ng small holes or creating inconsistencies in the paper if not cleaned regularly. Additionally, smaller amounts of solvent are used occasionally for cleaning equipment at the pulp processing mill, PP-1.

Flexographic Paper Printing Designs are printed on the tissue products by fl exographic paper printer systems FP-1 and FP-7. Both systems use water-based inks for printing. At the time of the inspection, it was stated that the
inks contain less than 0.03 % VOCs by weight content.

FP-1 consists of six flexographic printing presses th at print paper parent rolls to produce printed parent rolls. These printed parent rolls become paper towel and napkin products.

FP-7 is a 101.5-inch, four color, in -line flexographic printing press and re-winder that also prints paper parent rolls to produce printed to wel products at th e end of the unit.

FP-8 is a 4-color, 78-inch wide, flexographic printing press, manu factured by Bretting. It was
custom built and has no number. FP-8 is situ ated in Building No. 31 and was in operation by
June of 2005.

Polyethylene Extruding and Flexographic Printing (polyethylene film) The polyethylene extruder, the plate-making r oom, and the flexographic printing room are all housed in the Poly Plant Building.

Flexo-plate making is conducted in the plate-making ro om. The plates are produced for use with all of the mill plant’s flexographic printers. VOC-c ontaining solvents are used in the finishing step of plate-making. VOC emissions from a plate wa shing process are discharged from the building through a horizontal vent. A sma ller amount of fugitives leave the room through two door openingsPERMIT MEMORANDUM 99-113-TV (M-9) 12

into the Poly Plant build ing. The Poly Plant building has numer ous vents, the most prominent being three 5’ x 5’ exhaust vents down the center-line peakof the building roof. These vents have hingedflap rain caps which result in some what of a horizontal discharge. Some of the solvent is recovered and recycled.

PO-1 is the designation of the polyethylene extruding plant. The paper products are ultimately wrapped with polyethylene over-wrap and other materials, pack aged, and distributed to customers. Plastic over-wrap is produced on-site from the polyethylene and extruding plant. Polyethylene pellets, stored in silos, are pn eumatically conveyed to the extrud er. The extruder produces a polyethylene tube which is elongated by take-off ni p rollers, air cooled, solidified, passed through a corona treater, and wound onto takeoff rolls. Ozone generated in the corona treating process is discharged through a horiz ontal vent. Once a full roll is produ ced, it is taken from the takeoff roll, rewound into rolls of unprinted polyethylene film, and stored in the same building until needed for printing.

Flexographic printing of the polyethylene film is conducted in the fl exographic printing room. The polyethylene rolls are fed into a six-color, central impression flexographic printing press and dried through the tunnel dr yer to produce printed parent rolls of polyethylene film. The finished
rolls are stored and tran sferred to locations with in the facility where the product may be needed. Emissions from the plant are solvent and ink VO Cs and combustion produc ts from the catalytic oxidation incinerator and the dryer. The applicant has estimated that approximately 70% of the VOCs from the solvent and inks are captured by the recovery hood and discharged into an incinerator, and the remaining 30% of the VOCs leave the room through large openings into the main building and are ultimately discharged through the three main exhaust vents located on the roof. The incinerator temperatur e is monitored before and afte r exposure to the catalyst media and recorded daily. The inlet gas temperature shall be continuously monitored by a shutdown switch that will shut down the press should the temperature drop below 550 ° F. To document proper operation, the permittee is required to reco rd the before (Thermocouple T/C 1) and after (Thermocouple T/C 2) cataly tic cell temperature daily.

Steam and Electricity Co-generation (power plant) The facility has a power pl ant utilizing four boilers , identified as em ission units B-1, B-2, B-3, and B-4, which co-generate mo st of the electrical and steam needs of the facility. They are fueled by
coal and other fossil fuels. Th e ash residue generated from this operation is landfilled in an approved on-site landfill. Opacity of the boiler emissions is moni tored continuously and recorded by the use of strip charts. Following is a description of each boiler.

B-1 is primarily a natural gas-fired package boiler rated at 310 MMBTUH. It is capable of firing No. 2 fuel oil as a backup fuel. The unit co-generates steam and electricity for use on-site. It shares
a common stack with boiler B-2.

B-2 is primarily a pulverized coal-fired boiler rated at 440 MMBTUH. It is capable of firing natural gas and No. 2 fuel oil as backup fuels. The unit co -generates steam and electr icity for use on-site. It uses an electrostatic precipitator for particulate control and shares a comm on stack with boiler B-1.PERMIT MEMORANDUM 99-113-TV (M-9) 13

B-3 is primarily a pulverized coal -fired boiler rated at 557.11 MMBT UH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse fo r particulate control and shares a common stack with boiler B-4.

B-4 is primarily a pulverized coal -fired boiler rated at 557.11 MMBT UH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse fo r particulate control and shares a common stack with boiler B-3.

Emergency Backup Power Generators The facility has two emer gency backup power gene rators used only for emergency power in the event of a complete power loss. Otherwise they are operated only for pe riodic capab ility tests.

DG-1 is a 1,200 KW, Marathon Electr ic, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/20, with a diesel-fueled Ca terpillar engine, Se rial # 24Z00499.

DG-2 is a 1,200 KW, Marathon Electr ic, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/13, with a diesel-fueled Ca terpillar engine, Se rial # 24Z00501.

Coal Preparation Plant The coal preparation plant supplies the boilers with pulverized coal fuel. All emission units except the coal pile and preceding unloading/co nveying equipment are subject to the provisions of 40 CFR, Part 60, Subpart Y, “Standards of Perf ormance for Coal Preparation Plants.” Initial performance testing was completed. Subpart Y does not contain monitoring requirements. More detail on the applicability criteria is f ound in the NSPS discussion of Section VIII.

Coal Storage
Coal fuel used in the boilers is stored in an ou tdoor storage pile (FS-1) prior to processing into pulverized coal. Solid, bituminous and sub-bituminous coal is de livered by railcar and unloaded into a below-grade receiving bin. Some coal is also occasionally receiv ed by truck and unloaded into the coal pile. A conveyor moves the coal from the receiving bin to a radial stacker. The
radial stacker unloads the coal into an aboveground stockpile.

Coal Processing and Conveying Equipment A front-end loader is then used to transfer coal from the storage stockpile to the grizzly feeder. A conveyor transfers the coal from the grizzly feeder to the sizer /crusher for sizing, which also separates debris such as rocks. Except fo r the outlet chute opening to the conveyor, the
sizer/crusher is enclosed and housed in a small building. There are openings on two sides of the building for the ingoing and outgoing conveyors. From the sizer/crusher, a conveyor transfers
the sized coal to the coal bunkers ahead of the coal feeders, which in turn feed the pulverizers and subsequently the boilers. Th e coal feeders and pulverizers are enclosed processes. Dust suppression systems are located at the railcar unloading, the grizzly feeder, and the sizer/crusher.

Wastewater Treatment Plant The facility also operates its own wastewater treatment plant consisting of primary and secondary treatment stages. The majority of the solid wastewater residues are landfilled on-site.PERMIT MEMORANDUM 99-113-TV (M-9) 14

SECTION III. EQUIPMENT

The following tables list the Emission Units (EUs) at the facility that contribute to a process that generates significant emissions. The tables are categorized by Emission Unit Groups (EUGs), based on the type of emission and/or an applicable rule. The application states that the date of construction is either the approximate date the company commenced construction of the particular process, or the date of the last modification of the process for which the company obtained an air permit under la ws existing at that time.

EUG 1 – Subpart D Boilers

EUG 1 includes boilers that are subject to 40 CFR Part 60, Subpart D, “Standards of
Performance for Fossil-Fuel-Fired Steam Gene rators for Which Construction is Commenced After August 17, 1971.”

EUG 1 – Subpart D Boilers

EU

ID Boiler Manufacturer Boiler Rating (MMBtu/hr) Burner Model Construct

Date

B-1 Zurn Industires, Inc. 310 Keystone
SAOH-MJ-DAR-48 1975

B-2 Babcock & Wilcox Company 440 BW-24089 1975

B-3 Combustion Engineering, Inc. 557.11 VU-40 1978

B-4 Riley Stoker 557.11 RX Turbofurnace 1981

EUG 2 – Combustion Sources No t Subject to NSPS or NESHAP

EUG 2 includes emission units that have combus tion emissions not subj ect to an NSPS or a NESHAP performance standard.

EUG 2 – Combustion Sources No t Subject to NSPS or NESHAP
EU ID EU Name Model # Burner
Manuf. Burner Rating (MMBTUH) Construction

Date

PM-11 Paper Machine #11 Kinedizer 27M Maxon 2 x 24 1975

PM-12 Paper Machine #12 Oven-Pak EB6
Model 400 Maxon 2 x 16.5 1975

PM-13 Paper Machine #13 Oven-Pak EB6
Model 400 Maxon 2 x 16.5 1979

PM-14 Paper Machine #14 Combustifume Maxon 2 x 24 1981

PM-15 Paper Machine #15 LV-85 Maxon 2 x 25 1992

PO-1 Printing Press Tunnel Dryer Oven-Pak EB3 Maxon 2.0 1983PERMIT MEMORANDUM 99-113-TV (M-9) 15

PO-1 Catalytic Oxidizing
Incinerator HXC II - 400 2.0 1983

EU ID EU Name/ Model Power Output Construction

Date
DG-1 Marathon Electric, Magna One 1,200 KW 1982

DG-2 Marathon Electric, Magna One 1,200 KW 1982

EUG 3 –Coal Preparation Plant

EUG 3 consists of the Coal Preparation Plant and includes all emission units subject to the provisions of 40 CFR, Part 60, Subpart Y, “S tandards of Performance for Coal Preparation Plants,” which include coal processing and conveying equipment (including breakers and crushers) and coal storage systems in coal prepar ation plants that process more than 200 tons per day, as well as emission units not subject to Subp art Y. The railcar unloading and radial stacker preceding the coal pile are not subject to the standards.

EUG 3 – Coal Preparation Plant
EU ID EU Name Manufacturer/Model# Construct

Date Railcar Unloading FEECO 1991, est.

Radial Stacker FEECO 1991, est.
FS-1 Coal Pile Open Pile – Not Applicable 1975 Grizzly Feeder FEECO / Fairfield 1991, est.

Coal Sizer/Crusher Gundl ach / Model#56-DA-1294 1977, est. Conveyor Fort Howard (Ma nufactured on-site while Mill was owned by Fort Howard) 1977, est.

B-2 Coal Bunkers B&W 1975, est.

B-2 Coal Feeders Stock Equipment Co./ Gravimetric Feeder 1975, est.

B-2 Pulverizers B&W / EL50 Ball Mill 1975, est.

B-3 Coal Bunkers CE 1978, est.

B-3 Coal Feeders Stock Equipment C o. / Gravimetric Feeder 1978, est.

B-3 Pulverizers CE / Bowl Mill 533ARB 1978, est.

B-4 Coal Bunkers Riley 1981, est.

B-4 Coal Feeders Merrick / Coalometer 1981, est.

B-4 Pulverizers Riley / 556 Hammer Mill 1981, est.

EUG 4 – PP-1 Pulp Processing Units (Subpa rt S Affected/No Applicable Standards)

EUG 4, PP-1 Pulp Processing Units, emits VOCs fr om the bleaching and pulping processes. Some of these units are affected processes unde r 40 CFR Part 63, Subpart S, “National Emission
Standards for Hazardous Air Pollutants from the Pu lp and Paper Industry,” but are not subject to any performance standard or other requirements at this time because of the type of bleaching agents currently used in the pulping process. Th e facility uses second ary wood (recycled paper)
fiber and is therefore an affected facility. However, as a resu lt of the processes and bleachingPERMIT MEMORANDUM 99-113-TV (M-9) 16

chemicals used in producing the secondary fiber pulp, there are no standard s in the subpart that currently apply to the facility. Therefore, this EUG is rese rved for any future Subpart S regulated units. Emissions from these units we re subject to OAC 252:100-41 at the time of the public draft permit. As detailed in later s ections of this memorandum, Part 5 of OAC 252:100- 41, which deals with the toxic air contaminants, has been re placed by OAC 252:100-42. These
units have a VOC limit and are included with EUG 6.

EUG 5 – Subpart KK Flexographic Printing

EUG 5 includes emission units that have flexog raphic printing presses a nd auxiliary equipment subject to 40 CFR Part 63, Subpart KK, “Nat ional Emission Standards for the Printing and Publishing Industry.”

EUG 5 – Subpart KK Flexographic Printing

EU

ID EU Name Manufacturer/Model No. Construct

Date PO-1 Flexographic Polyethylene Prin ter Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer June, 1984

FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper Printer Fl exo #7 – PCMC/Model No. 6725 1997 FP-8 Flexographic Polyethylene Printer Bre tting, 4-color, 78-inch wide June, 2005

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

EUG 6 includes emission units that are subject to a VOC limit or may potentially be subject to
OAC 252:100-42. It include s units that are part of the pa per making process, having VOC or HAP emissions and not subject to Subpart S (PP-1 Pulp Processi ng Units are affected but not subject to standards at this time), units not subject to an NSPS or NESHAP performance standard, and units subject to an NSPS or NE SHAP performance standard but emitting VOC pollutants not covered by the standard (such as the flexographic printers). A Flexographic Polyethylene Extruder, Glouces ter Engineering, Model #2 64-001, Serial #264-28879-001, was originally included in this list but was relocated to the Insignificant Activities list as a result of the May 11 meeting.

EUG 6 – VOC Sources Not Subject to a NSPS or NESHAP

EU ID EU Name Manufacturer/Model/Serial # Construct

Date PP-1 Pulp Processing Units Components listed below 1975-1992 PM-11 Paper Machine #11 KMW 1975PERMIT MEMORANDUM 99-113-TV (M-9) 17

EU ID EU Name Manufacturer/Model/Serial # Construct

Date PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning PM-11, PM-12, PM-13, PM-14 NA 1975

PM-15 Solvent Cleaning NA 1992 PO-1 Flexo-plate making Anderson-Vreeland June, 1984 PO-1 Flexographic Polyethylene Prin ter Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer June, 1984

FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper Printer Fl exo #7 – PCMC/Model No. 6725 1997 FP-8 Flexographic Polyethylene Printer Bretting, 4-color, 78-inch wide 2005

Note: Although all of the equipmen t items listed in the following table is part of the pulping process, not all of them are listed in the permit. As a result of the May 11, 2005, meeting between AQD and the applicant, the equipment list included in the permit wa s revised to reflect only those units that have emissions, i. e., it does not incl ude closed units.

PP-1 Pulp Processing Units

EU Name Construction Date Pulpers (not system specific) 1975, 1979, 1981, 1983, 1992, est.

Unbleached Stock Blend Tanks 1975 & 1983, est.

Screens 1975, 1979, 1981, 1983, & 1992, est.

Unbleached Washers 1975, est.

Flotation Cell Washers 1975, 1979, 1981, 1983, & 1992, est.

Unbleached Thickener 1975 & 1992, est.

Bleached Washers 1975, 1981, 1983, 1992, est. Storage (not system specific) 1975, 1979, 1981, 1983, 1992 est.

Bleach Towers 1975, 1979, 1981, 1983, 1992, est.

Thickeners 1979, 1981, 1983, est.

Unbleached Stock Presses 1992, est. Mixers 1992, est. Cleaners 1992, est.

EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAPPERMIT MEMORANDUM 99-113-TV (M-9) 18

EUG 7 includes emissions units that have non -combustion, particulate process emissions, not subject to an NSPS or a NESHAP performance standard.

EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP

EU ID EU Name Manufacturer/ Serial # Construct Date

PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992

SECTION IV. EMISSIONS

Based on the facility’s 1998 turn around document, the facility processed approximately 324,460 tons of paper products and 480,090 tons of coal that year. Product usage was 1,787,370 pounds of ink and ink solvent, 72,960 gallon s of Paper Machine solv ent, and 7,075 tons of bleaching/de-inking additives. Because of the leng th of the emission discussions and illustrative tables for each Emission Unit, a facility em ission summary table is first offered in this s ection. For combustion emissions, the highest from all fuels considered is shown. Emission calculations for each emission
unit identified in the a pplication, as re-grouped into the following Emission Unit Groups, are
detailed in the discu ssion and tables follo wing this section.

Facility-Wide Emissions Summary

Combustion Emissions

Boilers PM (TPY) NO X (TPY) SO 2 (TPY) VOC (TPY) CO (TPY) HCL (TPY) H 2 SO 4 (TPY) HF (TPY)

B-1 38.41 (3) 279.32 (3) 913.61 (3) 8.96 (2) 136.87 (2) NA NA NA

B-2 74.00 (1) 994.44 (1) 1,489.34 (1) 173.45 (1) 194.26 (2) 27.75 (1) 39.32 (1) 13.88 (1)

B-3 14.64 (1) 655.78 (1) 1,853.85 (3) 16.10 (2) 97.59 (3) 87.73 (1) 8.78 (1) 2.93 (1)

B-4 43.91 (1) 992.45 (1) 1,847.31 (1) 14.83 (3) 204.93 (2) 96.61 (1) 11.71 (1) 2.93 (1) Paper
Machines

PM-11 5.95 (3) 36.04 (1) 141.46 (1) 1.39 (2) 21.19 (2)

PM-12 3.22 (3) 24.78 (1) 76.62 (1) 0.95 (2) 14.57 (2)

PM-13 4.34 (3) 24.78 (1) 103.14 (1) 0.95 (2) 14.57 (2)

PM-14 4.96 (3) 36.04 (1) 117.88 (1) 1.16 (2) 17.66 (2)

PM-15 2.00 (2) 26.28 (2) 0.16 (2) 1.21 (2) 18.40 (2)

PO-1 0.07 (2) 0.88 (2) 0.01 (2) 1.89 (2) (4) 0.74 (2) Subtotal 191.50 3,070.79 6,543.38 220.89 720.78 212.09 59.81 19.74

Non-Combustion Emissions

Coal Handling PM (TPY) NO X (TPY) SO 2 (TPY) VOC (TPY) CO (TPY) HCL (TPY) H 2 SO 4 (TPY) HF (TPY)

Railcar Unloading 35.23

Radial StackerPERMIT MEMORANDUM 99-113-TV (M-9) 19

Non-Combustion Emissions

Coal Handling PM (TPY) NO X (TPY) SO 2 (TPY) VOC (TPY) CO (TPY) HCL (TPY) H 2 SO 4 (TPY) HF (TPY)
Grizzly Feeder

Coal Sizer/
Crusher 82.03

Conveying 8.20

Coal Bunkers 8.20

Coal Feeders Closed

Process
(5) Pulverizers

FS-1 11.1 (6)

Subtotal 144.76 Paper Making
PP-1 Pulping

Process 123.17

Paper Making 54.97 98.83

Paper Machine
Additives 10.55

Paper Machine PM-11, 12, 13,
& 14 Solvents 179.1

Paper Machine
PM-15 Solvents 37.57

PO-1 Extruder 0.52 0.02 Subtotal 55.49 449.24 Printing
Plate Making 1.83

PO-1 Printer 4.41

PO-1 Printer 59.12 (6)

Ozone

Treaters 1.76 (7)

FP-1 Printer 92.28

FP-7 Printer 0.1152 Subtotal 159.52 Facility

Total 391.75 3,070.79 6,543.38 829.65 720.78 212.09 59.81 19.74

(1) - Coal fired emissions (2) - Natural gas fired emissions (3) - Fuel oil fired emissions (4) - Includes solvent cleaning VOCs not destroyed by catalytic incinerator. (5) - Closed Process No emissions (6) - Fugitives (7) - Ozone

EUG 1 – Subpart D BoilersPERMIT MEMORANDUM 99-113-TV (M-9) 20

The applicant submitted the following emission calcu lations for the boilers, based on either AP-42 factors, or emission testing as footnoted. However, the Title V permit limits are based on regulatory limits, justified by modeling to establish complian ce with existing air qualit y standards at the time
of issuance of Permit No. PSD-O K-404. Stack tests for Boiler B-2 burning High Btu coal were conducted on January 7, 8, and 9, 2003. Stack te sts for Boiler B-2 burn ing Low Btu coal were conducted on May 16 and 17, 200 3. Stack tests for Boiler B-3 bu rning Powder River Basin coal were conducted on May 20 and 21 , 2003. Stack tests for Boiler B-4 burning Powder River Basin coal were conducted on April 15 a nd 16, 2003. The results of the mo st recent tests are contained in reports prepared by Western En vironmental Services and Tes ting, Inc., received by AQD on November 6, 2003, with the applicant’s response to an NOD dated June 12, 2003.

