DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM August 23, 2010

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-5)

Georgia-Pacific 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 45th Street, 

South to Harold Abitz Drive, East into facility.

SECTION I. INTRODUCTION

Georgia-Pacific Consumer Products LP (applicant) 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 II, significant modification to the operating permit. The applicant owns and 

operates the Georgia-Pacific Consumer Products LP, Muskogee Mill, an existing major 

manufacturer and converter of sanitary paper 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 reduction in 

emissions resulting from this permit modification to impose an enforceable emissions limit does 

not change the facility’s status of a PSD (Prevention of Significant Deterioration) major source 

facility after permit modification.

Scope of Modification

The purpose of this modification is to address the applicability of Part 51, Appendix Y, 

“Guidelines for BART Determinations Under the Regional Haze Rule”. “BART” is the EPA

(US Environmental Protection Agency) acronym for Best Available Retrofit Technology 

[controls]. In brief, the facility has two boilers that are considered “BART – eligible” sources

[affected sources], having the potential to contribute to “visibility impairment” in a Class I area. 

The applicant requests that an enforceable emission limit be imposed on one of the boilers to 

maintain emissions below the “contribution threshold” that, if exceeded, would be considered to 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 2

“cause visibility impairment”. The applicant has proposed EPA’s recommended minimum 

contribution threshold of 0.5 deciviews. In support of this, the applicant submitted a technical 

report with dispersion modeling to demonstrate that the boilers do not need to be subject to 

BART controls. Finally, Subpart Y requires that DEQ establish the enforceable emission limit 

for each subject emission unit and for each pollutant subject to review and require compliance 

with the BART emission limitations no later than 5 years after EPA approves DEQ’s regional 

haze SIP. Additional details of the applicant’s technical report and BART evaluation are 

included as a new subsection of “Section V., PSD Review”.

Ongoing Modifications

The facility began construction in 1975 and has been in operation since 1978. The Title V permit 

incorporated all effective permit conditions. The facility is currently operating under the original 

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 efficiency, to allow for papermaking with lower 

grades of wastepaper, and to reduce dependence on outside vendors of packaging material. The 

three areas affected are the paper machine and converting area, the polyethylene plant, and the 

System 5 Pulp area. Increased emissions from this project are expected to trigger Prevention of 

Significant Deterioration (PSD) significance levels, requiring full PSD analysis, including Tier II 

permitting, modeling, and BACT analysis. Permit No. 99-113-C (M-4) (PSD) was then issued 

for clarification of several conditions of Permit No. 99-113-C (M-3) (PSD). These clarifications 

did not relax any permit conditions, did not authorize 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 manufacturer 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 during the converting process. The main processes 

involved in papermaking are pulping, de-inking (bleaching out the inks in the recycled paper), paper 

production, and printing. The company’s basic raw material for wet papermaking is currently 

recycled wastepaper and a small amount of purchased pulp, which is processed into pulp using a 

proprietary process. The facility typically recycles over a thousand tons 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 materials or the use of different additives and also the 

applicability of additional regulations and/or MACT standards, the facility will need to evaluate 

these issues to determine the needs for submitting a permit application.

Pulping and Pulp Processing

The derivation, rationale, and technical justification for the emission calculations are presented in 

the section for emissions. Following is a description of the equipment 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.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 3

Screens - Separate solid contaminants from the pulp slurry.

Washers - Separate solid contaminants from the pulp slurry.

Stock Presses - Used to dewater the pulp slurry and increase consistency.

Mixer - Used to mix the pulp slurry with process water, dilution water, chemicals, etc.

Flotation Cell Washers - Remove solid contaminants from the pulp slurry.

Cleaners - Remove solid particle contaminants.

Bleach Towers - Provide residence time to allow the bleach medium to react with the pulp slurry.

Thickeners - Used to increase pulp slurry consistency.

The pulping and pulp processing systems process and bleach 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 to 

recover usable fiber, blended with 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. Contaminants are removed in this 

step, as well. Additional contaminant removal is accomplished by means of processes performed by 

other equipment described above. Bleaching agents are added to the slurry for the purpose of 

increasing brightness. The facility uses no chlorine or chlorine dioxide to bleach pulp. As noted in 

the permit chronology above, the chlorine dioxide plant was not constructed. Bleached pulp is 

stored in storage tanks for later use on paper machines to make paper. VOCs and organic pollutants 

are released during pulp processing as a result of chemical and mechanical processes.

The Low Consistency Washers aerate the pulp slurry, which results in bubbles on top of the 

material. A rotating vacuum arm removes the bubbles from the top of the 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 atmosphere. Two vented bleaching towers were also tested by NCASI. The 

applicant has indicated that bleaching agents and aids other than those currently used, may be used 

in PP-1 in the future. The facility will need to evaluate 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 rolls 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 vacuum is pulled from below to remove additional water. Residual 

moisture is removed from the produced paper as it is dried in the 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 mentioned earlier, was designated in an application 

submitted on December 1, 2000, as a secondary fuel. PM-11 and PM-12 have after-dryers that use 

steam from the power plant. Combustion emissions and 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 subsequent to the NCASI testing are estimated by the applicant to be 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 4

60% of the VOC content, with 20% retained in wastewater and the other 20% is consumed (i.e., 

used up or reacts with latex contaminants). These values are based on testing done at other facilities. 

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)

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)
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 5

Following is a description of each paper machine.

PM-11 is a 209-inch, wet crepe/dry crepe twin-wire periformer, manufactured by KMW, with a 

suction forming roll, single-felted press section, 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. The stock system is conventional, utilizing a drum save-all for fiber 

recovery and an air flotation clarifier for water recycling.

PM-12 is a 209-inch, wet crepe twin-wire periformer, manufactured by KMW, with a suction 

forming roll, single-felted press section, 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-all for fiber recovery 

and an air flotation clarifier 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 pressure 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. The stock system is conventional, utilizing a 

drum save-all for fiber recovery and an air flotation clarifier for water recycling.

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 

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)
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 6

PM-14 is a 271-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming 

roll, single-felted press section, two pressure rolls, and an 18-foot 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 air flotation clarifier for water 

recycling.

PM-15 is a 273-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming 

roll, single-felted press section, two pressure rolls, and an 18-foot Yankee dryer equipped with two 

25 MMBTUH gas-fired hoods and high temperature hot water. The stock system is conventional, 

utilizing a disc save-all for fiber recovery and an air flotation clarifier for water recycling.

Emissions were measured from Paper Machine Nos. 12 and 14 by NCASI. Emission measurements 

for Paper Machine No. 12 were taken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum 

Systems Vent, the After Dryer Vent No. 1, the Yankee Dryer 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 Dryer, 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 chemical additives and 

items in bold represent emission units that were tested by NCASI.

Process Flow – Paper Machines

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 solvent is pumped from tanks or totes to paper machines PM-11, PM-12, 

PM-13, PM-14, and PM-15 for application on the machine clothing. The purpose of this cleanup is 

to rid the machine clothing of any contaminants, commonly known as stickies, which may be 

deposited from the paper stock going to the machines. These contaminants would adversely affect 

product from the machine by forming 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 flexographic 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 that 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 towel products at the end of the unit.

FP-8 is a 4-color, 78-inch wide, flexographic printing press, manufactured by Bretting. It was 

custom built and has no number. FP-8 is situated in Building No. 31 and was in operation by 

June of 2005.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 7

Polyethylene Extruding and Flexographic Printing (polyethylene film)

The polyethylene extruder, the plate-making room, and the flexographic printing room are all 

housed in the Poly Plant Building.

Flexo-plate making is conducted in the plate-making room. The plates are produced for use with 

all of the mill plant’s flexographic printers. VOC-containing solvents are used in the finishing step 

of plate-making. VOC emissions from a plate washing process are discharged from the building 

through a horizontal vent. A smaller amount of fugitives leave the room through two door openings 

into the Poly Plant building. The Poly Plant building has numerous vents, the most prominent being 

three 5’ x 5’ exhaust vents down the center-line peak of the building roof. These vents have hingedflap rain caps which result in somewhat 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, packaged, and distributed to customers. 

Plastic over-wrap is produced on-site from the polyethylene and extruding plant. Polyethylene 

pellets, stored in silos, are pneumatically conveyed to the extruder. The extruder produces a 

polyethylene tube which is elongated by take-off nip 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 horizontal vent. Once a full roll is produced, 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 flexographic printing room. 

The polyethylene rolls are fed into a six-color, central impression flexographic printing press and 

dried through the tunnel dryer to produce printed parent rolls of polyethylene film. The finished 

rolls are stored and transferred to locations within the facility where the product may be needed. 

Emissions from the plant are solvent and ink VOCs and combustion products 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 temperature is monitored before and after 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 record the before (Thermocouple T/C 1) and after 

(Thermocouple T/C 2) catalytic cell temperature daily.

Steam and Electricity Co-generation (power plant)

The facility has a power plant utilizing four boilers, identified as emission units B-1, B-2, B-3, and 

B-4, which co-generate most of the electrical and steam needs of the facility. They are fueled by 

coal and other fossil fuels. The ash residue generated from this operation is landfilled in an 

approved on-site landfill. Opacity of the boiler emissions is monitored continuously and recorded 

by the use of strip charts. Following is a description of each boiler.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 8

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 electricity for use on-site. It 

uses an electrostatic precipitator for particulate control and shares a common stack with boiler B-1.

B-3 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. 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 for particulate control and shares a common stack with boiler B-4.

B-4 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. 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 for particulate control and shares a common stack with boiler B-3.

Emergency Backup Power Generators

The facility has two emergency backup power generators used only for emergency power in the 

event of a complete power loss. Otherwise they are operated only for periodic capability tests.

DG-1 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/20, with a diesel-fueled Caterpillar engine, Serial # 24Z00499.

DG-2 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/13, with a diesel-fueled Caterpillar engine, Serial # 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/conveying equipment are subject to the provisions 

of 40 CFR, Part 60, Subpart Y, “Standards of Performance for Coal Preparation Plants.” Initial 

performance testing was completed. Subpart Y does not contain monitoring requirements. More 

detail on the applicability criteria is found in the NSPS discussion of Section VIII.

Coal Storage

Coal fuel used in the boilers is stored in an outdoor storage pile (FS-1) prior to processing into 

pulverized coal. Solid, bituminous and sub-bituminous coal is delivered by railcar and unloaded 

into a below-grade receiving bin. Some coal is also occasionally received 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 for 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 9

the sized coal to the coal bunkers ahead of the coal feeders, which in turn feed the pulverizers 

and subsequently the boilers. The 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-wire periformer, manufactured by KMW, with a 

suction forming roll, single-felted press section, 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. The stock system is conventional, utilizing a drum save-all for fiber 

recovery and an air flotation clarifier for water recycling.

PM-12 is a 209-inch, wet crepe twin-wire periformer, manufactured by KMW, with a suction 

forming roll, single-felted press section, 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-all for fiber recovery 

and an air flotation clarifier 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 pressure 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. The stock system is conventional, utilizing a 

drum save-all for fiber recovery and an air flotation clarifier for water recycling.

PM-14 is a 271-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming 

roll, single-felted press section, two pressure rolls, and an 18-foot 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 air flotation clarifier for water 

recycling.

PM-15 is a 273-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming 

roll, single-felted press section, two pressure rolls, and an 18-foot Yankee dryer equipped with two 

25 MMBTUH gas-fired hoods and high temperature hot water. The stock system is conventional, 

utilizing a disc save-all for fiber recovery and an air flotation clarifier for water recycling.