EUG 1 – Subpart D Boilers

EU

ID Boiler Rating (MMBtu/hr) Firing Configuration Controls Low
NO X Fuels

B-1 310 Forced Draft Package None No Gas/Oil B-2 440 Wall Fired Electrostatic Precipitator No Coal/Gas/Oil B-3 557.11 Tilting Tangential Baghouse Filter No Coal/Gas/Oil B-4 557.11 Wall Fired, Opposing Wa lls Baghouse Filter Yes Coal/Gas/Oil

COAL NATURAL GAS FUEL OIL

B-1

310 MMBTUH Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM NA NA 7.6 lbs (4)

MMCF 12.38 (1) 0.0033 lbs (5) gal 38.41 (1)

NO X NA NA 0.115 lbs (3)

MMBTU 187.38 (1) 0.024 lbs (6) gal 279.32 (1)

SO 2 NA NA 0.6 lbs (4)

MMCF 0.98 (1) 0.0785 lbs (6) gal 913.61 (1)

VOC NA NA 5.5 lbs (4)

MMCF 8.96 (1) 0.0002 lbs (7) gal 2.33 (1)

CO NA NA 84 lbs (4)

MMCF 136.87 (1) 0.005 lbs (6) gal 58.19 (1)

HCL NA NA NA NA NA NA

H 2 SO 4 NA NA NA NA NA NA

HF NA NA NA NA NA NA
B-2

440 MMBTUH Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY) PM (Hi Btu Coal) (19) 0.032 lbs (3)

MMBtu 74.00 ( 1 ) 7.6 lbs (4), (14)

MMCF 0.18 ( 1 ) 0.0033 lbs (5, 14) gal 0.55 ( 1 )

PM (Lo Btu Coal) (19) 0.027 lbs (3)

MMBtu 62.44 ( 1 )

NO X (Hi Btu Coal) (19) 0.43 lbs (3)

MMBtu 994.44 ( 1 ) 190 lbs (15)

MMCF 366.17 0.024 lbs (6) gal 396.45 ( 1 )

NO X (Lo Btu Coal) (19) 0.319 lbs (3)

MMBtu 737.73 ( 1 )

SO 2 (Hi Btu Coal) (19) 0.644 lbs (3)

MMBtu 1,489.34 ( 1 ) 0.6 lbs (4)

MMCF 1.39 ( 1 ) 0.0785 lbs (6) gal 1,296.73
(1)PERMIT MEMORANDUM 99-113-TV (M-9) 21

COAL NATURAL GAS FUEL OIL

SO 2 (Lo Btu Coal) (19) 0.267 lbs (3)

MMBtu 617.48 ( 1 )

VOC (Hi Btu Coal) (19) 0.075 lbs (3)

MMBtu 173.45 ( 1 ) 5.5 lbs (1), (4)

MMCF 12.72 ( 1 ) 0.0002 lbs (7) gal 3.30 ( 1 )

VOC (Lo Btu Coal) 0.002 lbs (3)

MMBtu 4.63 ( 1 )

CO (Hi Btu Coal) (19) 0.022 lbs (3)

MMBtu 50.88 ( 1 ) 84 lbs (1), (15)

MMCF 194.26 ( 1 ) 0.005 lbs (6) gal 82.59 ( 1 )

CO (Lo Btu Coal) (19) 0.004 lbs (3)

MMBtu 9.25 ( 1 )

HCL (Hi Btu Coal) (19) 0.012 lbs (3)

MMBtu 27.75 ( 1 ) NA NA NA NA

HCL (Lo Btu Coal) (19) 0.003 lbs (3)

MMBtu 6.94 ( 1 )

H 2 SO 4 (Hi Btu Coal) (19) 0.001 lbs (3)

MMBtu 2.31 ( 1 ) NA NA NA NA

H 2 SO 4 (Lo Btu Coal) (19) 0.017 lbs (3)

MMBtu 39.32 ( 1 )

HF (Hi Btu Coal) (19) 0.006 lbs (3)

MMBtu 13.88 ( 1 ) NA NA NA NA

HF (Lo Btu Coal) (19) 0.001 lbs (3)

MMBtu 2.31 ( 1 )

B-3

557 MMBTUH Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 0.005 lbs (3)

MMBtu 14.64 ( 1 ) 7.6 lbs (4), (16)

MMCF 0.09 ( 1 ) 0.0108 lbs (16, 17) gal 0.84 ( 1 )

NO X 0.224 lbs (3)

MMBtu 655.78 ( 1 ) 170 lbs (15)

MMCF 456.22 ( 2 ) 0.032 lbs (6) gal 624.55 ( 1 )

SO 2 0.403 lbs (3)

MMBtu 1,179.82 ( 1 ) 0.6 lbs (4)

MMCF 1.76 ( 1 ) 0.10362 lbs (6) gal 1,853.85 ( 2 )

VOC 0.001 lbs (3)

MMBtu 2.93 ( 1 ) 5.5 lbs (4)

MMCF 16.10 ( 1 ) 0.00076 lbs (7) gal 14.83 ( 1 )

CO 0.003 lbs (3)

MMBtu 8.78 ( 1 ) 24 lbs (15)

MMCF 70.26 ( 1 ) 0.005 lbs (6) gal 97.59 ( 1 )

HCL 0.03 lbs (3)

MMBtu 87.83 ( 1 ) NA NA NA NA

H 2 SO 4 0.003 lbs (3)

MMBtu 8.78 ( 1 ) NA NA NA NA

HF 0.001 lbs (3)

MMBtu 2.93 ( 1 ) NA NA NA NA

B-4

557 MMBTUH Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 0.015 lbs (3)

MMBtu 43.91 ( 1 ) 7.6 lbs (4), (18)

MMCF 0.18 ( 1 ) 0.0108 lbs (17, 18) gal 1.68 ( 1 )

NO X 0.339 lbs (3)

MMBtu 992.45 ( 1 ) 190 lbs (15)

MMCF 463.54 0.04 lbs (6) gal 715.63 ( 2 )

SO 2 0.631 lbs (3)

MMBtu 1,847.31 ( 1 ) 0.6 lbs (4)

MMCF 1.76 ( 1 ) 0.10362 lbs (6) gal 1,685.32PERMIT MEMORANDUM 99-113-TV (M-9) 22

COAL NATURAL GAS FUEL OIL

VOC 0.001 lbs (3)

MMBtu 2.93 ( 1 ) 5.5 lbs (4)

MMCF 13.42 0.00076 lbs (7) gal 14.83 ( 1 )

CO 0.012 lbs (3)

MMBtu 35.13 ( 1 ) 84 lbs (15)

MMCF 204.93 0.005 lbs (6) gal 81.32

HCL 0.033 lbs (3)

MMBtu 96.61 ( 1 ) NA NA NA NA

H 2 SO 4 0.004lbs (3)

MMBtu 11.71 ( 1 ) NA NA NA NA

HF 0.001 lbs (3)

MMBtu 2.93 ( 1 ) NA NA NA NA

(1) - 20% contingency added (2) - 10% contingency added (3) - Stack tests conducted in June 1980 for Boiler B-1, on January 7, 8, 9, 2003, for B-2 (High Btu coal), May 16 & 17, 2003, for B-2 (Low Btu coal), May 20 & 21, 2003, for B-3, and April 15 & 16, 2003, for B-4 (4) - AP-42, Table 1.4-2 (7/98) (5) - AP-42, Tables 1.3-1, 1.3-2 (9/98) (6) - AP-42, Table 1.3-1 (9/98), S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil (7) - AP-42, Table 1.3-3 (9/98) (14) - 99% efficiency for ESP (15) - AP-42, Table 1.4-1 (7/98) (16) - 99.60% efficiency for Baghouse (17) - AP-42, Tables 1.3-1 and 1.3-2 (9/98), S content of 0.66% (fuel supplier) (18) - 99.20% efficiency for Baghouse (19) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous

EUG 1 - Emissions Summary

PM (TPY) NO X (TPY) SO 2 (TPY) VOC (TPY) CO (TPY) HCL (TPY) H 2 SO 4 (TPY) HF (TPY)

B-1 38.41 (3) 279.32 (3) 913.61 (3) 8.96 (2) 136.87 (2) NA NA NA

B-2 74.00 (1) 994.44 (1) 1,489.34 (1)

173.45 (1) 194.26 (2) 27.75 (1) 39.32 (1) 13.88 (1)

B-3 14.64 (1) 655.78 (1) 1,853.85 (3) 16.10 (2) 97.59 (3) 87.83 (1) 8.78 (1) 2.93 (1)

B-4 43.91 (1) 992.45 (1) 1,847.31 (1) 14.83 (3) 204.93 (2) 96.61 (1) 11.71 (1) 2.93 (1)
Total 170.96 2,921.99 6,104.11 213.34 633.65 212.19 59.81 19.74
(1) – Coal fired emissions (2) – Natural gas fired emissions (3) – Fuel oil fired emissions

EUG 2 – Combustion Sources No t Subject to NSPS or NESHAP

EU ID Rating (MMBtu/hr) Firing Configuration Controls Fuels

PM-11 2 x 24 NA None Gas/Propan

e PM-12 2 x 16.5 NA None Gas/Propan

e PM-13 2 x 16.5 NA None Gas/Propan

ePERMIT MEMORANDUM 99-113-TV (M-9) 23

PM-14 2 x 24 NA None Gas/Oil

PM-15 2 x 25 NA None Gas/Oil PO-1 Catalytic Oxidizer 2.0 NA None VOCs/Gas

The applicant submitted the following emission calculations for the paper machines, based on AP-42 emission factors as footnoted, burner ratings, and fuel heating values. However, only Paper Machines PM-14 and PM-15 have permit limi ts, which were established by existing permits.

Emission calculations for firing the paper mach ines on LPG, a backup fuel for PM-12, were calculated by the same method. Since the LPG emissions do not exceed the limits set by natural gas and fuel oil, the results of these calculations are not presented. The gas/oil burners were replaced with gas only burners in 1999, 2003, an d 2002, respectively. The rating for the PM-12 burner is a correction from the rating of 13.0 MMBTUH submitted in the Title V application.

Emission calculations for the Dryer and Incinerato r (from natural gas combustion) were based on AP-42 emission factors, burner ratings, and fuel heating values. These calculations are shown below as presented on pages 161 and 162 of the Title V application. As described in the memorandum of Permit No. 83-062-O (PSD), issu ed for the PO-1 Polyethylene Extruder and Printer, “the Tunnel Dryer and TEC Systems Cata lytic Oxidation Incinera tor, Model No. HXC II - 400 was tested at a destruction efficiency of up to 96.8% of the collected VOC emissions while consuming on average 9.97 MMCF/year (1,138 ft 3 /hr) of commercial natu ral gas. The unit is capable of consuming up to 17.52 MMCF/yr (2,000 ft 3 /hr) at maximum operation capacity. Criteria pollutant emissions are based on AP- 42 (1/95), Tables 1.4-1, 1.4-2, and 1.4-3, using the
Commercial Boilers (0.3 - < 10 X 10 6 BTU/hr) emission rates in th at, at the maximum operating rates, this unit is capab le of delivering 2.0 X 10 6 BTU/hr. All emissions of criteria pollutants are
below de minimis levels from this source.” Note in the VOC calculation that because the
Incinerator is rated at 95% VOC destruction ef ficiency, only 5% of the VOCs produced from combustion are not destroyed and therefore emitted.

EUG 2 – Combustion Sources No t Subject to NSPS or NESHAP

NATURAL GAS FUEL OIL

PM-11

24 MMBTUH x 2 Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 1.92 (1) 0.0033 lbs (5) gal 5.95 (1)

NO X 100 lbs (15)

MMCF 25.23 (1) 0.02 lbs (6) gal 36.04 (1)

SO 2 0.6 lbs (4)

MMCF 0.15 (1) 0.0785 lbs (6) gal 141.46 (1)

VOC 5.5 lbs (4)

MMCF 1.39 (1) 0.0002 lbs (7) gal 0.36 (1)

CO 84 lbs (4)

MMCF 21.19 (1) 0.005 lbs (6) gal 9.01 (1)

PM-12

16.5 MMBTUH x 2 Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 1.32 (1) 0.0033 lbs (5) gal 3.22 (1)PERMIT MEMORANDUM 99-113-TV (M-9) 24

NATURAL GAS FUEL OIL

NO X 100 lbs (15)

MMCF 17.35 (1) 0.02 lbs (6) gal 24.78 (1)

SO 2 0.6 lbs (4)

MMCF 0.10 (1) 0.0785 lbs (6) gal 76.62 (1)

VOC 5.5 lbs (4)

MMCF 0.95 (1) 0.0002 lbs (7) gal 0.25 (1)

CO 84 lbs (4)

MMCF 14.57 (1) 0.005 lbs (6) gal 4.88 (1)

PM-13

16.5 MMBTUH x 2 Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 1.32 (1) 0.0033 lbs (5) gal 4.34 (1)

NO X 100 lbs (15)

MMCF 17.35 (1) 18.40 (2) 0.02 lbs (6) gal 24.78 (1)

SO 2 0.6 lbs (4)

MMCF 0.10 (1) 0.0785 lbs (6) gal 103.14 (1)

VOC 5.5 lbs (4)

MMCF 0.95 (1) 0.0002 lbs (7) gal 0.25 (1)

CO 84 lbs (4)

MMCF 14.57 (1) 0.005 lbs (6) gal 6.57 (1)

PM-14

24 MMBTUH x 2 Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 1.60 0.0033 lbs (5) gal 4.96

NO X 100 lbs (15)

MMCF 23.13 ( 2 ) 0.02 lbs (6) gal 36.04 ( 1 )

SO 2 0.6 lbs (4)

MMCF 0.15 ( 1 ) 0.0785 lbs (6) gal 117.88

VOC 5.5 lbs (4)

MMCF 1.16 0.0002 lbs (7) gal 0.36 ( 1 )

CO 84 lbs (4)

MMCF 17.66 0.005 lbs (6) gal 7.51

PM-15

25 MMBTUH x 2 Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 2.00 ( 1 ) NA NA

NO X 100 lbs (15)

MMCF 26.28 ( 1 ) NA NA

SO 2 0.6 lbs (4)

MMCF 0.16 ( 1 ) NA NA

VOC 5.5 lbs (4)

MMCF 1.21 NA NA

CO 84 lbs (4)

MMCF 18.40 NA NA

PO-1

2.0 MMBTUH Emissions

Factor Emissions (TPY) Emissions

Factor Emissions (TPY)

PM 7.6 lbs (4)

MMCF 0.07 NA NA

NO X 100 lbs (15)

MMCF 0.88 NA NA

SO 2 0.6 lbs (4) 0.01 NA NAPERMIT MEMORANDUM 99-113-TV (M-9) 25

NATURAL GAS FUEL OIL

MMCF
VOC 5.5 lbs (4)

MMCF 1.89 NA NA

CO 84 lbs (4)

MMCF 0.74 NA NA

(1) - 20% contingency added; (2) - 10% contingency added; (4) - AP-42, Table 1.4-2 (7/98); (5) - AP-42, Tables 1.3-1, 1.3-2 (9/98); (6) - AP-42, Table 1.3-1 (9/98); S = 0.5 for No . 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil; (7) - AP-42, Table 1.3-3 (9/98); (15) - AP-42, Table 1.4-1 (7/98)

EUG 2 – Emissions Summary

PM (TPY) NO X (TPY) SO 2 (TPY) VOC (TPY) CO (TPY)

PM-11 5.95 ( 1 ) 36.04 ( 1 ) 141.46 ( 1 ) 1.39 ( 2 ) 21.19 ( 2 )

PM-12 3.22 ( 1 ) 24.78 ( 1 ) 76.62 ( 1 ) 0.95 ( 2 ) 14.57 ( 2 )

PM-13 4.34 ( 1 ) 24.78 ( 1 ) 103.14 ( 1 ) 0.95 ( 2 ) 14.57 ( 2 )

PM-14 4.96 ( 1 ) 36.04 ( 1 ) 117.88 ( 1 ) 1.16 ( 2 ) 17.66 ( 2 )

PM-15 2.00 ( 2 ) 26.28 ( 2 ) 0.16 ( 2 ) 1.21 ( 2 ) 18.40 ( 2 )

PO-1 0.07 ( 2 ) 0.88 ( 2 ) 0.01 ( 2 ) 1.89 ( 2 ) ( 3 ) 0.74 ( 2 )

(1) - Fuel oil fired emissions (2) - Natural gas fired emissions (3) – Includes solvent cleaning VOCs not destroyed by catalytic incinerator.

EUG 3 – Coal Preparation Plant

The applicant submitted the following methodology for calculating emissions from the coal handling processes. Regulatory standards are limited to opacity standards. There were no limits placed on this EUG in the permit.

To calculate emissions for operations from railcar unloading to the griz zly feeder, an emission factor from AP-42, 13.2.4 Aggregate Handling and Storage Piles, was used from the Mineral Products Industry category. This factor incl udes both batch and continuous drop operations,
both of which are utilized for this coal preparation plant. It in cludes dust emissions from several
distinct source activities w ithin the storage cycle:

1. Loading of aggregate onto storage pile s (batch or conti nuous drop operations). 2. Equipment traffic in storage area. 3. Wind erosion of pile surfaces and ground areas around piles. 4. Load-out of aggregate for shipment or fo r return to the process stream (batch or continuous drop operations).

Emissions from railcar unloading, th e radial stacker, and filling the grizzly feeder with the frontend loader were calculated with the use of this emission factor. Inherent to the emission factor derivation and resulting emission calculations for this methodology are coal pile emissions. ThePERMIT MEMORANDUM 99-113-TV (M-9) 26

results of the calculations for the emission units in this EUG are illustrated by the following methodology and summarized in the table below.

From AP-42, Section 13.2.4: E (lbs/ton) = k*0.0032 * (U/5) 1.3 / (M/2) 1.4

where: k = 0.35 for PM 10 U = wind speed (15 mph, worst case valu e from Ranges of Source Conditions) M = moisture content (0.25 %, worst cas e value from Ranges of Source Conditions)

Applying the above factors, E = 0.0859 lbs PM/ton of coal.

Coal handling factors for crushing and conve ying were taken from “Compilation of Past Practices and Interpretations by EPA Region VIII on Air Quality Review of Surface Mining Operations.” These factors are also consistent w ith those used in an Oklahoma power plant Title V permit. A factor of 0.2 lbs PM/ton of coal was used for crushing, and a factor of 0.02 lbs PM/ton coal was used both for conveying and the conveying/filling proce ss into the bunkers. No factors were compiled for the coal feeders or the pulverizers. These are closed processes, and are expected to have no visible emissions. However, they are subject to a 20% opacity limit by regulation.

Applying the above emission factors to a th roughput of 519,362 tons of coal in 2003, the applicant estimated actual emissions as shown in the following table. Generally, sub-bituminous
coal would have a heat value content of more than 8,300 Btu /lb and less than 11,500 Btu/lb. Using the low value and the total combined h eat input rating of Boilers B-2, B-3, and B-4, operating on a continuous schedule, coal consumption should not exceed 820,178 TPY. The
PTE shown in the table is based on a throughput of 820,200.

EUG 3 –Coal Preparation Plant

EU Name Particulate Matter
Emission Factors (lbs/ton coal) Throughput (TPY) PM Emissions (TPY)

2003 Actual PTE

Railcar Unloading
0.0859 519,362 22.31 35.23 Radial Stacker Grizzly Feeder

Coal Sizer/Crusher 0.2 519,362 51.94 82.03 Conveying 0.02 519,362 5.19 8.20

Coal Bunkers 0.02 519,362 5.19 8.20

Coal Feeders Closed Process
No Emissions Pulverizers

Concerning the building housing the coal sizer/cr usher, there are openings on two sides of the building for the ingoing and outgoing conveyors. Except for the outlet chute opening to the conveyor, the Sizer/Crusher is en closed. Based on this and visu al observation, the applicant feels it is apparent that Sizer /Crusher emissions would not exceed Unloading/Stacker/Feeder emissions. Regardless, an emi ssion calculation for the crusher ha s been included in the EUG 3 emissions table above. The applicant further belie ves that the emission ra te in the table abovePERMIT MEMORANDUM 99-113-TV (M-9) 27

for the Sizer/Crusher does not seem practical wh en compared to the emission rate from the Unloading/Stacker/Feeder category directly abov e it. The applicant found no other factor by
which to calculate Sizer/Crus her emissions and has reques ted that AQD consider this inconsistency during permit development. The onl y limit placed in the permit at this time by AQD is opacity.