Emissions were measured from Paper Machine Nos. 12 and 14 by NCASI. Emission measurements 

for Paper Machine No. 12 were taken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum 

Systems Vent, the After Dryer Vent No. 1, the Yankee Dryer 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 Dryer, 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 chemical additives and 

items in bold represent emission units that were tested by NCASI.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 10

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)

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 

Dye Neutralizer 

(Grade Specific & 

Dye Neutralizer 

(Grade Specific 

Dye Neutralizer 

(Grade Specific 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 11

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

(Grade Specific 

& part of water 

system)

part of water 

system)

& part of water 

system)

& 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 

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 solvent is pumped from tanks or totes to paper machines PM-11, PM-12, 

PM-13, PM-14, and PM-15 for application on the machine clothing. The purpose of this cleanup is 

to rid the machine clothing of any contaminants, commonly known as stickies, which may be 

deposited from the paper stock going to the machines. These contaminants would adversely affect 

product from the machine by forming 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 flexographic 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 that 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 towel products at the end of the unit.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 12

FP-8 is a 4-color, 78-inch wide, flexographic printing press, manufactured by Bretting. It was 

custom built and has no number. FP-8 is situated 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 room, and the flexographic printing room are all 

housed in the Poly Plant Building.

Flexo-plate making is conducted in the plate-making room. The plates are produced for use with 

all of the mill plant’s flexographic printers. VOC-containing solvents are used in the finishing step 

of plate-making. VOC emissions from a plate washing process are discharged from the building 

through a horizontal vent. A smaller amount of fugitives leave the room through two door openings 

into the Poly Plant building. The Poly Plant building has numerous vents, the most prominent being 

three 5’ x 5’ exhaust vents down the center-line peak of the building roof. These vents have hingedflap rain caps which result in somewhat 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, packaged, and distributed to customers. 

Plastic over-wrap is produced on-site from the polyethylene and extruding plant. Polyethylene 

pellets, stored in silos, are pneumatically conveyed to the extruder. The extruder produces a 

polyethylene tube which is elongated by take-off nip 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 horizontal vent. Once a full roll is produced, 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 flexographic printing room. 

The polyethylene rolls are fed into a six-color, central impression flexographic printing press and 

dried through the tunnel dryer to produce printed parent rolls of polyethylene film. The finished 

rolls are stored and transferred to locations within the facility where the product may be needed. 

Emissions from the plant are solvent and ink VOCs and combustion products 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 temperature is monitored before and after 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 record the before (Thermocouple T/C 1) and after 

(Thermocouple T/C 2) catalytic cell temperature daily.

Steam and Electricity Co-generation (power plant)

The facility has a power plant utilizing four boilers, identified as emission units B-1, B-2, B-3, and 

B-4, which co-generate most of the electrical and steam needs of the facility. They are fueled by 

coal and other fossil fuels. The ash residue generated from this operation is landfilled in an 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 13

approved on-site landfill. Opacity of the boiler emissions is monitored 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 electricity for use on-site. It 

uses an electrostatic precipitator for particulate control and shares a common stack with boiler B-1.

B-3 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. 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 for particulate control and shares a common stack with boiler B-4.

B-4 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. 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 for particulate control and shares a common stack with boiler B-3.

Emergency Backup Power Generators

The facility has two emergency backup power generators used only for emergency power in the 

event of a complete power loss. Otherwise they are operated only for periodic capability tests.

DG-1 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/20, with a diesel-fueled Caterpillar engine, Serial # 24Z00499.

DG-2 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM93152-11/13, with a diesel-fueled Caterpillar engine, Serial # 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/conveying equipment are subject to the provisions 

of 40 CFR, Part 60, Subpart Y, “Standards of Performance for Coal Preparation Plants.” Initial 

performance testing was completed. Subpart Y does not contain monitoring requirements. More 

detail on the applicability criteria is found in the NSPS discussion of Section VIII.

Coal Storage

Coal fuel used in the boilers is stored in an outdoor storage pile (FS-1) prior to processing into 

pulverized coal. Solid, bituminous and sub-bituminous coal is delivered by railcar and unloaded 

into a below-grade receiving bin. Some coal is also occasionally received 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 14

separates debris such as rocks. Except for 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. The 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.

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 laws 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 Generators 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 Not Subject to NSPS or NESHAP

EUG 2 includes emission units that have combustion emissions not subject to an NSPS or a 

NESHAP performance standard.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 15

EUG 2 – Combustion Sources Not 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 1983

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, “Standards of Performance for Coal Preparation 

Plants,” which include coal processing and conveying equipment (including breakers and 

crushers) and coal storage systems in coal preparation plants that process more than 200 tons per 

day, as well as emission units not subject to Subpart 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 Gundlach / Model#56-DA-1294 1977, est.

Conveyor Fort Howard (Manufactured 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 Co. / Gravimetric Feeder 1978, est.

B-3 Pulverizers CE / Bowl Mill 533ARB 1978, est.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 16

EU ID EU Name Manufacturer/Model# Construct 

Date

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 (Subpart S Affected/No Applicable Standards)

EUG 4, PP-1 Pulp Processing Units, emits VOCs from the bleaching and pulping processes. 

Some of these units are affected processes under 40 CFR Part 63, Subpart S, “National Emission 

Standards for Hazardous Air Pollutants from the Pulp 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. The facility uses secondary wood (recycled paper) 

fiber and is therefore an affected facility. However, as a result of the processes and bleaching 

chemicals used in producing the secondary fiber pulp, there are no standards in the subpart that 

currently apply to the facility. Therefore, this EUG is reserved for any future Subpart S 

regulated units. Emissions from these units were subject to OAC 252:100-41 at the time of the 

public draft permit. As detailed in later sections of this memorandum, Part 5 of OAC 252:100-

41, which deals with the toxic air contaminants, has been replaced 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 flexographic printing presses and auxiliary equipment 

subject to 40 CFR Part 63, Subpart KK, “National 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 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 Flexo #7 – PCMC/Model No. 6725 1997

FP-8 Flexographic Polyethylene Printer Bretting, 4-color, 78-inch wide June, 2005
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 17

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 includes units that are part of the paper making process, having VOC or 

HAP emissions and not subject to Subpart S (PP-1 Pulp Processing 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 NESHAP performance standard but emitting VOC 

pollutants not covered by the standard (such as the flexographic printers). A Flexographic 

Polyethylene Extruder, Gloucester Engineering, Model #264-001, 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 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, 1984

PO-1 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 Flexo #7 – PCMC/Model No. 6725 1997

FP-8 Flexographic Polyethylene Printer Bretting, 4-color, 78-inch wide 2005

Note: Although all of the equipment 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 was revised to reflect 

only those units that have emissions, i.e., it does not include closed units.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 18