FS-1 Emissions - Title V application As stated in Appendix E of the original application, emission unit FS-1 is known as fuel storage. As noted above in the discussion for the plant-wide emission calculations, coal pile emissions were included in those calculations. Coal pi le emissions, FS-1, were calculated and submitted in the original permit application. Solid fuels that will be used in the boilers are stored in outdoor storage piles at the mill site. FS-1 pertains to the particulate emissions resulting from pile building, wind erosion, and pile breakdown. Ba sed on information from a 1984 report by the Electric Power Research Institute, CS 3455, th e following calculation was used to determine emissions from the coal pile:

E = 1.9(S/1.5)[(365-P)/235)](f/15)

where:

E = emission factor (Kg per hectare per day) S = silt content of aggregate (%) P = number of days with > 0 .25 mm of precip itate per year. f = percentage of time that the unobstructed wind speeds exceeds 5.4 m/s at the mean pile height.

for Muskogee:

S = 2.2 (AP-42 table 11.2, 3.1) P = 90 (AP-42 figure 11.2,1-1) f = 39 from the 1988 Windrose for Tulsa, OK (1 knot = .5 m/s)

As a result, for every hectare of coal stored, the following was used to determine the coal dust
emissions.

Kg/hectare-day = 1.9(2.2/1.5) [(365-90)/235](39/15) = 8.5

The approximate square footag e of the coal pile is 350,000 ft 2

.

Converting coal pile square footage to hectares = 350,000 ft 2 (0.00000929 hectare/ft 2 ) =
3.2515 hectares

Substituting 8.5/hectare-day (3.2515 hectares) = 27.63775 kg/dayPERMIT MEMORANDUM 99-113-TV (M-9) 28

Consequently, 27.63775 kg/day (365 days/yr)(1 ,000 g/kg)(1 lb/454 g) ton/2,000 lbs = 11.11 tons/yr.

EU ID Emissions Factor (kg/hectare-day) Throughput
(hectares) Control Efficiency PM Emissions (TPY)

FS-1 8.5 3.2515 None 11.11

EUG 4 – PP-1 Pulp Processing Units

This EUG is reserved for future Subpart S ap plicable units. HAP emission calculations are
included in EUG 6 – VOC Sources No t Subject to an NSPS or NESHAP.

EUG 5 – Subpart KK Flexographic Printing

Printing Presses Emissions of HAPS are limited by Subpart KK to 400 kilograms per month. In addition to restrictions on HAP emissions, these units have a large amount of VOC emissions. Non-HAP emissions may become subject to the requireme nts of OAC 252:100-42. VOC emissions for the printers, not subject to an NSPS or NESHAP, are illustrated in the discussion of emissions for EUG 6 and are not repeated here.

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

As noted earlier, a Flexographic Polyethyle ne Extruder, Gloucester Engineering, Model #264- 001, Serial #264-28879-001, was originally included in this list but wa s relocated to the Insignificant Activities list as a result of a meeting between the applicant and AQD on May 11, 2005. Additionally, the draft perm it was revised to elim inate the requirements for compliance with OAC 252:100-41, which was replaced by emergency rule for OAC 252: 100-42, a far less restrictive rule as applied to this facility.

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

EU ID EU Name Manufacturer/Model/Serial # Construct

Date PP-1 Pulp Processing Units Components listed in Section III 1977-1992 PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning PM-11, PM-12, PM-13, PM-14 NA 1975

PM-15 Solvent Cleaning NA 1992 PO-1 Flexo-plate making Anderson-Vreeland June, 1984PERMIT MEMORANDUM 99-113-TV (M-9) 29

EU ID EU Name Manufacturer/Model/Serial # Construct

Date Flexographic Polyethylene
Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/vapor collection hood and tunnel dryer June, 1984

FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper Printer Fl exo #7 – PCMC/Model No. 6725 1997 FP-8 Flexographic Polyethylene
Printer Bretting, 4-color, 78-inch wide June, 2005

PP-1 Pulp Processing Units The following discussion was prepared by the applicant and transposed here with minor editing.

Emissions were measured from Pulping System by The Nationa l Council for Air and Stream Improvement (NCASI) and overall emission fact ors developed for each pollutant emitted from the systems. The following discussion of th e derivation of emission s was taken from the applicant’s submittal dated Ma y 24, 2004, in response to AQD’s Notice Of Deficiency dated May 10, 2004, with some editorial changes by AQD:

Fort James Operating Company’s Muskogee Mill (“FJOC” or “the mill”) was selected by NCASI and the forest products industry leadership to participate in a comprehensive emission testing program. NCASI is the primary research arm of the pulp and pape r industry and worked closely with the United States Environmenta l Protection Agency (“USEPA”) to develop a sampling program to gather information on emi ssions of Hazardous Air Pollutants (“HAPs”) that would support the development of Maximum Achievable Control Technology (“MACT”) standards for, in addition to others, recycled fiber pulping and de-inking mills. As a side note concerning HAPs, each HAP that was originally analyzed in this discussion, except for limonene which was detected only at trace levels (0.009 lb s/hr), was also an Oklahoma Department of Environmental Quality (ODEQ) Toxic Air Contaminant (TAC). At the time of the study, an extensive list of state-regulated toxic air contaminants (TACs) wa s in effect under Part 5 of OAC 252:100-41 (Subchapter 41). Subsequent to pub lic notice of the draft permit, during which comments from the applicant were under consideration, Pa rt 5 of Subchapter 41 was superseded by OAC 252:100-42, which has become effective by em ergency rule and is expected to become permanently effective on June 15, 2006. Therefore this discussion is more pertinent now to

HAPs.

The primary goal of the progra m was to characterize the emi ssions of volatil e organic HAPs from various processes to determine if these emi ssions could be related to key process variables. A secondary goal was to obtain emissions data th at could be used to prepare Title V operating permit applications and to improve the accuracy of annual release estimates required by SARA

313.PERMIT MEMORANDUM 99-113-TV (M-9) 30

Initiated in 1994, the sampling prog ram consisted of two phases. In phase I, approximately 140 process liquid samples were collected from 33 mills. Based on industry experience and working closely with USEPA, NCASI developed a list of nearly 100 HAP compounds that the liquid samples would be analyzed for, with a target de tection limit of 1 mg/L. The results from the analysis of these samples and information collected about the process units were then used as a
basis for selection of eleven mills at which full- scale studies were conducted. The eleven mills were selected on the three principles belo w, and FJOC met each of the criteria.

1. The selected mills and process units were to be representative of similar facilities in the industry. Since one of the goals of phase I was the identification of compounds that had a reasonable likelihood of being detected in proc ess vent gases, it was necessary to collect samples from mills that used processes and a dditives that were typical of the industry. 2. The facilities chosen were to include pro cesses targeted by USEPA in 1994 for potential MACT III regulations, which included de-inking. 3. For each targeted mill process, major variab les possibly affecting emissions were to be considered. Within recovered fiber pulpi ng, de-inked and non-de -inked pulping were included. Within the category of paper produ ction, recovered fiber tissue and towel were
included.

PHASE I In phase I, the following six process liquid samples were collected for the screening study analysis at the pulp processing faci lity: Test Area 1 unbleached washer filtrate, bleached washer filtrate, Test Area 2 unbleached washer filtrate, bl eached washer filtrate, Paper Machine No. 12’s (PM-12) white water, and Paper Machine No. 14’s (PM-14) white water. The screening liquid sample points can be located on the simplified flow diagram below.PERMIT MEMORANDUM 99-113-TV (M-9) 31

Bleached

Washers Deinking

Deinking

Other Deinking

Units Unbleached

Washers Bleaching

Bleached

Washers Unbleached

Washers Bleaching Recovered

Fiber PM-12

PM-14

Other Paper
Machines

LEGEND

Stock Liquid Sample Point

PHASE II Emissions from process vents were measured from the Pulp Processing Te st Area 1 by NCASI.
Emission measurements were taken at the Unbl eached Disc Thickener Vent, the Unbleached Washers, the Bleached Washers, the Flotation Cell Vacuum System Device Vent No. 2, and the Stock Blend Tank Vent. Test Area 2 were taken at the No. 1 Bleach Tower Vent, the Pressurized Deinking Modules Reje cts Vent, the Unbleached Press Vent No. 1, the No. 2 Bleach Tower Vent, and the Thickener Vent.

There were generally three stack test results on each source that were averaged according to prescribed calculation protocols (note however that, if for a sour ce, all the runs for a compound gave emission rates below the detection limit, the average emission would be reported as ND (not detected) at the detection limit). The vent gas concentrations were multiplied by the measured vent gas flow rates to determine the s ource emission rates (lb/hr). The mass emission rates for individual compounds were calculated by using the molecular weights of the specific compound. The calculated emission rates were th en normalized by dividing the emission rate by the System production/throughput rate in short tons (T) to obta in the final results (lb/T).

Using the distributive property of mathematics, the emission rates for each source can be added together then multiplied by the system production rate yielding the same value as each emission rate being multiplied by the system production rate individually. Using Test Area 1 for example:

(#01)x + (#2D)x + (#4B)x + (#05)x + (#06)x = x (#01 + #2D + #4B + #05 + #06)PERMIT MEMORANDUM 99-113-TV (M-9) 32

where x is the system production rate at the time of testing.

NCASI generally states in its repo rt that, in some cases, not all of the vents from a process unit
were tested. The emissions for untested vents were estimated from similar tested vents. For example, if there were three roof vents, and only one of those vents was tested, and using a production rate of 300 tons per day (TPD) duri ng the testing, then 100 TPD was used in the
emission calculation for the one tested vent to account for the emissions from the other two
similar vents.

The Pulp Processing emission factors were used to estimate total TAC/HAP/VOC emissions for all pulping systems. This is reasonable since all systems use similar processes and raw materials to produce similar products . This approach should provide the best availabl e emission estimates for any existing system. Each System in Pulp Pr ocessing uses the same recovered fiber stock, and virtually the same additives and equipment to produce the same product. That is to say, each system uses a similar raw material and a simila r process to produce a si milar product. This assumption and methodology is somewhat analogous to using an AP-42 emission factor for a category of gas boilers that are simila r in heat input ra ting, size and design.

The primary difference in the Systems lies in the bleaching agent and/or sequence. Emission factors for the systems were developed by applying the production rate-normalized emission
factors from the two areas tested.

During the year 2004, the mill has been using the same bleaching agents except that more of one bleaching agent with an additive was used wh ereas less of another bleaching agent was used. According to the manufacturers of the additive, bleaching emissions would be similar. “Although there are some differences in the mode of chemical attack, the byproducts, such as methanol, acetic acid, and quinone st ructures, are associated with both bleaching species.” The applicant therefore believes that emissions usin g the new additive are similar to emissions prior to using the additive.

The discussion above summarized how HAP emissi on factors for two types of bleaching were tested by NCASI. When the emi ssion factors were selected to estimate potential-to-emit (PTE) emissions for the mill’s Title V application, the hi gher factors were selected and applied to the maximum expected production rates for the pulpi ng system. This method more-than-likely over estimates emissions, but is the most conservati ve method, and would in essence allow a safety margin to bleach with either type of bleach, yet have the most conservative PTE already estimated. The air modeling for toxics was perfor med at these conservative emission estimates.

The PTE for all the Pulp Processing is estimated in the table below. This is also the table submitted (in its latest revision) for the Title V permit application, and is the applicant’s request for establishing a permit limit.

EUG 6 – PP-1 Pulp Processing Emissions UnitsPERMIT MEMORANDUM 99-113-TV (M-9) 33

HAPs CAS # Emissions

TPY Emissions
lbs/hr 1,2-dimethoxyethane 110714 0.05 0.01 Acetaldehyde 75070 12.16 2.78 Biphenyl 92524 20.09 4.59

Chloroform 67663 39.61 9.04 Formaldehyde 50000 0.00 0.00

Methanol 67561 33.95 7.75 Methyl ethyl ketone 78933 0.57 0.13 Methylene chloride 74873 0.00 0.00

N aphthalene 91203 0.54 0.12

Phenol 108952 2.04 0.47 Propionaldehyde 123386 0.26 0.06

Toluene 108883 13.86 3.16
Note: Limonene was deleted from this table. It was detected only at trace levels.

For the permit, the following combined emission factor was developed.

Emission Factor = ∑ VOC Constituents = 28.11 lbs/hr = 0.44 lbs/ton Total Pulp Process Rate 64.59 TPH

The permitted factor is 0.45 lbs/ton.

Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15 The methodology that was used in calculating em ission factors for the paper machines presented in the public draft permit has been abandoned in favor of a mass balance based on the solvent content of additives used in the paper machines. This methodology is detailed in the following section titled “Paper Machine Additives.”

Paper Machine Additives
Pre-Draft Permit Emission Estimation On November 9, 1999, AQD received a modification to the Title V application to incorporate the use of VOC-containing enhancement chemicals, Paper Machine Additives, as they are now labeled, in the paper machines that would resu lt in estimated emissions of 25 TPY of VOCs.
This was to account for chemical s that were not in use when the NCASI testing was performed in 1995. Also, they were not included in the or iginal Title V application. The emissions are primarily from paper enhancement chemicals such as softness aids, dyes, biocides, etc. The application requested that an emission limit of 25 TPY VOC, based on a 60% release factor from these Paper Machine Additives, be incorporated into the Title V permit to allow for flexibility and potential growth.

The applicant provided additiona l information in th eir August 31, 2004 (received September 1, 2004) response to an NOD. The applicant included the table below as an example of the emissions produced from use of these chemicals. The applicant has indicated that the facility can maintain compliance with the total VOC limit and has reques ted that AQD not consider thePERMIT MEMORANDUM 99-113-TV (M-9) 34

chemical names and current usages to be the same year after year, i.e., to allow for flexibility of using different products. Flexibility is needed to change chemicals and chemical usages dictated by market and customer needs. The table was used to determine 2003 emissions reported on the 2003 Air Emissions Inventory (Turnaround Document ) and compared with additives used from 1999 to 2003, shows the need for flexibility. VOC emissions are based on VOC concentrations and throughput of each chemical. A 60% release factor is applied in the same way as demonstrated later for paper machine solvent emissions in SC-1.

EUG 6 - 2003 VOC Emissions from Paper Machine Additives % VOC by weight Release Factor VOCs (TPY)
Biocide 15% 60% 0.57
Biocide 74% 60% 1.55
Biocide 15% 60% 3.85
Biocide 15% 60% 3.42
Softener 8.40% 60% 0.69
Softener 4.30% 60% 0.00
Softener 11.60% 60% 0.37 red dye 2.70% 60% 0.00 yellow dye 4.00% 60% 0.05 Blue dye 1 4.00% 60% 0.00 Blue dye 2 0.30% 60% 0.00 beige dye 1.70% 60% 0.00 red dye 4.00% 60% 0.00 Blue dye 10.9% 60% 0.07 yellow dye 0.00% 60% 0.00 red dye 0.00% 60% 0.00 dye brightening aid 0.40% 60% 0.00 Blue dye 1.10% 60% 0.05

10.55

The following breakdown of TAC emissions serves only for informational purposes. With the revocation of Subchapter 41, these pollutants ar e currently not a concern as TACs. HAPs are
indicated in bold font.

EUG 6 - 2003 Paper Machine Additives TAC Analysis

Wt. % of
TAC TAC
Emissions

TPY CAS/Category/TAC

Biocide 10 0.35 6317-18-6 Cat. B Me thylene bis (thiocyanate)

60 2.09 111-77-3 Cat. C Diethylene glycol monomethyl ether

1 0.03 67-56-1 Cat. C Methanol

0.1 0.00 91-20-3 Cat. B Naphthalene

5 0.17 64742-94-5 Cat. B Aromatic SolventPERMIT MEMORANDUM 99-113-TV (M-9) 35

Wt. % of
TAC TAC
Emissions

TPY CAS/Category/TAC

Biocide 5 4.04 34590-94-8 Cat. C Dipropylene glycol methyl
ether yellow dye 10 0.23 57-13-6 Cat. C Urea blue dye 10 0.00 57-13-6 Cat. C Urea blue dye 1.9 0.00 N A - fume or dust / copper compounds blue dye 6 0.07 111-42-2 Cat. B Diethanolamine

15 0.00 N A - fume or dust / copper compounds

Post-Draft Permit Emissions Estimation As noted in the previous section, “Paper M achines PM-11, PM-12, PM-13, PM-14, and PM-15,” the previous methodology based on the NCASI tests to calculate emission factors for the paper machines presented in the public draft permit has been abandoned in favor of a mass balance
based on the solvent content of addi tives used in the paper machines . As a result of discussions with the applicant after the draft permit public noti ce, the applicant feels that the primary driving force of VOC emissions from the paper making pro cess (note this is not the same as the pulping process) is due to VOC-containi ng additives. Additionally, for this mass balance method to be representative of emissions, in addition to the 25 TPY of VOC emissions from additives placed in use after the draft permit was issued (and after NCASI testing) , it was necessary to account for emissions from additives that were in use during the time of the NCASI testing. The applicant
has estimated that an additional 65 TPY of emissions would cover this.

In summary, Emissions fro m Paper Machine Additives will be ca lculated from th e VOC-containing Paper Machine chemicals. The basis for the e missions calculation is a mass balance using the
summation of the estimate d VOCs emitted from additiv es that were in use when the NCASI testing was performed in 1995 (estimated at 65 TPY) and VOCs emitted from additives placed into use subsequent to the testing (25 TPY) . These include a contingency proj ected to meet ne ar term needs. The emissions are primarily from paper enhancem ent chemicals, dyes, et c. VOC emissions are
based on VOC concentrations an d throughput of each chemical, as suming a 60% release factor.

Solvent Cleaning of Paper Machines PM-11, PM-12, PM-13, and PM-14 Emissions of VOCs from SC-1, solvent cleanin g, are based on usage of a 100% VOC solvent to clean Paper Machine wires. This solvent is applied through spray nozzles located across a boom which stretches across the Paper Machine. Based on research from a similar de-ink facility paper machine, only 60% of the solvent applied to the machine equates to air emissions. According to the research, 20% is consumed in the reaction w ith the latex buildup on the wire, and 20% ends up in the water loop and eventually in the wastewat er treatment plant. The 60% evaporation rate was carried over from Permit No. 91-127-O (M-1 ), issued for PM-15. Solvent cleaning
emissions for the other machines have not been a ddressed in previous perm its. The applicant has proposed limits in the Title V a pplication based on similar emissi ons criteria and 1998 material usage projected to future demand. However, because VOC emissions from these sources have drastically increased si nce the 1998 application and the applican t expressed concerns over this limit, the TV permit has been amended to increa se the limit from 179.1 TPY to 338.0 TPY. ThePERMIT MEMORANDUM 99-113-TV (M-9) 36

numbers in the tables below did not reflect permitted numbers for PM-15 in the pervious permit, rather permitted emissions for PM-15 are carried over from Permit No. 91-127-O (M-1).

EUG 6 - SC-1 Solvent Cleaning of Pap er Machines PM-11, PM-12, PM-13, & PM-14

Pollutant CAS # Emission

Factor (lbs/ton) Throughput (TPY VOCs) Non-HAP
Emissions

(TPY) HAP
Emissions

(TPY)

Stoddard Solvent 8052413 60% 300 43.2

Aromatic Hydrocarbon Mixture > C9 64742945 60% 300 55.3

Aromatic hydrocarbon mixture > C9 64742956 60% 300 52.7

1,2,4-Trimethylbenzene 95636 60% 300 14.4

1,3,5-Trimethylbenzene 108678 60% 300 5.4

Xylene 1330207 60% 300 2.3 2.3

Naphthalene 91203 60% 300 5.8 5.8
Unspeciated VOC 60% 300

Total 179.1 8.1

Prorated for 338.0 TPY
VOCs 338.0 15.3

Solvent Cleaning of Paper Machine PM-15 As noted above, emissions for PM-15 were car ried over from Permit No. 91-127-O (M-1) and
combined with the total limit. Those numbers were 37.57 tons per year, 12-month rolling
cumulative.

Plate Making Emissions for Flexo-Platemaking at the Poly Pl ant, PO-1, are based on the solvent component
concentrations and the fact that the solvents are 100% VOC. Emissions are small because almost all of the used solvent is recycled at the Po ly Plant recycle unit. For permit limits, these emissions were combined with the PO-1 Flexographic Printer.

EUG 6 - PO-1: Flexo-plate making

Emissions

Factor Throughput (tons VOC / yr) VOC Emissions (TPY) HAP Emissions (TPY)

100% VOC 1.83 1.83 0.0

Existing PO-1, FP-1, and FP- 7 Flexographic Printers PO-1’s Flexographic Polyethylene Printer produces both fugitive and point source VOCs. The drying and collection hood above the Printer has a collection efficiency of only 70% which is consistent with US EPA published guidance, “ Control of Volatile Or ganic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts – Rotogr avure and Flexography” (EPA450/2-78-033, December 1978). This document is referred to on page 8 of ODEQ’s permit memorandum for the Poly Plant permit, Permit No. 83-062-O (PSD). Therefore, the remaining 30% are the source of the fugitive emissions from the Printer. The 70% that is collected is directed to a catalytic oxidation incinerator, inst alled as part of a control system for Permit No. 83-062-O PSD, which also included the polyethylen e extruder and th e flexographic printing press, where a destruction efficiency of 96.8% has been measured. Emission calculations are based onPERMIT MEMORANDUM 99-113-TV (M-9) 37

95% destruction efficiency. The remaining 5% of the 70% collected accounts for the Printer’s point source emissions.

Emission unit FP-1 consists of six flexographic prin ting presses. Water-base inks are used to print paper machine parent rolls to produce printe d parent rolls. These pr inted parent rolls are
then converted to both towel and napkin products. There are no stac ks for these processes. At the time of the application, the average VOC con centration of the water based inks ranged from approximately 6% to 8%. A conservative 10% was used to calculate a PTE and allow for flexibility in varying ink VOC concentrations.

Emission unit FP-7 is a 101.5”, four-c olor, in-line flexographic printi ng press. Water-base inks are used to print paper machine parent rolls to produce printed to wel products at th e end of this printer/re-winder. There are no stacks for this process. At the time of the application, the average VOC concentration of the water based i nks ranged from approximately 6% to 8%. A conservative 10% was used to calculate a PTE and allow for flexibility in varying ink VOC
concentrations.

New FP-8 Flexographic Printer A method for calculating emissions from printi ng is offered in a document titled “Technical Support Document (TSD) For Title V Permitting Of Printing Facilities,” Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, January 2005. A simplified version of this method is offered in AP-42, Ch apter 4, Section 4.9.1.2 (4/81). Both methods are mass balance, based on material usage. Th e following equations are from the TSD.

E

M

= E 1 + E 2 + E 3 + E 4

where: E M

= Total VOC emissions as summed from VOC emissions for individual materials (e.g., ink, fountain solution, etc.)

E

n = U
n x V
n x (1 – R
n /100) x {1 – ( η n /100) x ( ξ /100)}

where: E
n = VOC emissions from an individual material

U

n = Total usage of the individual material

V

n = Actual VOC content averaged ove r the collection period, e.g., 30 days

R
n = Amount of VOC retained and not emitted

η n = Capture efficiency for individual material emitted ξ = Control Device Efficiency

To determine whether a significant emission increase of a regulated NSR pollutant is projected to occur, the “ Actual-to-potential test ” must be applied. A signi ficant emission increase of a regulated NSR pollutant is projected to occur if the sum of the difference between the potential to emit from each new emission unit following comp letion of the project and the baseline actual emissions of these units before the project eq uals or exceeds the significant amount for that pollutant.PERMIT MEMORANDUM 99-113-TV (M-9) 38

Thus, a calculation of the potential to emit (PTE) for the new printer re quires a calculation of U
n (total material usage) at the maximum capaci ty to emit a pollutant under its physical and operational design. One method to calculate this requires knowledge of the printer capacity in terms of area and speed of paper printed as well as the ink carrying capacity of the printing plates. However, any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hour s of operation or on the type or amount of material co mbusted, stored, or processed, is treated as part of its design if
the limitation or the effect it would have on emissi ons is federally enforceable. Therefore, since the applicant has requested to take an enforceable limit for restrictions on the amount of material used, the calculation of an unrestricted PTE is not needed.

Using the equations above with several assumptions and simplifications, the applicant has
calculated emissions based on a re striction (enforceable limit) on U
n as follows:

R
n = 0; assumes all VOCs are emitted

η n = 0; since there are no controls, captu re efficiency is not a factor to be
considered ξ = 0; there are no control devices

The known values are:

U

n = 462,820 pounds per year

V

n = 10%

Therefore:

E

n = 462,820 lbs/yr x 0.10 x (1 – 0/100) x {1 – (0/100) x (0/100)} = 46,282 lbs/yr = 23.1 TPY

Since PSD analysis was not triggered, modeli ng to determine compliance with the NAAQS was not required. There are other regulatory standards that lim it emissions. All printing operations are subject to Subpart KK. Emissions of HAPs ar e limited at this facility by Subpart KK to 400 kilograms per month. In addition to restrictio ns on HAP emissions, these units have a large
amount of VOC emissions. Non-HAP emissions ma y become subject to the requirements of OAC 252:100-42. As previously noted, the draft per mit was revised to scale down the requirements for complian ce with OAC 252:100-41, which was replaced by OAC 252:100-42, a far less restrictive rule as applied to this facility. Ther efore, no evaluation of TACs was done. The applicant has requested to combin e the limits of FP-7 and FP-8 in to the limits proposed for FP-1 in the Title V application, i.e., a combined total limit of 92.28 TPY.

Plates are produced for use with all of the mill plant’s existing flexographic printers. The new printer will also utilize the flex o-plate making service. VOC-cont aining solvents are used in the finishing step of plate-making. A detailed discussi on of the emissions is included for that process. The applicant has indicated that th ese emissions will not be increased as a result of the new printer. Even though the new printer could increase the PTE of the Flexo-plate making process as a result ofPERMIT MEMORANDUM 99-113-TV (M-9) 39

increased demand, agai n the applicant is requesting an enforcea ble limit. That limit is included in this Title V permit.

EUG 6 – VOC Sources Not Subject to a NSPS or NESHAP

Emission

Factors Throughput (tons VOC /yr) Control Efficiency VOC Emissions (TPY) PO-1/Flexographic Polyethylene Printer

VOCs Uncontrolled (1) 30% (2) 197.05 NA 59.12 (3)

VOCs Controlled (1) 70% (2) 197.05 95% 6.90 FP-1, FP-7, & FP-8 Flexographic Paper Printers

VOCs Uncontrolled (1) 10 % VOC (4) 922.76 Tons Ink/yr No Controls 92.28 (5)

(1) Based on 1998 actual emissions. (2) Based on 100% of evaporation of maximum solvent content of printing inks and solvents used in platemaking (3) The permit limit is 99 TPY fr om Permit No. 83-062-0 (PSD). (4) An estimated 10% of ink volume is VOC and evaporates at 100% evaporation rate (5) The permit limit of 0.98 TPY for FP-7 from Permit No 97-218-C and the proposed limit for FP-8 were combined with the applicant’s original propo sed Title V limit of 92.28 for FP-1.

EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP

Paper Machines Paper fibers are released into the atmosphere via the drying, trimming, handling and slitting of the paper sheet. Emissions were calculated using stack test data from a sister mill in Rincon, Georgia. Results from the 2002 stack test ing of Rincon’s #19 Paper Machine drying hood indicated 0.465 lbs/hr of par ticulate matter generated, of which, 0.415 lbs/hr was not due to burning natural gas. The emission factor was c onverted to units of lbs PM/ton paper produced and multiplied by a contingency factor of 2. 0 to account for particulate matter emissions generated by the wet end of the paper machine.

Stack test data (November 2001) from the roof vents in the building above the No. 19 paper machine was also collected at the Rincon Mill and the results of that testing were 0.875 lbs/hr of particulate matter generated. This factor was also converted to units of lb PM/ton paper produced.

It should be noted that emissi ons measured from the Rincon, Georgia Plant were reported in units of mass per unit volume. Paper throughput was not reported in the test report. Relating the emissions to throughput as an emission factor is a relationship assumed by the applicant in their
estimation of emissions.

The two factors were then summed for an over all combined factor. Using this combined emission factor for Muskogee’s paper machines, an estimate of particulate emissions from the processes described above and from the roof vents was calculated based upon estimated paper production used in Title V potential-to-emit calculati ons in the original a pplication, resulting in
total emissions as illustrated in the table below.PERMIT MEMORANDUM 99-113-TV (M-9) 40

Control Efficiency PM Emissions (TPY)

PM-11 None 9.31

PM-12 None 13.03

PM-13 None 11.17

PM-14 None 11.17

PM-15 None 10.29

Total 54.97

PM-15 Dust Collection System Paper machine PM-15 is equipped with a dust colle ction system that is specifically designed to reduce dust inside the paper mach ine building. Reducing the dust in the paper machine building allows the employees to work in the area without the use of a respirator , which could otherwise be required by OSHA due to employee exposure limits . The system utilizes a wet scrubber to filter collected dust prior to discharge. The PM emissions listed above for PM-15 are potential emissions without this collection system ope rating. Since emissions will be permitted at potential levels, no monitoring or recordkeepi ng will be required for this collection system.

Hazardous Air Pollutants (HAPs) a nd Toxic Air Contaminants (TACs) The Toxic Air Contaminants (TACs) and Secti on 112(a) Hazardous Air Pollutants (HAPs) that are emitted from the processes were discussed in va rious sections of the original draft permit for public notice. Because of the le ngth and details and the recent non-applicability of TACs, those numbers were not repeated in the final version of the original Title V permit nor will they be included in this permit.

SECTION V. PSD REVIEW

Three PSD permits and evaluations have been issu ed during the life of this plant. Air quality impacts on the Ambient Air Quality Standards and increment analyses were evaluated for the
issuance of Permit Nos. 75-053-C & O a nd 77-076-C & 77-076-O. PSD/Modeling/BACT evaluation was performed for Permit No. PSD-OK-404. A PSD analysis performed for Permit
No. 83-062-O PSD addressed VOC emissions from the PO-1 Plant (flexographic printing and platemaking). The most recent modeling was that performed for construction permit No. 99- 113-C (M-3) (PSD). Because work included in that permit is ongoing, that modeling is not
discussed here.

SECTION VI. INSI GNIFICANT ACTIVITIES

Polyethylene Extruder In estimating VOC emissions from the Poly Plant extruder processes, emission factors from a 1996
article in the Journal of the Air and Waste Ma nagement Association (J AWMA) were used for linear low density polyethylene (LLDPE) blown film at a 355 o F melting temperature. The polyethylene (poly) film produced at the Poly Plant is a blown film process using 20 – 22 % LLDPE at a melting temperature of approximately 350 o F. Other emission factors associated with the JAWMA document refer to either high-d ensity blow molding or extrusion coating. Neither of these processes matches the process at the Poly Plant.PERMIT MEMORANDUM 99-113-TV (M-9) 41

VOC and TAC/HAP emissions were calculated using the emission fact ors developed in the JAWMA study in units of lbs emissions/million pounds poly extruded. These factors were then multiplied by the future potential extrusion rate in pounds/year and converted to tons/year in the following table. In 2002, the Poly Plant produced 5,020,914 pounds of poly, and in 2003, 5,358,174 pounds were produced. The future poly produc tion rate used to calculate a potentialto-emit is estimated at 6.0 MM lbs/yr.

EUG 6 – VOC/TAC/HAP/PM Emission s from Polyethylene Extruder
CAS # Factor ( lbs/MMlb) Film Mfg’d. ( MMlbs/yr) Emissions (TPY)

VOC – Extruder --------- 8.0 6.0 0.024
TAC/HAP’s

Ethane 74-84-0 0.02 6.0 0.00006 Ethylene 74-85-1 0.01 6.0 0.00003 Propylene 115-07-1 0.01 6.0 0.00003 Formaldehyde 50-00-0 0.09 6.0 0.00027

Acrolein 107-02-8 0.02 6.0 0.00006 Acetaldehyde 75-07-0 0.03 6.0 0.00009 Propionaldehyde 123-38-6 0.02 6.0 0.00006

Acetone 67-64-1 0.08 6.0 0.00024 Methyl ethyl ketone 78-93-3 0.02 6.0 0.00006

Formic acid 64-18-6 0.17 6.0 0.00051

Acetic acid 64-19-7 0.17 6.0 0.00051 Acrylic acid 79-10-7 0.02 6.0 0.00006

In estimating PM emissions from the Poly Plant resin handling processes, calculation of emissions from resin storage and handling is based on an emission factor from AP-42, Table 6.6.2-1 (rev. 9/91, reformatted 1/95), Fifth Edition, for storage of dimethyl terephthalate in Poly (ethylene terephthalate) resin production pr ocesses. Using an emission fact or of 0.017% and a resin usage rate of 6.0 MM lbs/yr yields PM emissions of 0.51 TPY or 0.12 lbs/hr. There is no poly recycling operation at the Poly Pl ant, since all scrap is sold. A small amount of trim is re-melted
and returned direc tly to the die.

Emission Factors (%) Polyethylene Throughput (MMlbs/yr) Emissions (TPY)

PM – Resin Storage & Handling 0.017 6.0 0.51

(lbs/MMlbs)

PM - Extruder 2.4 6.0 0.0072

Boiler Ash Handling Following is an evaluation performed by the appli cant based on some research of two coal-fired power plants. One was permitted in Colorado, and the other in Kentucky.PERMIT MEMORANDUM 99-113-TV (M-9) 42

Both permits used AP-42 to estimate particulate matter emissions from boiler ash handling operations. One permitting agency adapted AP-42 for clay and fly ash sintering at Chapter 11.8. The other agency adapted AP-42 for cement batc hing at Chapter 11.12. Fly ash sintering factors are uncontrolled, where as cement batching offers controlled and uncontrolled emission factors. The boiler ash silos are equipped with baghouses th at control emissions with a 99.9% efficiency. The applicant believes that cement exhibits very similar physical characteristics as boiler ash and therefore used the cement batching factors for th e following emission estimate of silo emissions.

Ash generation was estimated using 600,000 TPY of coal at 8.5% ash. The applicant used this as a worse case ash content for all high Btu coal. However, it should be noted that the permit contains conditions limiting ash content to lower values. Both fly ash and bottom ash are pneumatically conveyed to elevated silos equipped with identical baghous es. The ash is then loaded into enclosed trucks and disposed in th e mill’s permitted on-site landfill cells. According to Table 11.12-2, total PM emissions from Cement supplement unloading to elevated storage silo (pneumatic) are 0.0089 lbs PM/to n controlled and 3.14 lbs/ton uncontrolled. Estimating a maximum potential ash generation of approximate ly 51,000 TPY, potential PM emissions would equate to 454 lbs/year.

For truck loading, dumping and pile erosion, Chapter 13.2.4 Aggregate Handling and Storage Piles, was used.

From Section 13.2.4:

E (lbs/ton) = k*0.0032 * (U/5) 1.3 / (M/2) 1.4

where: k = 0.35 for PM 10 , U = wind speed (15 mph, worst case value from Ranges of Source Conditions), and M = moisture content (0.25 %, worst cas e value from Ranges of Source Conditions) Applying the above factors, E = 0.0859 lbs PM/ton of ash.

At 51,000 TPY of ash, PM emissions would equal 4,381 lbs/year from truc k loading, dumping, and pile erosion. This yields a total of 4,835 lbs/year of PM em issions for all of ash handling.

Converting Trim Vent Following is an evaluation performed by the app licant based on emissions information obtained from a sister facility in Green Bay, Wisconsin.

At the subject facility, scrap paper from the conve rting operations, called “t rim” or “broke,” is conveyed to the converting broke pulper to be mixed with water for reuse in the papermaking process. Much of the broke is transported in carts and dumpsters to a pulper or removed pneumatically from the point of generation a nd dumped on an overhead conveyor to a pulper. Some of the broke, however, is conveyed pneumati cally all the way to the top of a pulper where airborne particulate is removed from the air stream, and the air stream is cleaned by a baghouse before discharge to the atmosphere. This operational scenario describes the ConvertingPERMIT MEMORANDUM 99-113-TV (M-9) 43

operations at the subject facility as well as Conver ting operations at a sister tissue facility located in Green Bay, Wisconsin.

The Green Bay facility had stack testing performed on three stacks from their trim collection system. Those stack emissions totaled 7.22 lbs/ hr (31.6 TPY), uncontrolled. The trim collection system at the subject facility is equipped with baghouses having collection efficiency ratings of 99.9% prior to discharge to the atmosphere. At 7.22 lbs/hr and 99.9% collection efficiency,
annual emissions would e quate to 63.2 lbs/year.

Printed Napkins Printed napkins are printed by a group of eight (8 ) letterpress printing pre sses in the converting area. These presses do not perform publication ro togravure, product and packaging rotogravure, or wide-web flexographic printing and are no t subject to the printi ng and publishing MACT, Subpart KK. They were not included in th e Title V application because as a group their emissions are below 5 TPY VOC. Collectively, VOC emissions have increased to near 5 TPY. Individually, however, emissions are still well below this threshold.

Corona Treaters The Enercon Corona Treater Station, Model ASO12V -160, generates a corona that is used to treat the polyethylene film produced at the Polyethylene Plant. This treatment allows for enhanced ink bonding to the film. Ozone is genera ted as a result of treat ing the film in this
manner. The ozone from this source is vented to the atmosphere w ithout any controls.
Emissions of ozone from this vent line have been calculated to be 0.365 lbs/hr (1.599 TPY)
based on manufacturer’s data that the Enercon Corona Treater St ation is designed to produce 0.073 lbs/hr of ozone per KvA (kilovolt-ampere) and the maximum input of electricity is 5.0
KvA. There are no emission control devices attached to this system.
A second corona treater was installed for use when the primary system is down or when there are special printing needs that call for the film to be re -treated prior to printing. It is installed on the flexographic printer with an ozone decomposer mounted downstream. The decomposer is 95% effective and reduces generate d ozone to molecular oxygen. Em issions are exhausted to the atmosphere outside to the south of the building. This corona treater is seldom used and is currently present as a back-up system. The perm it allows for simultaneous operation of the two

corona treaters.

83-062-O (PSD)

Stack Source Power Input Emissions

Factor Ozone
Emissions

Lbs/hr TPY

1 Enercon Corona Treater M odel ASO12V-160 5 Kva 0.073
lbs/Kva 0.365 1.599

2 & 3 Enercon Corona Treater Model ASO41V-300 with Decomposer Model 03X-16 10 Kva 0.073
lbs/Kva 0.0365 0.1599

The insignificant activities identified and justif ied in the application are duplicated below.
Records must be available to confirm the in significance of the activities. Appropriate recordkeeping of activities indi cated below with “*” is specif ied in the Specific Conditions.PERMIT MEMORANDUM 99-113-TV (M-9) 44

1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr heat input (commerc ial natural gas). The applicant operates several space heaters at the facility. 2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. There is one abovegro und 10,000-gallon gasoline tank ex isting at the facility. The facility used only 9,500 gallons from this tank during the year 2003. This tank is equipped with a submerged fill pipe. 3. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. There are seve ral aboveground diesel tanks at the facility including a 100,000-gallon No. 2 diesel tank used to fuel a locomotive and some heavy equipment. 4. * Emissions from storage tanks constructe d with a capacity less than 39,894 gallons which store VOC with a vapor pressu re less than 1.5 psia at maximum storage temperature.
There are several diesel and so lvent tanks at the facility. 5. Additions or upgrades of instrumentation or control systems that result in emissions increases less than the pollutant quantiti es specified in OAC 252:100-8-3(e)(1). 6. Cold degreasing operations utilizing solvents th at are denser than air. There are numerous activities under this category.
7. Site restoration and/or bior emediation activities of < 5 year s expected duration. There are
no activities under this category at the facility at this time. 8. Hydrocarbon contaminated soil aeration pads u tilized for soils excavated at the facility only. There are no activities under this category at the facility at this time. 9. Emissions from the operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics (OAC 252:100-41-43) and HA Ps (§112(b) of CAAA90). The facility currently operates groundwater monitoring well s that are required by the facility’s solid waste landfill permits. There are no groundwater remediation wells at th e facility at this
time. 10. * Non-commercial water washing operations (less than 2,250 barrels/year) and drum crushing operations of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material.
11. Hazardous waste and hazardous materials dr um staging areas. There are numerous activities under this category. 12. Sanitary sewage collection and treatment fac ilities other than incine rators and Publicly Owned Treatment Works (POTW). Stacks or ve nts for sanitary sewer plumbing traps are also included (i.e., lift station). All of the f acility’s sanitary sewage is collected by two lift stations and discharged to the local POTW.
13. Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation. 14. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. There are numerous activities under this
category.PERMIT MEMORANDUM 99-113-TV (M-9) 45

15. Hand wiping and spraying of solven ts from containers with less than 1 liter ca pacity used for spot cleaning and/or degreasing in ozone attainment areas. There are numerous activities under this
category. 16. * Activities having the potential to emit no mo re than 5 TPY (actual) of any criteria pollutant (see instructions). a. Boiler Ash Handling b. Converting Trim Vent c. Printed Napkins d. PO-1 Polythylene Extruder, Glouces ter Engineering, M odel #264-001, Serial #264-
28879-001 17. Vacuum cleaning systems used exclusively for industrial, commercial, or residential housekeeping purposes, except those systems used to collect particulate matter subject to
252:100 and hazardous and/or toxic air contaminants.

SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference app licable provisions of Title 40 of the Code of Federal Regulations listed in OAC 252:100, Appendi x Q. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standa rds and Increments) [Applicable] Subchapter 3 enumerates the primary and se condary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these standards. In addition, modeled emissions from the proposed facility (for previous permits) demonstrated that the facility would not have a significant impact on air quality.

OAC 252:100-5 (Registration, Emissions Invent ory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories were submitted and fees paid for previous years as required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]
Part 5 includes the general administrative requir ements for Part 70 permits. Any planned changes in the operation of the facility that resu lt in emissions not authorized in the permit and that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may requi re a permit modification. Insigni ficant activities refer to those
individual emission units either listed in Appendix I or whose actual calendar year emissions do not exceed the following limits.

• 5 TPY of any one criteria pollutantPERMIT MEMORANDUM 99-113-TV (M-9) 46

• 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from existing permits, the permit application, or developed from the applicable requirement.

OAC 252:100-9 (Excess Emissions Re porting Requirements) [Applicable] Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following working day of the first occurrence of excess emi ssions in each excess emission event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess emission event describing the exte nt of the event and the actions taken by the owner or operator of the facility in response to this event. Request for affirmative defense, as described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional reporting may be required in the case of ongoi ng emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable] Open burning of refuse and other combustible mate rial is prohibited except as authorized in the specific examples and under the cond itions listed in this subchapter.

OAC 252:100-19 (Particulate Matter (PM)) [Applicable] Section 19-4 regulates emissions of PM from the combustion of fuel in any new and existing fuel-burning unit, with emission limits base d on maximum design heatinput rating. Fuelburning unit is defined in OAC 252:100-19 as any internal combustion engine or gas turbine, or
other combustion device used to convert the co mbustion of fuel into usable energy. Thus, Boilers B-1, B-2, B-3, and B-4, Paper Mach ine Drying Hoods PM- 11, PM-12, PM-13, PM-14, and PM-15, and the PO-1 Tunnel Dryer (Flexogra phic Polyethylene Printer) are subject to the requirements of this subchapter. AP-42 (7/98) Table 1.4-1 lists natural gas Total Particulate Matter (TPM) emissions to be 7.6 lbs/million scf or about 0.0076 lbs/ MMBTU, which is in compliance. AP-42 (9/98) Tables 1.3-1 and 1.3-2 lists TPM emissions factors for #6 fuel oil. This represents a highly conservative estimate compared to #2 fuel oil. Converti ng these factors to units of lbs/MMBtu yields the values illustrated in the tables below, which are in compliance with the allowable. Compliance with the applicable standard while burning coal was verified by stack testing. The following table illustrates complian ce for all combustions units burning any of the permitted fuels. It should be not ed that the emissions factors are uncontrolled factors, i.e., they do
not take into account emissions controls.

EMISSION

UNIT COAL
Emission

Factor NAT. GAS
Emission

Factor FUEL OIL
Emission

Factor APP. “C”
Allowable

Boiler B-1

310 MMBTUH NA 0.0076 0.07 ( 3 ) 0.27

Boiler B-2 Hi Btu Coal 0.032 ( 1 )

, ( 2 ) 0.0076 0.07 ( 3 ) 0.24PERMIT MEMORANDUM 99-113-TV (M-9) 47

440 MMBTUH Lo Btu Coal 0.027 ( 1 )

, ( 2 ) 0.0076 0.07 ( 3 ) 0.24

Boiler B-3

557 MMBTUH 0.005 ( 1 )

, ( 2 ) 0.0076 0.07 ( 3 ) 0.23

Boiler B-4

557 MMBTUH 0.015 ( 1 )

, ( 2 ) 0.0076 0.07 ( 3 ) 0.23

(1) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous (2) - Stack tests, conducted on January 7, 8, 9, 2003 for B-2, May 20 & 21, 2003 for B-3, and April 15 & 16,
2003 for B-4 (3) - Heating value for No. 2 Fuel Oil = 0.14 MMBtu/ga l, Heating value for No. 6 Fuel Oil = 0.15 MMBtu/gal

EMISSION UNIT NATURAL GAS
Emission Factor FUEL OIL
Emission Factor APP. “C”
Allowable

Paper Machine PM-11

(24 MMBTUH x 2) 0.0076 0.07 0.41

Paper Machine PM-12

(16.5 MMBTUH x 2) 0.0076 0.07 0.45

Paper Machine PM-13

(16.5 MMBTUH x 2) 0.0076 0.07 0.45

Paper Machine PM-14

(24 MMBTUH x 2) 0.0076 0.07 0.41

Paper Machine PM-15

(25 MMBTUH x 2) 0.0076 0.07 0.41

PO-1 Catalytic Incinerator

(2.0 MMBTUH) 0.0076 0.07 0.60

Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units and emission points in an industrial process ba sed on process weight rate, as specified in Appendix G. The following table illustrates the calculated hourly rates of PM emissions. All emission points are in compliance with the Subchapter 19 limits.

Paper Machines and Coal Preparation Plant

EMISSION UNIT Emissions (lbs/hr) Limit (lbs/hr)

PM-11 2.1 19.7

PM-12 3.0 24.7

PM-13 2.6 22.3

PM-14 2.6 22.3

PM-15 2.3 21.1 (TPY Coal) Railcar Unloading, Radial St acker, Grizzly Feeder 519,362 5.09 46.2

Coal Sizer/Crusher 519,362 11.86 46.2 Conveying 519,362 1.18 46.2

Coal Bunkers 519,362 1.18 46.2 Coal Feeders, Pulverizers Closed Process, No emissions

FS-1 Coal Pile Emissions included with abovePERMIT MEMORANDUM 99-113-TV (M-9) 48

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except fo r short-term occurrences that consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecu tive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. Boilers B-1, B-2, B- 3, and B-4 are not subject to Subchapter 25 since they are subject to an opacity limitation in NSPS Subpart D. Other combustion units are subject to this standard. Those fired with na tural gas are therefore no t likely to exceed this standard. Equipment subject to a Subpart Y opac ity limitation at the Coal Preparation plant is not subject to Subchapter 25.

OAC 252:100-29 (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originated in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate this requirement; th erefore it is not necessary to require specific precautions to be taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]
Part 5 limits sulfur dioxide emissions from new fu el-burning equipment (constructed after July 1, 1972). The limits, based on heat input, are 0.2 lbs/MMBTU for gaseous fuels, 0.8 lbs/MMBTU for liquid fuels, and 1.2 lbs/MMBTU for solid fuels. The averaging time for the emission limits is 3 hours unless a solid fuel sampling and anal ysis method is used to determine emission compliance. In that case the av eraging time is 24 hours. Testing was done for emissions from coal combustion, which demonstrated emissions from this fuel were well within the limits. Specific conditions in the permit limiting fuel sulfur content for the various fuels will ensure compliance with the limits when these fuels are used. The table below illustrates compliance
based on the emission calculations illustrated in the permit memorandu m. It should be noted that the values for natural gas combustion are based on AP-42 emission factors.

EMISSION UNIT NAT. GAS
Emission Factor FUEL OIL
Emission Factor COAL
Emission Factor

B-1

310 MMBTUH 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu NA

B-2
440

MMBTUH Hi Btu Coal (1) 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu 0.644 lbs (4)

MMBtu

Lo Btu Coal (1) NA NA 0.267 lbs (4)

MMBtu

B-3
557 MMBTUH 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu 0.403 lbs (4)

MMBtu

B-4
557 MMBTUH 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu 0.631 lbs (4)

MMBtu

PM-11 (24 MMBTUH x 2) 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu NA

PM-12 (16.5 MMBTUH x 2) 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu NAPERMIT MEMORANDUM 99-113-TV (M-9) 49

PM-13 (16.5 MMBTUH x 2) 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu NA

PM-14 (24 MMBTUH x 2) 0.0006 lbs (2)

MMBtu 0.69 lbs (3)

MMBtu NA

PM-15 (25 MMBTUH x 2) 0.0006 lbs (2)

MMBtu NA NA

(1) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous (2) - AP-42, Table 1.4-2 (7/98) (3) - AP-42, Table 1.3-1 (9/98), SO 2 = 157S lbs/10 3 gal, S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil Heating value for No. 2 Fuel Oil = 0.14 MMBtu/gal, Heating value for No. 6 Fuel Oil = 0.15 MMBtu/gal (4) - Stack tests, conducted on January 7, 8, 9, 2003 for B-2, May 20 & 21, 2003 for B-3, and April 15 & 16,
2003 for B-4

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable] This subchapter limits new gas- fired, liquid-fired, and solid fo ssil fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20, 0.30, and 0.70 respectively, lbs of NO X per MMBTU, three-hour average. Only boilers B-1, B-2, B-3, and B-4 exceed the 50 MMBTUH threshold and are subject to these standards. Paper Machine PM-15 has a total heat input rating, al l burners combined, of 50 MMBTUH and is also s ubject. The table below illustrates compliance based on the emission calculations illustrated in the permit
memorandum.

EMISSION UNIT COAL
Emissions

Factor NATURAL GAS
Emissions Factor FUEL OIL
Emissions

Factor

B-1

310 MMBTUH NA 0.138 lbs ( 1 )

MMBtu 0.21 lbs ( 1 )

, ( 4 )

MMBtu

B-2

440 MMBTUH NO X (Hi Btu Coal) (6) 0.52 lbs ( 1 )

, ( 3 )

MMBtu 0.19 lbs ( 5 )

MMBtu 0.21 lbs ( 1 )

, ( 4 )

MMBtu

NO X (Lo Btu Coal) (6) 0.38 lbs ( 1 )

, ( 3 )

MMBtu NA NA

B-3

557 MMBTUH 0.27 lbs ( 1 )

, ( 3 )

MMBtu 0.187 lbs ( 2 )

, ( 5 )

MMBtu 0.26 lbs ( 1 )

, ( 4 )

MMBtu

B-4

557 MMBTUH 0.41 lbs ( 1 )

, ( 3 )

MMBtu 0.19 lbs ( 5 )

MMBtu 0.29 lbs ( 2 )

, ( 4 )

MMBtu

PM-15

50 MMBTUH NA 100 lbs ( 5 )

MMCF NA

NA – Not Applicable (1) -20% contingency added (2) -10% contingency added (3) -Stack tests, conducted January 7-9, 2003, for B-2, May 20-21, 2003, for B-3, and April 15-16, 2003, for B-4 (4) -AP-42, Table 1.3-1 (9/98), S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil (5) -AP-42, Table 1.4-1 (7/98) (6) -Lo Btu coal is sub-bituminous, Hi Btu is bituminous

OAC 252:100-35 (Carbon M onoxide) [Not Applicable] This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum catalytic cracking units, and petr oleum catalytic reforming units. There are no affected sources.PERMIT MEMORANDUM 99-113-TV (M-9) 50

OAC 252:100-37 (Volatile Organi c Compounds) [Part 7 Applicable]

Part 3 requires storage tanks cons tructed after December 28, 1974, w ith a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an orga nic vapor recovery system. The two underground 10,000-gallon gasoline tanks installed under Permit No. 75-053-C no longer remain. One aboveground 10,000-gallon gasoline tank is existing at the facility. This tank is equipped with a submerged fill pipe.
Part 5 limits the VOC content of coating used in co ating lines or operations. This facility will not normally conduct coating or paintin g operations except for routine maintenance of the facility and equipment, which is not an affected operation.

Part 7 requires fuel-burning equipment to be opera ted and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete combustion. All fuel-burning equipment at this facility including the boilers, paper machine drying hoods, PO-1 tunnel dryer, and catalytic oxidizer are designed to provide essentially complete combustion of organic materials.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable] This subchapter regulates toxic air contaminants (TAC) that are emitted in to the ambient air in areas of concern (AOC). Any wo rk practice, material substituti on, or control equipment required by the Department prior to June 11, 2004, to c ontrol a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirement s for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Okla homa to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing mu st be conducted by methods appr oved by the Air Quality Director and under the direction of qualified personnel. A no tice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any fede ral or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conduc ted in accordance with the provisions of this subchapter shall be considered invalid. Nothi ng shall preclude the use, including the exclusive use, of any credible evidence or information re levant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-7 Permits for Minor Fa cilities not in source categoryPERMIT MEMORANDUM 99-113-TV (M-9) 51

OAC 252:100-11 Alternative Emi ssions Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevator s not in source category

OAC 252:100-35 Carbon Monoxide not in source category

OAC 252:100-39 Nonattainment Areas not in area category

OAC 252:100-47 Landfills not in source category

SECTION VIII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not App licable to this Permit] PSD does not apply to this permit since there are no proposed emission increases. Future emission increases must be evaluated against the threshold levels of CO - 100 TPY, NO X - 40 TPY, SO 2 - 40 TPY, VOC - 40 TPY, PM - 25 TPY, PM 10 - 15 TPY, and Lead - 0.6 TPY.

NSPS, 40 CFR Part 60 [Subp arts D and Y Applicable] Subpart D – Standards of Performance for Fossil- Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971 (§§60.40-60.46), affects each fossil-fuelfired steam generating unit more than 73 megawa tts heat input rate (250 million Btu per hour). Boilers B-1, B-2, B-3, and B-4 ar e all rated above this threshol d and are therefore affected
facilities. §60.42, § 60.43, & §60.44 – contain standards for partic ulate matter, sulfur dioxide, and nitrogen oxides. The standard for particul ate matter is 0.10 lbs/MMBtu from fossil fuel or
fossil fuel and wood residue with no greater than 20% opacity except for one six-minute period per hour of not more than 27% opacity. The standard for SO 2 is 0.8 lbs/MMBtu from liquid fossil
fuels and 1.2 lbs/MMBtu from solid fossil fuels. The standard for NO X is 0.2 lbs/MMBtu from gaseous fossil fuel, 0.30 lbs/MMBtu from liquid fossil fuels, and 0.7 lbs/MMBtu from solid
fossil fuels. Boiler B-1 is not permitted to burn coal. All four boilers are perm itted to burn fuel oils and natural gas. Initial compliance testing for coal combus tion was performed for Bo ilers B-2, B- 3, and B-4. Initial compliance tes ting for B-1 was performed in June 1980. §60.45 - Contains requirements for calibration, maintenance, and operation of continuous monitoring systems for measuring the opacity of emissions, sulfur dioxide emissions, nitrogen oxides emissions, and either oxygen or carb on dioxide except as provided in paragraph §60.45(b). For a fossil fuel-fired steam generator that does not use a flue gas desulfurization device, a continuous monitoring system for measuri ng sulfur dioxide emissi ons is not required if the owner or operator monitors su lfur dioxide emissions by fuel sampling and analysis. If the owner or operator demonstrates during the performa nce test that emissions of nitrogen oxides are less than 70 percent of the a pplicable standards in §60.44, a c ontinuous monitoring system for measuring nitrogen oxides emissions is not required. If an owner or operator does not install any continuous monitoring systems for sulfur oxides and nitrogen oxides, a continuous monitoring system for measuring either oxygen or carbon dioxide is not required. The facility is required to continuously monitor opacity. Subpart Da - Standards of Performan ce for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978 (§§60.40a - 60.49a), affects each electricPERMIT MEMORANDUM 99-113-TV (M-9) 52

utility steam generating unit that is capable of combusting more than 73 megawatts (250 million Btu/hour) heat input of fossil fuel (either alone or in combinati on with any other fuel) and for
which construction or modification is commenced after September 18, 1978. Electric utility steam generating unit means any steam electric generating unit that is constructed for the purpose of supplying more than one-third of its pot ential electric output capacity and more than 25 MW electrical output to any util ity power distribution system fo r sale. Any steam supplied to a steam distribution system for the purpose of pr oviding steam to a steam-electric generator that would produce electrical energy fo r sale is also considered in determining the electrical energy output capacity of the affected facility.
Boilers B-3 and B-4 were constructed in 1978 and 1981, respectively, but do not meet the
definition of electric utility steam generating unit . The boilers are therefore not subject to the requirements of this subpart. Subpart Db - Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (§§60.40b - 60.49b), affects each steam generating unit that commences construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam ge nerating unit of greater than 29 MW (100 million Btu/hr). Construction of the boilers commenced prior to the effective da te and have not been
modified or reconstructed and ar e therefore not subject to the requirements of this subpart. Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (§§60.40c - 60.48c), affects 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 29 MW (100 MMBtu/hr) or less, but greater than or equal to 2.9 MW (10 MMBtu/hr). The boilers were constructed prior to the effective date and are rated at greater than
100 MMBtu/hr. The boilers are therefore not su bject to the requirement s of this subpart. Subpart Y - “Standards of Performance fo r Coal Preparation Plants,” are applicable to any of the following affected facilities that commenced construction or modification after October 24, 1974, in coal preparation plants which process more than 181 Mg (200 tons) per day: Thermal dryers, pneumatic coal-cleaning equipment (a ir tables), coal pr ocessing and conveying equipment (including breakers and crushers), coal storage systems, and coal transfer and loading
systems. Coal preparation plant means any facility (excluding underground mining operations) which prepares coal by one or more of the following processes: breaking, crushing, screening, wet or dry cleaning, and thermal drying. The coal preparation plant does not have thermal dryers, pneumatic coal-cleaning equipment, or coal transfer and loading systems. All other facilities in the coal preparation plant, except the coal pile, are subject to this rule. Coal storage system means any facility used to store coal except for open storage piles. In an Analysis Regarding Regulatory Status of Fugitive Emissions From Coal Unloading at Preparation Plants , dated October 3, 1997, from the EPA to Congresswoman Barbara Cubin, it was noted that “if coal is unloaded for storage, then the unloading activity is not an affected facility under NSPS Subpart Y. The coal must be directly unloaded into receiving equipment, such as a hopper to be subject to the provisions of NSPS Subpart Y. ” Cited as key phrases in the
definition of Coal processing and conveying equipment were “equipment used to convey coal to ------------- machinery” and “but is not limited to” (page iii). The second phrase only supports the case of applicability where co al is directly unloaded into receiving equipment. For this facility, where coal is unloaded to a coal pile , the first phrase supports the non-applicability of the rule. Therefore, the coal pile and precedi ng unloading/conveying equipm ent are not affectedPERMIT MEMORANDUM 99-113-TV (M-9) 53

facilities. However, it was also concluded “fugitive emissions from coal dumping at the site of a coal preparation plant must be c ounted in determining whether a coal preparation plant is a major source subject to the Title V permitting requirements (cover letter). Whether a facility has been regulated as an affected facility does not determ ine whether fugitive emissions from that facility
are to be counted in de termining whether the source as a whol e is major under TV. Rather, if the facility is part of a source that falls within a source category which has been listed pursuant to section 302(j) of the Act, then all fugitive emissions of any regulated air pollutant from that facility are to be included in determining whether that source is a major stationary source under Section 302 or part D of Title I of the Act an d accordingly required to obtain a Title V permit” (page iv). Coal processing and conveying equipment means any machinery used to reduce the size of coal or to separate coal from refuse, and the equipm ent used to convey coal to or remove coal and refuse from the machinery. This includes, but is not limited to, breakers, crushers, screens, and conveyor belts. Therefore, all processes de scribed here are subj ect to this rule.

NESHAP, 40 CFR Part 61 [Poten tially Subpart M Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for small amounts of mercury from the boilers which are covered by NSPS Subpart D and will become subject to NESHAP Subpart DDDDD. Subpart M – National Emission Standards for Asbestos. The facility may be subject to certain regulations pertaining to the construction, demolition, and dispos al of asbestos-containing
materials.