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 NESHAP

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 turnaround 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 gallons of Paper Machine solvent, and 7,075 tons of bleaching/de-inking 

additives. Because of the length of the emission discussions and illustrative tables for each 

Emission Unit, a facility emission summary table is first offered in this section. For combustion 

emissions, the highest from all fuels considered is shown. Emission calculations for each emission 

unit identified in the application, as re-grouped into the following Emission Unit Groups, are 

detailed in the discussion and tables following this section.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 19

Facility-Wide Emissions Summary

Combustion Emissions

Boilers PM

(TPY)

NOX

(TPY)

SO2

(TPY)

VOC

(TPY)

CO

(TPY)

HCL

(TPY)

H2SO4

(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)

NOX

(TPY)

SO2

(TPY)

VOC

(TPY)

CO

(TPY)

HCL

(TPY)

H2SO4

(TPY)

HF

(TPY)

Railcar 

Unloading

35.23

Radial Stacker

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
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 20

Non-Combustion Emissions

Coal

Handling

PM

(TPY)

NOX

(TPY)

SO2

(TPY)

VOC

(TPY)

CO

(TPY)

HCL

(TPY)

H2SO4

(TPY)

HF

(TPY)

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 Boilers

The applicant submitted the following emission calculations 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 compliance with existing air quality standards at the time 

of issuance of Permit No. PSD-OK-404. Stack tests for Boiler B-2 burning High Btu coal were 

conducted on January 7, 8, and 9, 2003. Stack tests for Boiler B-2 burning Low Btu coal were 

conducted on May 16 and 17, 2003. Stack tests for Boiler B-3 burning 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 and 16, 2003. The results of the most recent tests are contained in 

reports prepared by Western Environmental Services and Testing, 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 

NOX

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 Walls 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)
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 21

COAL NATURAL GAS FUEL OIL

NOX NA NA 0.115 lbs 

(3)

MMBTU

187.38 (1) 0.024 lbs 

(6)

 gal

279.32 (1)

SO2 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

H2SO4 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)

NOX (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)

NOX (Lo Btu 

Coal) (19)

0.319 lbs (3)

 MMBtu

737.73 (1)

SO2 (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)

SO2 (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)

H2SO4 (Hi 

Btu Coal) (19)

0.001 lbs 

(3)

 MMBtu

2.31 (1) NA NA NA NA

H2SO4 (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)
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 22

COAL NATURAL GAS FUEL OIL

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)

NOX

0.224 lbs 

(3)

 MMBtu

655.78 (1) 170 lbs 

(15)

 MMCF

456.22 (2) 0.032 lbs 

(6)

 gal

624.55 (1)

SO2

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

H2SO4

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)

NOX

0.339 lbs 

(3)

 MMBtu

992.45 (1) 190 lbs 

(15)

 MMCF

463.54 0.04 lbs 

(6)

 gal

715.63 (2)

SO2

0.631 lbs 

(3)

 MMBtu 

1,847.31 (1) 0.6 lbs (4)

 MMCF

1.76 (1) 0.10362 lbs 

(6)

 gal

1,685.32

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

H2SO4

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
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 23

EUG 1 - Emissions Summary

PM

(TPY)

NOX

(TPY)

SO2

(TPY)

VOC

(TPY)

CO

(TPY)

HCL

(TPY)

H2SO4

(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 Not 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

e

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 limits, which were established by existing permits.

Emission calculations for firing the paper machines 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, and 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 Incinerator (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), issued for the PO-1 Polyethylene Extruder and 

Printer, “the Tunnel Dryer and TEC Systems Catalytic Oxidation Incinerator, 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 ft3/hr) of commercial natural gas. The unit is 

capable of consuming up to 17.52 MMCF/yr (2,000 ft3/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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 24

Commercial Boilers (0.3 - < 10 X 106 BTU/hr) emission rates in that, at the maximum operating 

rates, this unit is capable of delivering 2.0 X 106 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 efficiency, only 5% of the VOCs produced from 

combustion are not destroyed and therefore emitted.

EUG 2 – Combustion Sources Not 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)

NOX 100 lbs 

(15)

 MMCF

25.23 (1) 0.02 lbs 

(6)

 gal

36.04 (1)

SO2 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)

NOX 100 lbs 

(15)

 MMCF

17.35 (1) 0.02 lbs 

(6)

 gal

24.78 (1)

SO2 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)

NOX 100 lbs 

(15)

 MMCF

17.35 (1) 18.40 (2) 0.02 lbs 

(6)

 gal

24.78 (1)

SO2 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

NOX

100 lbs 

(15)

 MMCF

23.13 (2) 0.02 lbs 

(6)

 gal

36.04 (1)
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 25

NATURAL GAS FUEL OIL

SO2

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

NOX

100 lbs 

(15)

 MMCF

26.28 (1) NA NA

SO2

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

NOX

100 lbs 

(15)

 MMCF

0.88 NA NA

SO2

0.6 lbs 

(4)

 MMCF

0.01 NA NA

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)

NOX

(TPY)

SO2

(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.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 26

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 grizzly 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 includes both batch and continuous drop operations, 

both of which are utilized for this coal preparation plant. It includes dust emissions from several 

distinct source activities within the storage cycle:

1. Loading of aggregate onto storage piles (batch or continuous 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 for return to the process stream (batch or 

continuous drop operations).

Emissions from railcar unloading, the 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. The 

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 PM10

U = wind speed (15 mph, worst case value from Ranges of Source Conditions)

M = moisture content (0.25 %, worst case value from Ranges of Source Conditions)

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

Coal handling factors for crushing and conveying 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 with 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 process 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 throughput 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 heat 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.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 27

EUG 3 –Coal Preparation Plant

EU Name Particulate Matter 

Emission Factors 

(lbs/ton coal)

Throughput 

(TPY)

PM Emissions (TPY)

2003 Actual PTE

Railcar Unloading

Radial Stacker 0.0859 519,362 22.31 35.23

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

Pulverizers No Emissions

Concerning the building housing the coal sizer/crusher, 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 enclosed. Based on this and visual observation, the applicant 

feels it is apparent that Sizer/Crusher emissions would not exceed Unloading/Stacker/Feeder 

emissions. Regardless, an emission calculation for the crusher has been included in the EUG 3 

emissions table above. The applicant further believes that the emission rate in the table above 

for the Sizer/Crusher does not seem practical when compared to the emission rate from the 

Unloading/Stacker/Feeder category directly above it. The applicant found no other factor by 

which to calculate Sizer/Crusher emissions and has requested that AQD consider this 

inconsistency during permit development. The only 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 pile 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. Based on information from a 1984 report by the 

Electric Power Research Institute, CS 3455, the 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 precipitate per year.

f = percentage of time that the unobstructed wind speeds exceeds 5.4 m/s at the mean pile

height.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 28

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 footage of the coal pile is 350,000 ft2.

Converting coal pile square footage to hectares = 350,000 ft2(0.00000929 hectare/ft2) = 

3.2515 hectares

Substituting 8.5/hectare-day (3.2515 hectares) = 27.63775 kg/day

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 applicable units. HAP emission calculations are 

included in EUG 6 – VOC Sources Not 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 requirements 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 Polyethylene Extruder, Gloucester Engineering, Model #264-

001, Serial #264-28879-001, was originally included in this list but was relocated to the 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 29

Insignificant Activities list as a result of a meeting between the applicant and AQD on May 11, 

2005. Additionally, the draft permit was revised to eliminate 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, 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 Flexo #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 National Council for Air and Stream 

Improvement (NCASI) and overall emission factors developed for each pollutant emitted from 

the systems. The following discussion of the derivation of emissions was taken from the 

applicant’s submittal dated May 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 paper industry and worked 

closely with the United States Environmental Protection Agency (“USEPA”) to develop a 

sampling program to gather information on emissions of Hazardous Air Pollutants (“HAPs”) that 

would support the development of Maximum Achievable Control Technology (“MACT”) 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 30

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 lbs/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) was in effect under Part 5 of OAC 

252:100-41 (Subchapter 41). Subsequent to public notice of the draft permit, during which 

comments from the applicant were under consideration, Part 5 of Subchapter 41 was superseded 

by OAC 252:100-42, which has become effective by emergency 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 program was to characterize the emissions of volatile organic HAPs 

from various processes to determine if these emissions could be related to key process variables. 

A secondary goal was to obtain emissions data that could be used to prepare Title V operating 

permit applications and to improve the accuracy of annual release estimates required by SARA 

313. Initiated in 1994, the sampling program 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 detection 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 below, 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 process vent gases, it was necessary to collect 

samples from mills that used processes and additives that were typical of the industry.

2. The facilities chosen were to include processes targeted by USEPA in 1994 for potential 

MACT III regulations, which included de-inking.

3. For each targeted mill process, major variables possibly affecting emissions were to be 

considered. Within recovered fiber pulping, de-inked and non-de-inked pulping were 

included. Within the category of paper production, recovered fiber tissue and towel were 

included.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 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 I

In phase I, the following six process liquid samples were collected for the screening study 

analysis at the pulp processing facility: Test Area 1 unbleached washer filtrate, bleached washer 

filtrate, Test Area 2 unbleached washer filtrate, bleached 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.

 

 

 

PHASE II

Emissions from process vents were measured from the Pulp Processing Test Area 1 by NCASI. 

Emission measurements were taken at the Unbleached 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 Rejects 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 source, 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 source 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 then normalized by dividing the emission rate by 

the System production/throughput rate in short tons (T) to obtain the final results (lb/T).
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 32

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)

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

NCASI generally states in its report 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) during 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 available emission estimates for 

any existing system. Each System in Pulp Processing 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 similar process to produce a similar product. This 

assumption and methodology is somewhat analogous to using an AP-42 emission factor for a

category of gas boilers that are similar in heat input rating, 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 whereas 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 structures, are associated with both bleaching species.” The 

applicant therefore believes that emissions using the new additive are similar to emissions prior 

to using the additive.

The discussion above summarized how HAP emission factors for two types of bleaching were 

tested by NCASI. When the emission factors were selected to estimate potential-to-emit (PTE) 

emissions for the mill’s Title V application, the higher factors were selected and applied to the 

maximum expected production rates for the pulping system. This method more-than-likely over 

estimates emissions, but is the most conservative 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 performed at these conservative emission estimates.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 33

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 Units

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

Naphthalene 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 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 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 result in estimated emissions of 25 TPY of VOCs. 

This was to account for chemicals that were not in use when the NCASI testing was performed 

in 1995. Also, they were not included in the original 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 34

these Paper Machine Additives, be incorporated into the Title V permit to allow for flexibility 

and potential growth.

The applicant provided additional information in their 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 requested that AQD not consider the 

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 are currently not a concern as TACs. HAPs are 

indicated in bold font.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 35

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 Methylene 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 Solvent

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 NA - fume or dust / copper compounds 

blue dye 6 0.07 111-42-2 Cat. B Diethanolamine

15 0.00 NA - fume or dust / copper compounds 

Post-Draft Permit Emissions Estimation

As noted in the previous section, “Paper Machines 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 additives used in the paper machines. As a result of discussions 

with the applicant after the draft permit public notice, the applicant feels that the primary driving 

force of VOC emissions from the paper making process (note this is not the same as the pulping 

process) is due to VOC-containing 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 from Paper Machine Additives will be calculated from the VOC-containing 

Paper Machine chemicals. The basis for the emissions calculation is a mass balance using the 

summation of the estimated VOCs emitted from additives 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 projected to meet near term needs. 