NESHAP, 40 CFR Part 63 [Subpart KK Applicable] Subpart S – National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry, affects both new and ex isting processes that produce pulp, paper, or paperboard located at a major source that use: (1) Kraft, soda, or semi-chemical pulping processes using wood; or (2) Mechanical pulping processes using wood; or (3) Any process using secondary or non-wood fibers. Equipment listed in § 63.444 (a) are required to be enclosed and vented into a closed-vent system and routed to a control device. Geor gia-Pacific uses secondary wood (recycled paper) fiber and is an affected facility. However, as a result of the processe s and bleaching chemicals used in producing the secondary fiber pulp, the facil ity is not subject to any of the standards in the subpart. Subpart KK - National Emission Standards for the Pr inting and Publishing Industry, applies to each new and existing facility th at is a major source of hazar dous air pollutants (HAP), as defined in 40 CFR 63.2, at which publication rotogr avure, product and packaging rotogravure, or wide-web flexographic printi ng presses are operated and ar ea sources as outlined in §63.820(a)(2). For product and packaging, affect ed sources include all of the product and packaging rotogravure or wide-web flexographic printing presses at a facility plus any other equipment at that facility which the owner or operator chooses to include in accordance with paragraph §63.821(a)(3) of this section, except pr oof presses, and any product and packaging rotogravure or wide-web flexogra phic press which is used primar ily for coating, laminating, or other operations which the owner or operator choos es to exclude under cert ain provisions listed
in this section. The owner or operator of product and packag ing rotogravure, or wide-web flexographic printing presses may al so elect to include in that affected source stand-alone coatingPERMIT MEMORANDUM 99-113-TV (M-9) 54

equipment subject to certain provi sions listed in this section. The following lists the affected

sources:

EU

ID EU Name Manufacturer/Model No. Construct

Date PO-1 Flexographic Polyethylene Prin ter Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer June, 1984

FP-1 Flexographic Paper Printer Fle xo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6725 1997 FP-8 Flexographic Polyethylene Printer Bre tting, 4-color, 78-inch wide June, 2005 Each product and packaging rotogravure or wide-w eb flexographic printing affected source at a facility that is a major source of HAP, as de fined in 40 CFR 63.2, that applies no more than 400kg per month, for every month, of organic HAP on product and packaging rotogravure or wideweb flexographic printing presses, on and after th e applicable compliance date as specified in §63.826 of this subpart is subject only to th e recordkeeping requirements of §63.829(e) and reporting requirements of §63.830(b)(1 ) of this subpart. The owne r or operator is required to maintain records of the total volume and orga nic HAP content of each material applied on product and packaging rotogravure or wide-web flexographic printing presses during each month for five years, and upon request, submit them to the Administrator. Subpart MM - National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, S oda, Sulfite, and Stand-Alone Semi chemical Pulp Mills, applies to each kraft, soda, sulfite, or stand-alone se michemical pulp mill that is a major source of hazardous air pollutants ( HAP) emissions as defined in §63.2. Th e affected sources are: (1) Each existing chemical recovery system (as defined in §63.861) located at a kraft or soda pulp mill; (2) Each new nondirect contact evaporator ( NDCE) recovery furnace and associated smelt dissolving tank(s) located at a kraft or soda pul p mill; (3) Each new direct contact evaporator (DCE) recovery furnace system (as defined in §63.861) and associated smelt dissolving tank(s) located at a kraft or soda pulp m ill; (4) Each new lime kiln located at a kraft or soda pulp mill; (5) Each new or existing sulfite combustion un it located at a sulfite pulp mill, except such existing units at Weyerhaeuser Paper Company's Cosmopolis, Washington facility (Emission Unit no. AP–10); (6) Each new or existing semi chemical combustion unit located at a standalone semichemical pulp mill; (7) The requireme nts of the alternative standard in §63.862(d) apply to the hog fuel dryer at Weyerhaeuser Pa per Company's Cosmopolis , Washington facility (Emission Unit no. HD 14).
There are no such sources as listed above at this facility. Therfore, this subpart is not applicable. Subpart DDDDD, National Emission Standards for Hazar dous Air Pollutants for Industrial,
Commercial and Institutional Boilers and Proc ess Heaters. In Ma rch, 2007, the EPA filed a
motion to vacate and remand this rule back to th e agency. The rule was vacated by court order, subject to appeal, on June 8, 2007. No appeals we re made and the rule was vacated on July 30, 2007. Existing and new small gaseous fuel boilers and process heaters (less than 10 MMBtu/hrPERMIT MEMORANDUM 99-113-TV (M-9) 55

heat rating) were not subject to any standards, recordkeeping, or notifications under Subpart

DDDDD. EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting authorities should take regarding MACT determin ations under either S ection112(g) or Section 112(j) for sources that were affected sources under Subpart DDDDD and ot her vacated MACTs. It is expected that the guidance (or rule) will establish a new timeline for submission of section 112(j) applications for vacated MACT standards. At this time, AQD has determined that a 112(j) determination is not needed for sources po tentially subject to a vacated MACT, including Subpart DDDDD. This permit may be reopened to address Section 112(j) when necessary.

CAM, 40 CFR Part 64 [Not Applicable] This part applies to any pollutant-specific emi ssion unit at a major sour ce that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses “large emissions units,” or any appl ication that a ddresses “large emissions units” as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of the following criteria.

• It is subject to an emission limit or standard for an applicable regulated air pollutant

• It uses a control device to achieve compliance wi th the applicable emission limit or standard

• It has potential emissions, prior to the contro l device, of the applicable regulated air pollutant of 100 TPY

Boilers B-2, B-3, and B-4 use control devices to achieve compliance with the particulate matter standards of NSPS Subpart D and OAC 252:100-19. Potential pre-control emissions from these units equal or exceed major source levels (100 TP Y of a regulated pollutant or 10/25 TPY of a HAP), but they are not large emissions units sinc e post-control emissions do not equal or exceed 100 TPY. They will be subject to CA M upon renewal of the Title V permit.

Chemical Accident Prevention Provisi ons, 40 CFR Part 68 [Not Applicable] The emissions units subject to this determination do not process or store mo re than the threshold quantity of any regulated substance (Section 1 12r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: www.epa.gov/ceppo

.

Stratospheric Ozone Protection, 40 CF R Part 82 [Subpart F Applicable] These standards require phase out of Class I & II substances, reduc tions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-deple ting substances (Subparts A & C) ; control servic ing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximi ze the substitution of safe alternatives to Class I and Class II substances (Subpart D); requi re warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozon e-depleting compounds under the Significant New Alternativ es Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A applies to any person that produces, tran sforms, destroys, imports or exports a controlled substance or imports or exports a cont rolled product. It identifies ozone-depletingPERMIT MEMORANDUM 99-113-TV (M-9) 56

substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Cla ss I, Group V). A complete phaseout of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, sche duled in phases starting by 2002, is required by January 1, 2030. The facility does not conduct any of the affected processes and is therefore not subject to this rule. Subpart F applies to any person servicing, maintaini ng, or repairing appliances. This subpart also applies to persons disposing of appliances , including small appliances and motor vehicle air conditioners. In addition, this subpart applies to refrigerant reclaimers, technician certifying programs, appliance owners and operators, ma nufacturers of applia nces, manufacturers of recycling and recovery equipment, approved recycling and recovery equipment testing organizations, persons selling cl ass I or class II refrigerants or offering clas s I or class II refrigerants for sale, and persons purchasing class I or class II refrigerants . The purpose of this subpart is to reduce emissions of class I and cl ass II refrigerants and their substitutes to the lowest achievable level by maximizing the recaptur e and recycling of such refrigerants during the service, maintenance, repair, a nd disposal of applianc es and restricting the sale of refrigerants consisting in whole or in part of a class I a nd class II ODS in accordance with Title VI of the
Clean Air Act. The facility performs ma intenance that involves r ecycling and recovery of refrigerants. Standard Conditions included in the permit address required work practices to be used during the maintenance, service, repair, or disposal of appliances, leak re pair requirements, standards for recycling and recovery equipment, technician certification, and recor dkeeping requirements. Additional applicable require ments are found in the rule.

SECTION IX. COMPLIANCE

Inspection

An inspection is not required for this perm it modification since th ere is no physical or operational change being ma de at the facility.

Fee Paid

The applicant submitted the required fee of $500 for a minor modification to a Part 70 source permit.

Tier Classification and Public Review

This application has been classified as Tier I based on the request for an operating permit
modification that is mi nor under 252:100-8-7.2(b)(1).PERMIT MEMORANDUM 99-113-TV (M-9) 57

SECTION X. SUMMARY

There are no active Air Quality compliance or enfo rcement issues that would affect the issuance of this permit. Issuance of th e operating permit is recommended.PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS

Georgia Pacific Company Permit No. 99-113-TV (M-9) Georgia-Pacific Consumer Products LP

The permittee is authorized to operate in conformity with the specifications submitted in the application for an operating permit on March 5, 1999, and the additional information submitted on September 23 and November 9, 1999; December 1, 2000; February 16, November 2, and November 11, 2001; May 16, June 3, and July 11, 2002; November 6, 2003; May 27, September 1, and September 23, 2004, and the application fo r an operating permit modification on May 7,
2009. The Evaluation Memorandum dated Oct ober 12, 2009, explains the derivation of applicable permit requirements and the estimate s of emissions, however, it does not contain operating limitations or permit requirements. Co ntinuing operations under this permit constitutes acceptance of, and consent to, th e conditions contained herein.

1. Points of emission and emissions limitations. [Permit No. PSD-OK-404], [OAC 252:100-8-6(a)(1)]

Where two emission limits with different bases are given for a si ngle emission point and pollutant, the source shall not exceed either limit at any time.

EUG 1 – Subpart D Boilers

EU ID Manufacturer &
Serial Number Fuels Controls Construct

Date

B-1 Zurn Gas None 1975

B-2 Babcock & Wilcox Coal/Gas Electrostatic Precipitator 1975

B-3 Combustion Engineering Coal/Gas Baghouse Filter 1978

B-4 Riley Coal/Gas Baghouse Filter 1981

All Boilers 40 CFR 60 Subpart D; OAC 252:100-31 & 33 Standards Fuels Opacity PM (lbs/MMBTU) SO 2 (lbs/MMBTU) NO X (lbs/MMBTU)

Coal 20/27 0.10 1.2 0.70

Natural Gas 20/27 0.10 0.2 0.20

Fuel
Mixtures 20/27 0.10 OAC 252:100-31 40 CFR 60, Subpart D

Boilers B-2, B-3, & B-4 40 CFR 63 Subpart DDDDD Standards Opacity PM (lbs/MMBTU) OR TSM (lbs/MMBTU) HCl (lbs/MMBTU) Mercury (lbs/MMBTU)

20/27 0.07 0.001 0.09 0.000009SPECIFIC CONDITIONS 99-113-TV (M-9) 2

A. Boilers B-1

, B-2

, B-3

, B-4

. [OAC 252: 100-4], [40 CFR, 60, Subpart D] The facility is subject to Subpart D, Standards of Perf ormance for Fossil-Fuel-Fired
Steam Generators for Which Constructi on is Commenced After August 17, 1971. The permittee shall comply with all applicable requirements including standards, emission and fuel monitoring, test methods and proce dures. Compliance with the emission limits specified in this permit shall be demonstrat ed by the initial testing requirements of 40 CFR Part 60 Subpart D, upon the first firing of each fuel. These requirements have been met for firing natural gas in Boiler B-1 and for firing coal in Boilers B-2, B-3, and

B-4.

B. Boilers B-1

, B-2

, B-3

, B-4

. [40 CFR, 63, Subpart DDDDD] The facility shall comply with any appli cable requirements including, but not limited to, standards, operating limits, work practice standards, emi ssion and fuel monitoring, test methods and procedures, and recordkeeping and reporting.

C. Additional limitations for Boiler B-4

. [Permit No. PSD-OK-404] i. Upon the first firing of natural gas, co mpliance with the emi ssion limits of this condition shall be demonstrated by test me thods and procedures as set forth in 40 CFR Part 60 Appendix A; Method 7, Dete rmination of nitrogen oxide emissions from stationary sources; Method 10, Dete rmination of carbon monoxide emissions from stationary sources; and Method 9, Vi sual determination of the opacity of emissions from stationary sources. Initial testing requirements have been met for firing coal.

Permit No. PSD-OK-404

EU Fuels NO X CO SO 2 PM VOC Opacity

B-4 Coal (lb/hr) 389.98 32.37 668.53 55.71 9.71 10% Coal (lb/MMBtu) 0.7 0.06 1.2 0.10 0.017 Gas (lb/hr) 111.4 46.8* 0.4 2.8 3.3* No Visible
Emissions Gas (lb/MMBtu) 0.2 0.084* 0.001 0.005 0.006* * Updated - Original factor was AP-42, 1981 or earlier; new factor is AP-42, 07/98.

ii. Ongoing compliance with the limits specified in the above table shall be demonstrated by compliance with Spec ific Condition Nos. 3. F., G., J., and K.SPECIFIC CONDITIONS 99-113-TV (M-9) 3

EUG 2 – Combustion Sources No t Subject to NSPS or NESHAP

EU ID Manufacturer & Serial Number Fuels Construct

Date Burner Replace

PM-11 Kinedizer 27M Gas/Propan

e 1975 1999

PM-12 Oven-Pak EB6 Model 400 Gas/Propan

e 1975 2003

PM-13 Oven-Pak EB6 Model 400 Gas/Propan

e 1979 2002

PM-14 Combustifume Gas 1981 NA

PM-15 LV-85 Gas 1992 NA

PO-1 Oven-Pak EB3 Gas 1984 NA PO-1 Catalytic Incinerator Gas 1984 NA

DG-1 1,200 KW generator - Marathon Electric, Magna One, Model# 683 FDR8126GG W, Serial # LM-93152-11/20, w/ Caterpillar engine, Serial# 24Z00501 Diesel 1982 NA

DG-2 1,200 KW generator - Marathon Electric, Magna One, Model# 683 FDR8126GG W, Serial # LM-93152-11/13, w/ Caterpillar engine, Serial# 24Z00499 Diesel 1982 NA

NA – Not applicable

All Paper Machines – OAC 252:100-25 & 31 Standards Fuels Opacity SO 2 (lbs/MMBTU)

Natural Gas 20/60 0.2

D. Additional limitations for Paper Machine PM-15 . [Permit No. 91-127-O (M-1)]

EU ID NO X (TPY) CO (TPY)

PM-15 26.28 18.40

EUG 3 – Coal Preparation Plant

EU Name Manufacturer/Model# Construct Date
Railcar Unloading FEECO 1991, est.

Radial Stacker FEECO 1991, est. FS-1 Coal Pile Open Pile – No Model# 1975 Grizzly Feeder FEECO / Fairfield 1991, est.

Coal Sizer/Crusher Gundlach / Model#56-DA-1294 1977, est. Conveyor Manufactured on-site by Fort Howard 1977, est.

B-2 Coal Bunkers B&W 1975, est. B-2 Coal Feeders Stock Equipment Co ./ Gravimetric Feeder 1975, est.

B-2 Pulverizers B&W / EL50 Ball Mill 1975, est.

B-3 Coal Bunkers CE 1978, est. B-3 Coal Feeders Stock Equipment Co . / Gravimetric Feeder 1978, est.

B-3 Pulverizers CE / Bowl Mill 533ARB 1978, est. B-4 Coal Bunkers Riley 1981, est.

B-4 Coal Feeders Merrick / Coalometer 1981, est. B-4 Pulverizers Riley / 556 Hammer Mill 1981, est.SPECIFIC CONDITIONS 99-113-TV (M-9) 4

40 CFR 60 Subpart Y Grizzly Feeder

Coal Sizer/Crusher Conveying

Coal Bunkers

Coal Feeders

Pulverizers

E. Coal Preparation Plant. [OAC 252:100-4], [40 CFR 60 Subpart Y]
i. The sources listed in the ta ble above identified as “40 CF R 60 Subpart Y” are subject to 40 CFR 60, Subpart Y, Standards of Perf ormance for Coal Preparation Plants. The initial performance testing requiremen ts to demonstrate compliance with the opacity standards were complete d and the standards were met.

F. EUG 4 - PP-1 Pulp Processing Units (Subpart S Affected/No Applicable Standards)
i. Pollutants authorized from this EUG are listed in EUG 6. These units are affected facilities under 40 CFR Part 63, Subpar t S, National Emission Standards for Hazardous Air Pollutants from the Pulp a nd Paper Industry. No standards in the subpart currently apply to the facility. ii. The permittee shall not conduct kraft, soda, sulfite, or semi-chemical pulping processes using wood. iii. The facility shall no t use chlorine or chlori ne dioxide to bleach pu lp. The use of these bleaching agents shall make th e facility subject to the st andards of 40 CFR Part 63, Subpart S and require submittal of an application for a pe rmit modification. iv. The facility is subject to the emissions limitations and standards specified in EUG 6 of this permit.

EUG 5 – 40 CFR 63 Subpart KK, Flexographic Printing

EU

ID EU Name Manufacturer/Model No. Construct

Date PO-1 Flexographic Polyethylene Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer 1984

FP-1 Flexographic Paper
Printer Flexo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper
Printer Flexo #7 – PCMC/Model No. 6725 1997

FP-8 Flexographic Printer Bretti ng, 4-color, 78-inch wide 2005SPECIFIC CONDITIONS 99-113-TV (M-9) 5

G. All presses, Subpart KK Flexographic Printing . [40 CFR 63 Subpart KK] i. EUG 5 is subject to Subpart KK - Nati onal Emission Standards for the Printing and Publishing Industry. The permittee shall comp ly with all applicable requirements. ii. The application of organic HAP on produc t and packaging rotogravure or wide-web flexographic printing presses is limited to no more than 400 kg per month, for every
month. iii. EUG 5 is subject to only the recordkeeping requirements of §63.829(e) and reporting requirements of §63.830(b)(1) of this subpart. The owner or operator is required to
maintain records of the total volume and organic HAP content of each material applied on product and packaging rotograv ure or wide-web flexographic printing presses during each month, to maintain these records for five years, and upon request, submit them to the Administrator.

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

EU ID EU Name Manufacturer/Model# Construct

Date PP-1 Pulp Processing Units All components listed below under PP-1 Pulp Processing Units 1975-1992

PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning PM-11, PM-12, PM-13, PM-14,
PM-15 NA 1975

PO-1 Corona Treater Enercon, Model ASO12V-160 June, 1984

Corona Treater Enercon, Model ASO41V-300 w/Decomposer Model 03X-16 June, 1984

Flexo-plate making Anderson-Vreeland June, 1984 Flexographic Polyethylene
Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer June, 1984

FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724
Flexo 31-001 – Fort Howard
Flexo 31-002 – Fort Howard
Flexo 31-003 – Fort Howard
Flexo 31-005 – PCMC/Model No. 6992
Flexo 31-008 – PCMC/Model No. 7416 1983
1980
1980
1980
1990
1993 FP-7 Flexographic Paper Printer Fl exo #7 – PCMC/Model No. 6725 1997 FP-8 Flexographic Printer Bretting, 4-color, 78-inch wide 2005SPECIFIC CONDITIONS 99-113-TV (M-9) 6

PP-1 Pulp Processing Units

EU Name Construct Date

Stock Blend Tanks 1975 & 1983, est.

Flotation Cell Washers 1975, 1979, 1981, 1983, & 1992, est.

Bleached Washers 1975, est., 1975, 1981, 1983, 1992, est.

Bleach Towers 1975, 1979, 1981, 1983, 1992, est.

Thickeners 1975, 1979, 1981, 1983, est., & 1992, est.

Stock Presses 1992, est.

Permit No. 99-113-TV FP-1/Flexographic Paper Pr inter (six printers) FP-7/Flexographic Paper Printer FP-8/Flexographic Paper Printer 92.28 TPY

H. Additional limitations for Paper Machine Additives and SC-1 Solvent Cleaning

. [Permit No. 91-127-O (M-1)]

Permit No. 99-113-TV & 91-127-O (M-1)

Emission Unit Emission Factor (lbs/lb VOC content) VOC Emissions (TPY) Paper Machine Additives 60% 90.0 SC-1: Solvent Cleaning PM-11, PM-12, PM-13, PM-14, PM-15 60% 338.0

I. Additional limitations for PO-1 Flexographic Printer . [Permit No. 83-062-O (PSD)]

Non-HAP VOCs

Emissions Unit Emissions (TPY) PO-1 Flexographic Printer 99.0 * * Controlled and uncontrolled combined, including PO-1 Platemaking emissions.