The emissions are primarily from paper enhancement chemicals, dyes, etc. VOC emissions are 

based on VOC concentrations and throughput of each chemical, assuming 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 cleaning, 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 with the latex buildup on the wire, and 20% ends 

up in the water loop and eventually in the wastewater treatment plant. The 60% evaporation rate 

was carried over from Permit No. 91-127-O (M-1), issued for PM-15. Solvent cleaning 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 36

emissions for the other machines have not been addressed in previous permits. The applicant has 

proposed limits in the Title V application based on similar emissions criteria and 1998 material 

usage projected to future demand. However, because VOC emissions from these sources have 

drastically increased since the 1998 application and the applicant expressed concerns over this 

limit, the TV permit has been amended to increase the limit from 179.1 TPY to 338.0 TPY. The 

numbers in the tables below did not reflect permitted numbers for PM-15 in the previous 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 Paper 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 carried 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 Plant, 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 Poly 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 Organic Emissions from 

Existing Stationary Sources – Volume VIII: Graphic Arts – Rotogravure and Flexography” (EPA450/2-78-033, December 1978). This document is referred to on page 8 of ODEQ’s permit 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 37

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, installed as part of a control system for Permit No. 

83-062-O PSD, which also included the polyethylene extruder and the flexographic printing press, 

where a destruction efficiency of 96.8% has been measured. Emission calculations are based on 

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 printing presses. Water-base inks are used to 

print paper machine parent rolls to produce printed parent rolls. These printed parent rolls are 

then converted to both towel and napkin products. There are no stacks for these processes. At 

the time of the application, the average VOC concentration 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-color, in-line flexographic printing press. Water-base inks 

are used to print paper machine parent rolls to produce printed towel products at the 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 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.

New FP-8 Flexographic Printer

A method for calculating emissions from printing 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, Chapter 4, Section 4.9.1.2 (4/81). Both methods are 

mass balance, based on material usage. The following equations are from the TSD.

EM = E1 + E2 + E3 + E4

where: EM = Total VOC emissions as summed from VOC emissions for individual materials 

(e.g., ink, fountain solution, etc.)

En = Un x Vn x (1 – Rn/100) x {1 – (ηn/100) x (ξ/100)}

where: En = VOC emissions from an individual material

Un = Total usage of the individual material

Vn = Actual VOC content averaged over the collection period, e.g., 30 days

Rn = Amount of VOC retained and not emitted

ηn = 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 significant emission increase of a 

regulated NSR pollutant is projected to occur if the sum of the difference between the potential 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 38

to emit from each new emission unit following completion of the project and the baseline actual 

emissions of these units before the project equals or exceeds the significant amount for that 

pollutant.

Thus, a calculation of the potential to emit (PTE) for the new printer requires a calculation of Un

(total material usage) at the maximum capacity 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 hours of operation or on 

the type or amount of material combusted, stored, or processed, is treated as part of its design if 

the limitation or the effect it would have on emissions 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 restriction (enforceable limit) on Un as follows:

Rn = 0; assumes all VOCs are emitted

ηn = 0; since there are no controls, capture efficiency is not a factor to be

considered

ξ = 0; there are no control devices

The known values are:

Un = 462,820 pounds per year

Vn = 10%

Therefore:

En = 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, modeling to determine compliance with the NAAQS was 

not required. There are other regulatory standards that limit emissions. All printing operations 

are subject to Subpart KK. Emissions of HAPs are limited at this facility 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 requirements of 

OAC 252:100-42. As previously noted, the draft permit was revised to scale down the 

requirements for compliance with OAC 252:100-41, which was replaced by OAC 252:100-42, a far 

less restrictive rule as applied to this facility. Therefore, no evaluation of TACs was done. The 

applicant has requested to combine the limits of FP-7 and FP-8 into 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 flexo-plate making service. VOC-containing solvents are used in the 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 39

finishing step of plate-making. A detailed discussion of the emissions is included for that process. 

The applicant has indicated that these 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 of 

increased demand, again the applicant is requesting an enforceable 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 from 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 proposed 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 testing of Rincon’s #19 Paper Machine drying hood 

indicated 0.465 lbs/hr of particulate matter generated, of which, 0.415 lbs/hr was not due to 

burning natural gas. The emission factor was converted 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 emissions 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 overall 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 40

production used in Title V potential-to-emit calculations in the original application, resulting in 

total emissions as illustrated in the table below.

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 collection system that is specifically designed to 

reduce dust inside the paper machine 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 operating. Since emissions will be permitted at 

potential levels, no monitoring or recordkeeping will be required for this collection system.

Hazardous Air Pollutants (HAPs) and Toxic Air Contaminants (TACs)

The Toxic Air Contaminants (TACs) and Section 112(a) Hazardous Air Pollutants (HAPs) that 

are emitted from the processes were discussed in various sections of the original draft permit for 

public notice. Because of the length 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 issued 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 and 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). Modeling was 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.

BART Review

As noted in the “Introduction”, the facility has two boilers that are considered “BART – eligible” 

sources, having the potential to contribute to “visibility impairment”, Boiler B-1 and Boiler B-2. 

The applicant requests that an enforceable emission limit be imposed on Boiler B-1 to maintain 

emissions below the “contribution threshold” that, if exceeded, would be considered to “cause 

visibility impairment”.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 41

Subpart Y outlines the three steps involved in determining whether a source or group of sources 

cause or contribute to visibility impairment for purposes of BART. Step 1 establishes a 

threshold (measured in deciviews) against which to measure the visibility impact of one or more 

sources. There are maximum thresholds for “cause” and “contribute” to impairment of visibility.

A single source responsible for a 1.0 deciview change or more should be considered to “cause” 

visibility impairment. Any threshold for determining whether a source “contributes” to visibility 

impairment should not be higher than 0.5 deciviews. The “contribution” threshold is used to 

determine whether an individual source is reasonably anticipated to contribute to visibility 

impairment. The applicant has proposed that the Subpart Y default value of 0.5 deciviews for 

the “contribution” value be adopted for this evaluation. Step 2 establishes the pollutants that 

need to be considered. The Georgia-Pacific plant emits all pollutants of concern, i.e. SO2, NOX, 

and PM. Step 3 establishes the modeling method(s) to be used to determine which sources and 

pollutants need not be subject to BART. The applicant used CALPUFF to process and produce 

pollutant concentrations from CENRAP data for the years 2001 through 2003. CALPUFF is the 

best regulatory modeling application currently available for predicting a single source's 

contribution to visibility impairment and is currently the only EPA-approved model for use in 

estimating single source pollutant concentrations resulting from the long range transport of 

primary pollutants. It can also be used for some other purposes, such as the visibility 

assessments addressed in today's rule, to account for the chemical transformation of SO2 and 

NOX. The applicant’s report states that output from CALPUFF was used in CALPOST to 

evaluate contributions to impairment of visibility.

Within Step 3 of the aforementioned applicability procedure are three options for determining 

that certain sources need not be subject to BART. These options rely on different modeling 

and/or emissions analysis approaches. The applicant chose Option 1, Individual Source 

Attribution Approach (Dispersion Modeling). This option provides for dispersion modeling to 

determine that an individual source cannot reasonably be anticipated to cause or contribute to 

visibility impairment in a Class I area and thus is not subject to BART wherein the 

“contribution” threshold is compared against the 98th percentile of values. If the 98th percentile 

value from modeling is less than the contribution threshold, then it may be concluded that the 

source does not contribute to visibility impairment and is not subject to BART. For this 

evaluation, the applicant used maximum impacts rather than 98th percentile values as the 

standard. It should be noted that dispersion modeling cannot currently be used to estimate the 

predicted impacts on visibility from an individual source's emissions of VOC or ammonia.

The highest contribution to visibility impairment was 0.49 dv, having occurred in the year 2003 

in the Caney Creek Class I Area. The full table illustrating the results of the modeling can be 

found in the applicant’s report titled “Analysis For Best Available Retrofit Technology – Waiver 

Request”, dated march 2007 and submitted to AQD under cover letter dated March 30, 2007. An 

adjustment to include paper machine Emission Units PM-11 and PM-12 increased the 

contribution to 0.498 dv.

Finally, the applicant proposes that the use of an enforceable limit on NOX of 744 lbs/day will 

prevent a contribution to impairment of visibility from exceeding 0.5 dv. As noted in various 

discussions throughout this memorandum, Subpart Y requires that DEQ establish the enforceable 

emission limit for each subject emission unit and for each pollutant subject to review and require 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 42

compliance with the BART emission limitations no later than 5 years after EPA approves DEQ’s 

regional haze SIP. 

SECTION VI. INSIGNIFICANT 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 Management Association (JAWMA) were used for 

linear low density polyethylene (LLDPE) blown film at a 355 oF 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 oF. Other emission factors associated 

with the JAWMA document refer to either high-density blow molding or extrusion coating. 

Neither of these processes matches the process at the Poly Plant.

VOC and TAC/HAP emissions were calculated using the emission factors 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 production rate used to calculate a potentialto-emit is estimated at 6.0 MM lbs/yr.

EUG 6 – VOC/TAC/HAP/PM Emissions 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 processes. Using an emission factor 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 43

recycling operation at the Poly Plant, since all scrap is sold. A small amount of trim is re-melted 

and returned directly 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 applicant based on some research of two coal-fired 

power plants. One was permitted in Colorado, and the other in Kentucky.

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 batching 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 that 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 the 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 baghouses. The ash is then 

loaded into enclosed trucks and disposed in the 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/ton controlled and 3.14 lbs/ton uncontrolled. Estimating a 

maximum potential ash generation of approximately 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 PM10,

U = wind speed (15 mph, worst case value from Ranges of Source Conditions), and

M = moisture content (0.25 %, worst case value from Ranges of Source Conditions)

Applying the above factors, E = 0.0859 lbs PM/ton of ash.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 44

At 51,000 TPY of ash, PM emissions would equal 4,381 lbs/year from truck loading, dumping, 

and pile erosion. This yields a total of 4,835 lbs/year of PM emissions for all of ash handling.

Converting Trim Vent

Following is an evaluation performed by the applicant based on emissions information obtained 

from a sister facility in Green Bay, Wisconsin.

At the subject facility, scrap paper from the converting operations, called “trim” 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 and dumped on an overhead conveyor to a pulper.

Some of the broke, however, is conveyed pneumatically 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 Converting 

operations at the subject facility as well as Converting 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 equate to 63.2 lbs/year.

Printed Napkins

Printed napkins are printed by a group of eight (8) letterpress printing presses in the converting 

area. These presses do not perform publication rotogravure, product and packaging rotogravure, 

or wide-web flexographic printing and are not subject to the printing and publishing MACT, 

Subpart KK. They were not included in the 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 generated as a result of treating the film in this 

manner. The ozone from this source is vented to the atmosphere without 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 Station 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 generated ozone to molecular oxygen. Emissions are exhausted to the 

atmosphere outside to the south of the building. This corona treater is seldom used and is 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 45

currently present as a back-up system. The permit 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 Model 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 justified in the application are duplicated below. 

Records must be available to confirm the insignificance of the activities. Appropriate 

recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.

1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 

MMBTU/hr heat input (commercial 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 aboveground 10,000-gallon gasoline tank existing 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 several 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 constructed with a capacity less than 39,894 gallons which 

store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. 

There are several diesel and solvent tanks at the facility.

5. Additions or upgrades of instrumentation or control systems that result in emissions 

increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1).

6. Cold degreasing operations utilizing solvents that are denser than air. There are numerous 

activities under this category.

7. Site restoration and/or bioremediation activities of < 5 years expected duration. There are 

no activities under this category at the facility at this time.

8. Hydrocarbon contaminated soil aeration pads utilized 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 HAPs (§112(b) of CAAA90). The facility 

currently operates groundwater monitoring wells that are required by the facility’s solid 

waste landfill permits. There are no groundwater remediation wells at the facility at this 

time.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 46

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 drum staging areas. There are numerous 

activities under this category.

12. Sanitary sewage collection and treatment facilities other than incinerators and Publicly 

Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are 

also included (i.e., lift station). All of the facility’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.