J. PP-1 Paper Pulping.

i. Total combined VOC emissions from th e pulp processing systems shall not exceed

127 TPY. ii. Compliance with the VOC limits for emissions from the pulping systems shall be based on the total combined finished pulp stock, 12-month rolling cumulative, using the permittee’s fiscal month accounting basis, and the em ission factor of 0.45 lbs/ton finished pulp stock.SPECIFIC CONDITIONS 99-113-TV (M-9) 7

K. Paper Machine Additives and Solvent Cleaning of PM-11

, PM-12

, PM-13

, PM-14,
and PM-15

.

i. Emissions from Paper Machine Additives are emissions from VOC-containing paper
enhancement chemicals. Emissions of VOCs from the use of pa per machine additives shall not exceed 90.0 TPY, 12-month rolling cumulative, based on the permittee’s fiscal month accounting basis.
ii. Emissions of VOCs fromsolvent cleaning of Paper Machines PM-11, PM-12, PM13, PM-14, and PM-15 shall not exceed 338.0 TPY, 12-month rolling cumulative, based on the permittee’s fis cal month accounting basis.
iii. Emissions shall be calculated based on the total VOC content of each additive or
cleaner material used and a 60% release factor.

L. Printers PO-1

, FP-1

, FP-7, and FP-8 . Total emissions of VOCs from each of the printer systems is limited to the amounts spec ified in the above ta ble as allowed by Permit No. 83-062-O (PSD) for PO-1 and s upplemented by this permit for FP-1, FP-7,
and FP-8.
i. Emission calculations shall be based on mass balance, assumi ng 100% evaporation
of the maximum VOC content of the inks a nd cleaning solvents. Emissions from the PO-1 Flexographic Printer sh all be prorated into uncont rolled and controlled using factors of 30% and 70%, respec tively, with an additional efficiency factor applied to
controlled emissions to account for therma l destruction through the PO-1 Catalytic
Oxidation Incinerator. ii. The Enercon Model ASO41V-300 shall be operated only with a properly functioning decomposer.

M. Additional limitations for the PO-1 Flexographic Printing Press and Platemaking. [Permit No. 83-062-O (PSD)] i. The permittee is authorized to use bo th corona treaters at the same time.
ii. Total VOC emissions from ink and solv ent usage (combined with the PO-1 Flexoplatemaking from EUG 6) shall not exceed 99 TPY based on the previous 12 months usage of ink and solvent, using the pe rmittee’s fiscal month accounting basis.

EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP

EU ID EU Name Manufacturer/ Serial # Construct Date

PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992SPECIFIC CONDITIONS 99-113-TV (M-9) 8

Permit No. 99-113-TV & OAC 252:100-25

EU ID Control Efficiency PM Emissions (TPY)

PM-11 None 9.31

PM-12 None 13.03

PM-13 None 11.17

PM-14 None 11.17

PM-15 None 10.29

N. Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15. i. Total combined annual throughput of dry finished paper shall not exceed the amount in tons per year submitted in the permit application, based on a 12-month rolling cumulative basis, using the permittee’s fiscal month accounting basis.

2. Initial Testing requirements. [OAC 252:100-8-6(a)(1)], [OAC 252:100-43]

A. Boilers B-1, B-2, B-3, and B-4. [40 CFR 60 Subpart D] i. The boilers are subject to §60.46, test me thods and procedures, when firing a fuel not previously tested for initial co mpliance and evaluati on of monitoring. ii. In conducting the performance tests required in §60.8, the owner or operator shall use as reference methods and procedures th e test methods in appendix A of this part or other methods and procedures as specified in this section, except as provided in §60.8(b). Acceptable alternativ e methods and procedures are given in paragraph (d) of §60.46. B. Additional requirements for Boiler B-4. [40 CFR 60 Subpart D], [Permit No. PSD-OK-404] i. Upon the first firing of gas, complia nce with the emission limitations shall be determined by the permittee using test me thods and procedures as set out in 40 CFR Part 60 Appendix A, and Subpart D. ii. During the initial performance test, sulf ur dioxide, particulate matter, and volatile organic compound testing will not be required by the permitting authority while firing natural gas. iii. Permittee shall be exempt from initial performance testing while firing gas until such time that the emission points actually begin firing this fuel. Boiler B-4 has only fired gas through the igniters. Testi ng for gas firing will not be required until the load burners are operated. iv. The permittee shall conduct the required performance testing, within 60 days from
the time Boiler B-4 has been fired with gas for a total period of 96 cumulative hours, in conformance with the Specific a nd General Conditions of this permit. The permittee shall be allowed an add itional mechanical checkout period not exceeding 16 hours in length. v. Should any combustion equipment modificatio ns be made such as different type burners, combustion air relocation, fuel c onversion, tube removal or addition, etc.,
then emission correlations as describe d in the attachment to Permit No. PSD-OK404 titled “Use Of Flue Gas Oxygen Mete r As BACT For Combustion Controls,” and/or 40 CFR 60 Subpart D, or more recently published and accurate EPA methodology shall be conducted within 60 da ys of attaining full operation afterSPECIFIC CONDITIONS 99-113-TV (M-9) 9

such modification. The permittee shall be exempt from this requirement and the requirement to install a continuous reco rding flue gas oxygen monitor if initial nitrogen oxide performance testing demonstrates less than 70% of the applicable nitrogen oxide standard in accordance with 40 CFR Part 60.45 (b)(3) and (4). This exemption was met for firing coal. Results of all emission determinations shall be sent to AQD within 45 days after completion of the test. C. Additional requirements for Boiler B-4. [General Conditions, Permit No. PSD-OK-404] i. The permittee shall notify the permitting authority in writing of the actual firing of the permitted fuel within 30 days of such action and the estimated date of demonstration of compliance as require d in the specific conditions. This requirement has been met for firing coal. ii. Each emission point for which an emission test met hod is established in this permit shall be tested in order to de termine compliance with the emission
limitations contained herein within sixt y (60) days of achieving the maximum production rate, but in no event later than 180 days after initial firing of the permitted fuel. The permittee shall provide (1) sampling ports adequate for test methods applicable to such facility, (2) safe sampling platforms, (3) safe access to sampling platforms, and (4) utilities for sampling and testing equipment.

3. Monitoring Requirements. [OAC 252:100-43] , [OAC 252:100-4], [40 CFR 60 Subpart D], [Permit Nos. 75-053-C&O, 77-076-C& O, 79-021-C&O, 81-066-C&O, 81-081-C&O, 83-062-O (PSD), PSD-OK-404, and 91-127-O (M-1)]

Fuel Standards. Fuel standards to ensure co ntinued compliance with the applicable permit limit are taken from the applicable permit and/or the permit application as submitted by the applicant to meet compliance with applicable air quality standards at the time of permit
issuance. A. All equipment. i. When fired on natural gas, equipment shall be fired with only commercial natural

gas. B. Boiler B-1

. i. Boiler B-1 shall be fire d with only natural gas. C. Paper Machines PM-11

, PM-12

, PM-13 , and PM-15

. i. Paper Machine PM-15 shall burn only commercial-grade natural gas. ii. The use of propane as backup fuel is authorized for Paper Machines PM-11, PM12, and PM-13.

D. PO-1 Catalytic Oxidation Incinerator and Fl exographic Printing Pr ess Tunnel Dryer. [Permit No. 83-062-O (PSD)] i. The tunnel dryer and catalytic oxidation incinerator shall be fueled with only commercial pipeline-grade natural gas. ii. The catalytic oxidation incinerator inle t gas temperature shall be continuously monitored by a shutdown switch that will s hut down the press should the temperature drop below 550 ° F. To document its proper operation, the permittee shall record theSPECIFIC CONDITIONS 99-113-TV (M-9) 10

before (Thermocouple T/C 1) and afte r (Thermocouple T/C 2) catalytic cell temperature daily. The catalys t shall be evaluated at leas t annually to ensure it is within the manufacturer’s specifications. It shall be replaced as recommended by the annual catalyst evaluation report. E. Emergency Generator units DG-1 and DG-2

. i. Emergency Generator units DG-1 and DG-2 shall be fired on diesel fuel.

Fuel Sampling & Analyses
F. Boilers B-2, B-3, & B-4. i. Coal shall be sampled and analyzed to provide a gross sample representative of the fuel consumed during a boiler operating day. ii. Coal shall be analyzed for percent sulf ur content and gross calorific value using the most recent ASTM methods for sample preparation, sulfur analysis, and gross
calorific value determination. Coal sha ll be analyzed on a dry basis using the most recent ASTM method for moisture analysis. iii. Either the fuel supplier’ s certification or analyses shall be accepted by AQD. Additional testing and/or monitoring to c onfirm the accuracy of any data from the fuel supplier may be required at the discretion of AQD.

G. Additional requirements for Boiler B-4. [EPA Letters dated April 9 and May 7, 1987] [Specific and General Conditions, Permit No. PSD-OK-404] i. Coal fired in Boiler B-4 shall be sampled and analyzed by the permittee for sulfur and ash content. The frequency of sampling and analysis shall be as specified in 40 CFR Part 60.45, Emission and Fuel Monitori ng. These data may be used, at the discretion of the permitting authority, to determine violations of the emission limitations. Records of the test results of each sample shall be made available for inspection by the permitting authority for at least five years.

Continuous Opacity Monitoring.

H. Boilers B-1, B-2, B-3, and B-4 . [Permit No. 77-076-C], [40 CFR 60 Subpart D] [EPA Letters dated April 9 and May 7, 1987], [Specific and General Conditions, Permit No. PSD-OK-404] i. The permittee is required to have in stalled, and to maintain and operate a continuous opacity monitoring system as required by §60.45, for Boilers B-2, B-3, and B-4, for the firing of coal. Boiler B-1 fires only natural gas and was not required to install opacity monitoring.ii. Monitoring requirements for Boilers B-2, B-3, and B-4, will have to be reevaluated for monitoring requirements in accordance with of §60.45, when using the alternate fuels authorized by Specific Condition No. 1. iii. Opacity monitoring shall comply with th e specifications of 40 CFR, Part 60. The continuous monitoring data may, at the di scretion of the permitting authority, be
used to determine violations of the conditions of this permit. iv. The opacity limits of Specific C ondition No. 1 shall apply at all times. v. The emission of any pollutant more fre quently or at a level in excess of that authorized by this permit shall constitute a violation of the terms and conditions of this permit.SPECIFIC CONDITIONS 99-113-TV (M-9) 11

I. Coal Preparation Plant & FS-1 Coal Pile. [OAC 252:100-25-3, 29, & 43],

The permittee shall utilize all wet suppressi on equipment, e.g., “spray-bars”, on the conveyors preceding the coal-pile whenever nece ssary to meet the opacity standards of OAC 252:100-25 while coal is being unloaded a nd/or transferred to the coal-pile. A visual inspection of the wet suppression equi pment shall be completed within one hour of starting unloading, and within one hour of resuming unloading after such activity has been suspended for reasons other than changi ng of railcars. Quarterly, the permittee shall conduct, during the daylight hours, one of the following testing alternatives for each specified emission point associated with unloading, e.g., drop-point from the train, associated conveyors, and coal-pile radial stacker. i. The permittee shall conduct an EPA Method 22 visual observation of emissions from the railcar unloading and the radial stacker . In no case shall the observation period
for the Method 22 be less than two minutes in duration. (1) When two consecutive quarterly Me thod 22 observations show no visible emissions, the frequency may be reduced to semi-annual visual observations. Likewise, when two semi-annual visual observations show no visible emissions, the frequency may be reduced to annual visual observations. Upon any determination of visual emissions, the observation frequency shall revert to quarterly. (2) If visible emissions are observed in dur ation of greater than one minute for any observation point using the EPA Method 22, then the permittee shall take
immediate corrective actions to reduce the opacity. Following implementation of corrective actions, a Method 22 shall be conducted at the affected emission point(s) to document whethe r the corrective actions were successful. If visible
emissions are observed in duration of greater than one minute following implementation of corrective actions, th en the permittee shall conduct, before nightfall, two visual observations of emi ssions each hour for the next four hours
in accordance with 40 CFR Pa rt 60, Appendix A, Method 9; except that if the first two Method 9 observations conducted during the first hour do not exceed 20% opacity, the Method 9 testing may be terminated. If any of the Method 9 observations exceeds 60% opacity, the Met hod 9 testing may be terminated and the owner or operator shall comply w ith the provisions of OAC 252:100-9 for excess emissions during start-up, shut down, and malfunction of air pollution control equipment. In no case shall the observation pe riod for the Method 9 be
less than six minutes in duration. ii. The permittee shall conduct an EPA Met hod 9 visual observation of emissions from the railcar unloading and the radial stacker . In no case shall the observation period
for the Method 9 be less than six minutes in duration. (1) Frequencies of EPA Method 9 observations may be reduced in accordance with the frequencies specified in Specific Conditi on No. I.i.(1)., i.e., quarterly to semiannual to annual. (2) If the opacity is greater than 20% for any observation point using the EPA Method 9, then the permittee shall take im mediate corrective actions to reduce the opacity. Following implementation of corrective actions, a Method 9 shall beSPECIFIC CONDITIONS 99-113-TV (M-9) 12

conducted at the affected emission point (s) to document whether the corrective
actions were successful. If the opacity from the Me thod 9 is greater than 20% following implementation of corrective act ions, then the permittee shall conduct an additional Method 9 observation during the same consecutive 60 minute period, and before nightfall, two visual observations of emissions each hour for
the next two hours in accordance with 40 CFR Part 60, Appendix A, Method 9; except that if any of the additional Me thod 9 observations exceeds 60% opacity, the Method 9 testing may be terminated and the owner or operator shall comply with the provisions of OAC 252:100-9 for excess emissions during start-up, shutdown, and malfunction of air pollution control equipment. In no case shall the observation period for the Method 9 be less than six minutes in duration.

Good Combustion Practices [OAC 252:100-43]

J. Boilers B-1, B-2, B-3, and B-4

. i. The permittee shall continuously monitor the oxygen concentration from the boilers. ii. The oxygen monitor shall be maintained and calibrated in accordance with the manufacturer specifications. When manufacturer’s specific ations are not available, a published industry standard shall suffice. iii. A minimum and maximum oxygen concentr ation action level(s) (e.g., load-based concentrations) representing “good combustion practice” sh all be established using the most appropriate of the following: (1) the most recent performance test data; (2) manufacturer’s recommendations; (3) engineering calculations; (4) operator knowledge; and/or (5) historical data. iv. The permittee shall record any variance outside the established oxygen concentration action level(s) and take immediate corrective action to return the boilers to the proper good combustion range. v. The oxygen concentration act ion level(s), a boiler opera tional plan (including a corrective action plan to ensure good co mbustion practices), as well as supporting information documenting good combustion sh all be maintained on-site in an operation and maintenance (O&M) manual fo r the boiler. Supporting information necessary to document good combustion includes calibration and maintenance records, strip-chart or other data r ecordings, performance tests or portable combustion analysis results for NO X , CO, and/or VOCs, the amount of time the oxygen concentration varies outside the oxygen concentration action level(s), and any corrective action taken. Supporting information shall be kept for a period of five

years. Equipment Standards. [OAC 252:100-43] K. Baghouses - Boilers B-3 and B-4. The permittee shall develop and implement an operation and maintenance (O&M) manual for the baghouses. At a minimum the plan shall contain the following provisions.SPECIFIC CONDITIONS 99-113-TV (M-9) 13

i. Method for determining and documenting the time the baghouses are operational (e.g., when there is flow through the baghouses) and when the baghouses are bypassed. ii. Method for determining and documenting good operation that specifically addresses bag leaks. A maximum opacity actio n level representi ng “good operating conditions” shall be established using th e most appropriate of the following: (1) the most recent performance test data; (2) manufacturer’s recommendations; (3) engineering calculations; (4) operator knowledge; and/or (5) historical data The permittee shall record any exceedance out side the established opacity action level
and take immediate correctiv e action to return the aff ected baghouse to good operating
conditions. iii. Method for determining and documenting good operation that specifically addresses improper bag dust accumulation. iv. Description of scheduled baghouse maintenance activities. v. Description of baghouse r ecordkeeping activities.

L. Electrostatic Precipitator (ESP) – Boiler B-2 [OAC 252:100-43] i. A maximum opacity action level shall be established using the most appropriate of the following:

(1) the most recent performance test data; (2) manufacturer’s recommendations; (3) engineering calculations; (4) operator knowledge; and/or (5) historical data. Permittee shall continuously monitor fiel d operational status and opacity for increasing trends in opacity caused by pot ential malfunctions of the ESP. In the event of a maximum opacity action level ex ceedance, the permittee shall verify that the electrostatic precipitator is properly functioning. The permittee shall record any exceedance outside the established opac ity action level and take immediate
corrective action to re turn the electrostatic precipita tor to good operating conditions. ii. The permittee shall develop and implem ent an operation and maintenance (O&M) manual for the electrostatic precipitator for determining and documenting good operation. At a minimum the plan sha ll contain the following provisions. (1) The maximum opacity action level(s) for opacity. (2) Improper dust accumulation. (3) A description of scheduled electrosta tic precipitator maintenance activities. (4) A description of electrostatic pr ecipitator recordkeeping activities. 4. Hours of Operation. [OAC 252:100-8-6(a)(1)] i. The facility is authorized to opera te 24-hours per day, every day of the year. ii. Emergency Generator units DG-1 and DG-2 are limited to 1,440 h ours total combined operating hours, 12-month rolling cumulative, based on the permittee’s fiscal month accounting basis. (1) The generators shall be equipped with meters to measure hours of operation.SPECIFIC CONDITIONS 99-113-TV (M-9) 14

(2) An operating log shall be maintained to assure compliance with the limit on operating
hours.

5. Emission Controls. [OAC 252:100- 8-6(a)(1)], [OAC 252:100-37] A. All boilers, B-1, B-2, B-3, and B-4. The air pollution control devices may be modi fied or replaced, upon prior approval of the Air Quality Division, provided that it can be demonstrated that the replacement equipment is at least as efficient in cont rolling emissions as the previous pollution
control device.

B. Boilers B-2

, B-3 , and B-4

. [Permit Nos. 75-053-C&O, 77-076- C&O, 81-066-C&O, & PSD-OK-404] i. Emissions from Boiler B-2 shall pass thr ough an Electrostatic Precipitator or a control device having equal or lesser emissions prior to discharge to the atmosphere. ii. Emissions from Boiler B-3 shall pass through a baghouse or a control device having equal or lesser emissions prior to discharge to the atmosphere.
iii. BACT for Boiler B-4. (1) BACT for NO X emissions shall consist of the use of low NO X burners to limit
emissions to 0.7 lbs/MMBtu. (2) BACT for PM emissions shall consist of a fabric filter coll ection system to limit
emissions to 0.1 lbs/MMBtu. (3) BACT for SO 2 shall consist of the use of low sulfur content coal when fired by
coal to limit emissions to 1.2 lbs/MMBtu. (4) BACT for CO and VOCs shall consis t of boiler design, efficient equipment operation, and the use of combustion cont rols shall be utilized to ensure
minimization of CO and VOCs and to en sure that emissions do not exceed the
limits.
C. Paper Machine PM-14

. [Permit Nos. PSD-OK-404 & 81-066-C&O] BACT for Paper Machine PM-14 shal l consist of the use of low NO X burners and natural gas for the primary fuel. All ot her pollutants shall be minimized by proper operation of the unit.

6. Reporting Requirements. [OAC 252: 100-8-6(a)(3)(B)], [OAC 252:100-43] In addition to any applicable reporting requirements contained in Subparts D and Y of Part 60, Subpart M of Part 61, Subpart KK of Part 63, and OAC 252:100, the permittee is subject to the following reporting requireme nts incorporated from existing permits.

A. Boiler B-4. [General Conditions, Permit No. PSD-OK-404] i. The permittee shall notify the permitti ng authority in writing upon firing of the permitted alternate fuel within 30 days of such action and include the estimated date of demonstration of compliance as required in the specific conditions. ii. The permittee shall notify the permitting authority of the scheduled date of compliance testing at least thirty (30) days in advance of such test. Compliance test results shall be submitted to the permitting authority within forty-five (45) days after the complete testing.SPECIFIC CONDITIONS 99-113-TV (M-9) 15

iii. If, for any reason, the permittee does not comply with or will not be able to comply with the emission limitations specified in this permit, the permittee shall provide the permitting authority with the following information in writing within ten (10) days of such conditions: (1) description of noncomplying emission(s); (2) cause of noncompliance; (3) anticipated time the noncompliance is e xpected to continue or, if corrected, the duration of the period of noncompliance; (4) steps taken by the permittee to reduce and eliminate the noncomplying emission; and (5) steps taken by the permittee to pr event recurrence of the noncomplying
emission. Failure to provide the above informati on when appropriate shall constitute a
violation of the terms and c onditions of this permit. Submittal of this report does not constitute a waiver of the emission limitations contained within this permit. iv. Any change in the information submitte d in the application regarding facility emissions or changes in the quantity or qua lity of materials processed that will result in new or increased emissions must be reported to the permitting authority. If appropriate, modifications to the permit may then be made by the permitting authority to reflect any n ecessary changes in the perm it conditions. In no case are any new or increased emissions allowed that will cause violation of the emission limitations specified herein. v. In the event of any change in control or ownership of the source described in this permit, the permittee shall notify the succeed ing owner of the existence of this permit by letter and forward a copy of such letter to the permitting authority.

7. A log which lists each emission unit (EU) listed in EUG 4, PP-1 Pulp Processing Units, shall be maintained at the facility. It sha ll contain adequate information to identify each unit and cross-reference each one to an appropriate identifier such as a serial number or some other identifier. The installation date(s ) shall be included for every emissions unit. For EUG 3, Coal Preparation Plant, only a site drawing which identifies all EUs is required to be maintained at the facility.

8. Recordkeeping. The perm ittee shall maintain records of operations as listed below. These
records shall be maintained on-site or at a local field office for at least five years after the date of recording and shall be provide d to regulatory personnel upon request. [OAC 252:100-8-6(a)(3)(B)]
All EUGs A. Either a material safety data sheet (M SDS) or a certified pr oduct data sheet, that documents the volatile organic solvent content and the HAP content of each raw material for which VOC emissions are regulat ed by this permit, including printing inks, cleaning solvents, and paper machine additives.

EUGs 1, 2, and 3 B. Records of fuel analyses, pollution cont rol monitoring/inspection/maintenance, and continuous monitoring, and Me thod 9 and or Method 22 opacity monitoring required bySPECIFIC CONDITIONS 99-113-TV (M-9) 16

Specific Condition No. 3 (frequencies for fuel sampling and analyses as required by Specific Condition No. 3).

EUGs 1 and 2 C. Information necessary to identify the e quipment specified in Specific Condition No. 1.

EUGs 6 and 7 D. Throughput (12-month rolling cumulative, based on the permittee’s fiscal month accounting basis): i. Combined finished pulp stock, all pulp processing, Sy stems 1 through 5. ii. Combined dry finished paper, all paper machines, PM-11 through PM-15.

EUGs 5 & 6 E. Records required by 40 CFR 63, Subpart KK. F. Demonstration of compliance for HAP/V OC limitations by the appropriate method specified. G. Usage of VOC -containing raw materials a nd calculations of VOC emissions based on
the authorized emission factors and methodologies (m onthly, and 12-month rolling cumulative, based on the permittee’s fiscal month accounting basis) for each of the following groups of sources: i. FP-1 (six printers), FP-7, and FP-8 combined total. ii. PO-1 Flexographic Printer and Platemaking, combined total. iii. SC-1 solvent cleaning, Paper Machines PM-11 through PM-15.

EUG 1 [Permit No. 81-066-C&O] H. Records and information required by 40 CF R Part 60, Subpart D. This information shall be recorded in a permanent form suitabl e for inspection and shall be retained for at least five years following the date of such measurements, mainte nance, reports and
records. I. Records required by Specific Conditions 3.J., K., and L., including required data recording, supporting informa tion and documentation, and a copy of the Operation and
Maintenance Manual. 9. The following records shall be maintained on-site to verify Insignificant Activities. No recordkeeping is required for those operat ions which qualify as Trivial Activities. [OAC 252:100-8-6 (a)(3)(B)]

A. For fuel storage/dispensing equipment operated solely for faci lity owned vehicles if fuel throughput is not more than 2,175 gallons/day : daily throughput, averaged each time the storage tank is filled. B. For fluid storage tanks with a capacity of 10,000 gallons or less and a true vapor pressure less than 1.0 psia: Records of capacity of the tanks and contents. C. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor pressure less than 1.5 psia: Records of capacity of the tanks and contents. D. For non-commercial water washing operations (less than 2,250 barrels/year) and drum crushing operations of empty ba rrels less than or equal to 55 gallons with less than three percent by volume of residual material: Em issions from products contained in theseSPECIFIC CONDITIONS 99-113-TV (M-9) 17

drums are already accounted for at 100% product usage in other operations, therefore no records will be required. E. For activities that have the potential to emit less than 5 TPY (actual) of any criteria pollutant: The type of activity and the amount of emissions from that activity (annual).

10. The Permit Shield (Standard Conditions, S ection VI) is extende d to the following requirements that have been determined to be inapplicable to this facility. [OAC 252:100-8-6(d)(2)]

A. OAC 252:100-7 Permits for Minor Facilities
B. OAC 252:100-11 Alternative Emissions Reduction
C. OAC 252:100-15 Mobile Sources
D. OAC 252:100-17 Incinerators
E. OAC 252:100-23 Cotton Gins F. OAC 252:100-24 Particulate Emissions From Grain, Feed, or Seed Operations
G. OAC 252:100-35 Carbon Monoxide
H. OAC 252:100-39 Nonattainment Areas
I. 40 CFR Part 72 Acid Rain

11. Permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, an Annual Compliance Certifi cation for each twelve (12) m onth period, no later than 30 days after February 28, 2010 and each 12 month a nniversary date thereafter for the duration of this permit. The certification shall include a monthly summary of any noncompliance with the permit or applicable regulations for the past year. Permittee shall also submit to Air Quality Division of DEQ, a Semi-Annual Monito ring and Deviation Report for each six (6) month period, no later than 30 days after August 31, 2009 and February 28, 2010 and each six (6) month anniversary date thereaf ter for the duration of this permit. The report shall include the results of any required monitoring for each six (6) month monitoring period. [OAC 252:100-8-6(c )(5)(A), (C) & (D)]

12. AQD reserves the right to require stack testing for any emission unit.MAJOR SOURCE AIR QUALITY PERMIT
STANDARD CONDITIONS (July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Okl ahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is th e Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or
ordinances. [Oklahoma Clean Ai r Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditi ons of this permit. Any permit noncompliance
shall constitute a violation of the Oklahoma Cl ean Air Act and shall be grounds for enforcement action, permit termination, revocation and reissuance, or modifi cation, or for denial of a permit renewal application. All terms and cond itions are enforceable by the DEQ, by the Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act (excluding state-only requirements). Th is permit is valid for operations only at the specific location listed. [40 C.F.R. §70.6(b), OAC 252:100-8-1.3 a nd OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. However, nothing in th is paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for noncompliance if the health, safety, or environm ental impacts of haltin g or reducing operations would be more serious than the impacts of continuing operations. [O AC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial danger to public health, safety, or the environm ent shall be reported in accordance with Section XIV (Emergencies). [OAC 252:100- 8-6(a)(3)(C)(i ii)(I) & (II)]

B. Deviations that result in emissions exceedin g those allowed in this permit shall be reported consistent with the requirem ents of OAC 252:100-9, Excess Em ission Reporting Requirements. [OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this sectio n shall be certified as required by Section III (Monitoring, Testing, Re cordkeeping & Reporting), Paragraph F. [OAC 252:100-8-6(a)(3)(C)(iv)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2

SECTION III. MONITORING, TES TING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including monitoring data and necessary support information, shall be retained on-sit e or at a nearby field office for a period of at least five years from th e date of the monitoring sample, measurement, report, or application, and shall be made av ailable for inspection by regulatory personnel upon request. Support information includes all orig inal strip-chart recordings for continuous monitoring instrumentation, and copies of all repo rts required by this perm it. Where appropriate, the permit may specify that records may be maintained in computerized form. [OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8- 6(c)(1), and OAC 252: 100-8-6(c)(2)(B)]

B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techni ques or methods used; (5) the results of such analyses; and (6) the operating conditions existing at th e time of sampling or measurement. [OAC 252:100-8- 6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit or alternative date as specifically identified in a subsequent Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requireme nts since the prev ious report shall be clearly identified in the report. Submission of these periodic reports will satisfy any reporting requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of S ection II (Reporting Of Deviations From Permit Terms) of these standard conditi ons. [OAC 252:100-8-6( a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be re quired under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeep ing, or as required by any pr ovision of the Federal Clean
Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report, Excess Emission Report, and Annual Emission I nventory submitted in accordance with this permit shall be certified by a responsible offici al. This certificatio n shall be signed by a responsible official, and shall contain the follow ing language: “I certif y, based on information and belief formed after reasonable inquiry, the st atements and information in the document are true, accurate, and complete.” [OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC 252:100-9-7(e), and OAC 252:100-5-2.1(f)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 3

G. Any owner or operator subj ect to the provisions of Ne w Source Performance Standards (“NSPS”) under 40 CFR Part 60 or National Emi ssion Standards for Hazardous Air Pollutants (“NESHAPs”) under 40 CFR Parts 61 and 63 shall main tain a file of all measurements and other information required by the applicable general provi sions and subpart(s). These records shall be maintained in a permanent file suitable for insp ection, shall be retained for a period of at least five years as required by Paragraph A of this Section, and sh all include records of the occurrence and duration of any start-up, shutdo wn, or malfunction in the operati on of an affected facility, any malfunction of the air pollution control equipment; and any periods during which a continuous monitoring system or monitoring device is inoperative. [40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annuall y. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or comp liance was achieved. Th e progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods approved by the Division Director. All tests sh all be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the ma nufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. [OAC 252:100-8-6(a)(3)(A )(iv), and OAC 252:100-43]

J. The reporting of total particulate matter em issions as required in Part 7 of OAC 252:100-8 (Permits for Part 70 Sources), OAC 252:100-19 (Control of Emissi on of Particulate Matter), and OAC 252:100-5 (Emission Inventory), shall be conduc ted in accordance with applicable testing or calculation procedures, modified to include b ack-half condensables, for the concentration of particulate matter less than 10 microns in diameter (PM 10 ). NSPS may allow reporting of only particulate matter emissions caught in the f ilter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252: 100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMP LIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit or alternative date as specificall y identified in a subsequent Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become ef fective since the issuance of this permit. [OAC 252:100-8-6(c)(5)(A), and (D)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 4

B. The compliance certification sha ll describe the operating permit term or condition that is the basis of the certification; the current compliance status; whethe r compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reporting period. The compliance certification shall also include such other facts as the permitting authority may require to determine th e compliance status of the source. [OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification sh all contain a certifica tion by a responsible official as to the results of the required monitoring. This certification shall be si gned by a responsible official, and shall contain the following language: “I certify, based on information and belief formed after reasonable inquiry, the statements and in formation in the document are true, accurate, and complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions units or stationary sources that are not in comp liance with all applicable requirements. This
schedule shall include a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance w ith any applicable requirements for which the emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or
administrative order to which the emissions unit or stationary source is subject. Any such schedule of compliance shall be supplemental to , and shall not sanction noncompliance with, the applicable requirements on which it is based, excep t that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the permit term and that are applicable to the fac ility. Compliance with all new requirements shall
be certified in the next annual cer tification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC 252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are li sted in the Standard Conditions and the Specific Conditions of this permit. Thos e requirements that the applicant requested be determined as not applicable are summarized in the Specific Condi tions of this permit. [OAC 252:100-8-6(d)(2)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 5

SECTION VII. ANNUAL EMISSI ONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees
based on emissions inventories. The methods used to calculate emissions for inventory purposes
shall be based on the best availa ble information accepted by AQD. [OAC 252:100-5-2.1, OAC 252:100-5- 2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, th e term of an operating permit sha ll be five years from the date
of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expirati on of its permit unless a timely and complete renewal application has been su bmitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provi ded in OAC 252:100-8-1.4(b) ) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit sha ll apply for a permit to operate (or modified operating permit) within 180 days following the fi rst day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this perm it, or the application of any provision of this permit to any circumstance, is held in valid, the application of such provision to other circumstances, a nd the remainder of this permit, shall not be affected thereby. [OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any proper ty rights of any sort, or any exclusive privilege. [OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in a ny manner affecting the titl e of the premises upon which the equipment is located and does not rel ease the permittee from any liability for damage
to persons or property caused by or resulting from the mainte nance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon r eceipt of a written requ est and within sixty (60) days of the request unless the DEQ specifi es another time period, any information that the DEQ may request to determine whether cause exists for modifying, reopening, revoking,MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 6

reissuing, terminating th e permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. § 2-5-105(18). Confidential information shal l be clearly la beled as such and shall be separable from the main body of the document such as in an attachment. [OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this f acility is required and shall be made in writing within thirty (30) days after such sale or transfer. [Oklahoma Clean Air Ac t, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopene d and reissued, or terminated for cause. Except as provided for minor permit modifications , the filing of a request by the permittee for a permit modification, revocation and reissuance, te rmination, notification of planned changes, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6(a)(7)( C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the following circumstances: [OAC 252:100- 8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Ac t become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the eff ective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements. (3) The DEQ or the EPA determines that inaccura te information was used in establishing the emission standards, limitations, or other condi tions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ. (4) DEQ determines that the permit should be amended under the discretionary reopening provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8- 7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making ch anges other than those described in Section XVIII (Operational Flexibility), those qualifying fo r administrative permit amendments, or those defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The notification should include any changes which may alter the status of a “grandfathered source,” as defined under AQD rules. Such cha nges may require a permit modification. [OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 7

E. Activities that will result in air emissions th at exceed the trivial/insignificant levels and that are not specifically approved by this perm it are prohibited. [O AC 252:100-8-6(c)(6)]

SECTION XIII. IN SPECTION & ENTRY

A. Upon presentation of credentials and othe r documents as may be required by law, the permittee shall allow authorized regulatory offi cials to perform the following (subject to the permittee's right to seek conf idential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)
for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a
source is located or emissions -related activity is conducted, or where records must be kept under the conditions of the permit; (2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including monitoring and air po llution control equipment), practices, or operations regulated or required under the permit; and (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring complian ce with the permit. [OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later than 4:30 p.m. on the next working day afte r the permittee first becomes aware of the exceedance. This notice shall contain a descript ion of the emergency, the probable cause of the exceedance, any steps taken to mitigate emi ssions, and corrective actions taken. [OAC 252:100-8-6 (a)(3 )(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and subs tantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall
notification be more than 24 hours after the exceedance. [OAC 252:100- 8-6(a)(3)(C )(iii)(II)]

C. An "emergency" means any situation arisi ng from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal ope ration, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An em ergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error. [OAC 252:100-8-2] D. The affirmative defense of emergency sh all be demonstrated through properly signed, contemporaneous operating logs or other rele vant evidence that: [O AC 252:100-8-6 (e)(2)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 8

(1) an emergency occurred and the permittee ca n identify the cause or causes of the

emergency; (2) the permitted facility was at the time being properly operated; (3) during the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emissi on standards or other requirements in this permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted unde r this section shall be certified as required by Section III (Mon itoring, Testing, Recordkeeping & Reporting), Paragraph F. [OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Se ction 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date . [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are eith er on the list in Appendix I to OAC Title 252, Chapter 100, or whose actual calendar year emissi ons do not exceed any of the limits below. Any activity to which a State or Federal applicab le requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant. (2) 2 tons per year for any one hazardous air pol lutant (HAP) or 5 tons per year for an aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule. [OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emi ssions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or Federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OP ERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in theMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 9

permit). When an operating scenario is changed, th e permittee shall record in a log at the facility the scenario under which it is operati ng. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted em ission rate of any existing emissions unit to be exceeded;

provided that the f acility provides the EPA and the DEQ with written notification as required below in advance of the proposed changes, whic h shall be a minimum of seven (7) days, or twenty four (24) hours for emergencies as defi ned in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification re quired above shall include a br ief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longe r applicable as a result of the change. The permit shield provided by this permit does not a pply to any change made pursuant to this paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless elsewhere covered by a mo re restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditi ons listed in the Open Burning Subchapter. [OAC 252:100-13] (2) No particulate emissions from any fuel-burni ng equipment with a ra ted heat input of 10
MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an op acity limit promulgated under 40 C.F.R., Part 60, NSPS, no discharge of greater than 20% opacity is allowed except for: [OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three su ch periods in any consecutive 24 hours. In no case shall the average of any si x-minute period exceed 60% opacity; (b) Smoke resulting from fires covered by th e exceptions outlined in OAC 252:100-13-7; (c) An emission, where the presence of uncombi ned water is the only reason for failure to meet the requirements of OAC 252:100-25-3(a); or (d) Smoke generated due to a malfunction in a facility, when the source of the fuel producing the smoke is not under the direct a nd immediate control of the facility and
the immediate constriction of the fuel flow at the fac ility would produce a hazard to life and/or property.MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 10

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standa rds to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fi red fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed th e listed ambient air standards for sulfur dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storag e tanks built after December 28, 1974, and with a capacity of 400 gallons or more stori ng a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be e quipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the followi ng standards for production and consumption of ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an or der for production or im portation of certain class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the requirements of §82.4; (2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping requirements at §82.13; and (3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon tetrachloride, tr ichloroethane (methyl chloroform), and bromomethane (Methyl Bromide). Class II substances (lis ted at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance re frigerant (or regulated substitute s ubstance) in the motor vehicle air conditioner (MVAC), the permittee is subject to a ll applicable requirements. Note: The term
“motor vehicle” as used in S ubpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC ” as used in Subpart B does not include the air-tight sealed refrigeration system used as re frigerated cargo, or the system used on passenger buses using HCFC-22 refrigeran t. [40 CFR 82, Subpart B] C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, se rvice, repair, or disposal must comply with the required pract ices pursuant to § 82.156; (2) Equipment used during the mainte nance, service, repair, or di sposal of appliances mustMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 11

comply with the standards for recycling and recovery equipment pursuant to § 82.158; (3) Persons performing maintenance, service, repa ir, or disposal of appliances must be certified by an approved technician cert ification program pursuant to § 82.161; (4) Persons disposing of small appliances, MVAC s, and MVAC-like appliances must comply with record-keeping requirements pursuant to § 82.166; (5) Persons owning commercial or industrial pro cess refrigeration equipment must comply with leak repair requireme nts pursuant to § 82.158; and (6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work asso ciated with permit revi ew and, wherever it is not inconsistent with Federal requirements, to provide for incorporation of requirements established through construction permitting into the Source’s Title V permit without causing redundant review. Requirements from construction permits may be incorporated into the Title V permit through the administrative amendment pro cess set forth in OAC 252:100-8-7.2(a) only if the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to the public that this permit is subject to EPA review, EPA objection, and petition to EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit. (2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected Stat e, as provided by 40 C.F.R. § 70.8(b). (4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as provided by 40 C.F.R.§ 70.8(a) and (c). (5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 C.F.R. § 70.8(d). (7) A copy of the final construction permit is sent to EPA as provide d by 40 CFR § 70.8(a). (8) The DEQ shall not issue the proposed construction permit until any affected State and EPA have had an opportunity to review the proposed permit, as provided by these permit conditions. (9) Any requirements of the construction permit may be reopened for cause after incorporation into the Title V permit by th e administrative amendment process, byMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 12

DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40 C.F.R. § 70.7(f) and (g). (10) The DEQ shall not issue the administrativ e permit amendment if performance tests fail to demonstrate that the source is operati ng in substantial compliance with all permit requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifica tions or establishing wh ether or not a person
has violated or is in violat ion of any provision of the Okla homa implementation plan, nothing shall preclude the use, including the exclusive us e, of any credible evidence or information,
relevant to whether a source woul d have been in compliance with applicable requirements if the appropriate performance or compliance te st or procedure had been performed. [OAC 252:100-43-6]Rodney Bond, Operating Vice-President Georgia-Pacific Consumer Products LP, Muskogee
4901 Chandler Road Muskogee, OK 74403-4909

RE: Operating Permit No. 99-113-TV (M-9) Georgia-Pacific Consumer Pr oducts LP – Muskogee Mill

Dear Mr. Bond:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit is issued subject to standard and sp ecific conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections.

Also note that you are required to annually submit an emission inventory for this facility. An emission inventory must be completed on a pproved AQD forms and submitted (hardcopy or electronically) every year by April 1 st . Any questions concerning the form or submittal process
should be referred to the Emi ssion Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact me at (918) 293-1617 or by mail at DEQ Regional Office at Tulsa, 3105 East Skelly Drive, Suite 200, Tulsa, Oklahoma, 74105.

Sincerely,

David Pollard, P.E., Prof essional Engineer III AIR QUALITY DIVISION