15. Hand wiping and spraying of solvents from containers with less than 1 liter capacity 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 more 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, Gloucester Engineering, Model #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 applicable provisions of Title 40 of the Code of

Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in 

the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary 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.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 47

OAC 252:100-5 (Registration, Emissions Inventory 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 requirements for Part 70 permits. Any planned 

changes in the operation of the facility that result in emissions not authorized in the permit and 

that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior 

notification to AQD and may require a permit modification. Insignificant 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 pollutant

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 Reporting 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 emissions 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 extent 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 ongoing 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 material is prohibited except as authorized in the 

specific examples and under the conditions 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 based on maximum design heat input 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 combustion of fuel into usable energy. Thus, 

Boilers B-1, B-2, B-3, and B-4, Paper Machine Drying Hoods PM-11, PM-12, PM-13, PM-14, 

and PM-15, and the PO-1 Tunnel Dryer (Flexographic Polyethylene Printer) are subject to the 

requirements of this subchapter. AP-42 (7/98) Table 1.4-1 lists natural gas Total Particulate 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 48

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. Converting 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 compliance for all combustions units burning any of the 

permitted fuels. It should be noted 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

440 MMBTUH

Hi Btu Coal 0.032 (1), (2) 0.0076 0.07 (3) 0.24

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/gal, 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 based 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.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 49

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 Stacker, 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 above

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for 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 consecutive 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 natural gas are therefore not likely to exceed this 

standard. Equipment subject to a Subpart Y opacity 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; therefore 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 fuel-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 analysis method is used to determine emission 

compliance. In that case the averaging 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 memorandum. It should be noted that 

the values for natural gas combustion are based on AP-42 emission factors.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 50

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

NA

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), SO2 = 157S lbs/103gal, 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 fossil 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 NOX 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, all burners combined, of 50 MMBTUH and is also subject. 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

NOX (Hi Btu Coal) (6) 0.52 lbs (1), (3)

MMBtu

0.19 lbs 

(5)

 MMBtu

0.21 lbs 

(1), (4)

 MMBtu

NOX (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
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 51

EMISSION UNIT COAL 

Emissions 

Factor

NATURAL GAS 

Emissions Factor

FUEL OIL 

Emissions 

Factor

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 Monoxide) [Not Applicable]

This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum 

catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources.

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

Part 3 requires storage tanks constructed after December 28, 1974, with 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 organic 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 coating lines or operations. This facility will not 

normally conduct coating or painting operations except for routine maintenance of the facility 

and equipment, which is not an affected operation.

Part 7 requires fuel-burning equipment to be operated 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 into the ambient air in 

areas of concern (AOC). Any work practice, material substitution, or control equipment required 

by the Department prior to June 11, 2004, to control 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 requirements 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 Oklahoma to install, maintain and 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 52

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant 

source. All required testing must be conducted by methods approved by the Air Quality Director 

and under the direction of qualified personnel. A notice-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 federal 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 conducted in accordance with the provisions of this 

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive 

use, of any credible evidence or information relevant to whether a source would have been in 

compliance with applicable requirements if the appropriate performance or compliance test or 

procedure had been performed.

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

OAC 252:100-7 Permits for Minor Facilities not in source category

OAC 252:100-11 Alternative Emissions 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 Elevators 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

SIP, 40 CFR Part 51, Appendix Y, Guidelines for BART Determinations [Applicable]

BART-eligible (Best Available Retrofit Technology) sources include those sources that: (1) have 

the potential to emit 250 tons or more of a visibility-impairing air pollutant; (2) were in existence 

on August 7, 1977 but not in operation prior to August 7, 1962; and (3) whose operations fall 

within one or more of the specifically listed source categories in 252:100-8-71.

Georgia Pacific is not a Kraft pulp mill but has fossil-fuel fired boilers of more than 250 million 

Btu/hr (MMBTUH) input Boilers B-1 and B-2 were in existence prior to August 7, 1977 (i.e., 

construction of the units had commenced), but not in operation prior to August 7, 1962. Based 

on a review of existing emissions data, either B-1 or B-2 alone has the potential to emit more 

than 250 tons per year of visibility impairing pollutants, specifically NOX or SO2. Therefore, 

Emission Units B-1 and B-2 meet the definition of a BART eligible source. BART is required 

for any BART-eligible source that emits any air pollutant which may reasonably be anticipated 

to cause or contribute to any impairment of visibility in a Class I Area. Following EPA guidance, 

DEQ has determined that an individual source will be considered to “contribute to visibility 

impairment” if emissions from the source result in a change in visibility, measured as a change in 

deciviews (Δdv), that is greater than or equal to 0.5 dv (0.5 decviews) in a Class I area. 

Visibility impact modeling previously conducted by Georgia Pacific determined that the 

maximum predicted visibility impacts based on the limits specified in this permit from Emission 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 53

Units B-1 and B-2 do not exceed the 0.5 dv threshold at any Class I area. However, this is based 

on a voluntary reduction in NOX emissions to 744 lbs/day to be achieved by a limitation on 

natural gas fuel input to Boiler B-1, therefore requiring this permit modification. Therefore, 

upon approval of DEQ’s SIP, Georgia Pacific will not be subject to additional BART control 

determination requirements unless there is an emissions increase.

PSD, 40 CFR Part 52 [Not Applicable 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, NOX - 40 TPY, SO2 - 40 

TPY, VOC - 40 TPY, PM - 25 TPY, PM10 - 15 TPY, and Lead - 0.6 TPY.

NSPS, 40 CFR Part 60 [Subparts 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 megawatts heat input rate (250 million Btu per hour). 

Boilers B-1, B-2, B-3, and B-4 are all rated above this threshold and are therefore affected 

facilities. §60.42, §60.43, & §60.44 – contain standards for particulate matter, sulfur dioxide, 

and nitrogen oxides. The standard for particulate 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 SO2 is 0.8 lbs/MMBtu from liquid fossil 

fuels and 1.2 lbs/MMBtu from solid fossil fuels. The standard for NOX 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 permitted to burn fuel oils and natural 

gas. Initial compliance testing for coal combustion was performed for Boilers B-2, B-3, and B-4. 

Initial compliance testing 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 carbon 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 measuring sulfur dioxide emissions is not required if 

the owner or operator monitors sulfur dioxide emissions by fuel sampling and analysis. If the 

owner or operator demonstrates during the performance test that emissions of nitrogen oxides are 

less than 70 percent of the applicable standards in §60.44, a continuous 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 Performance for Electric Utility Steam Generating Units for Which 

Construction is Commenced After September 18, 1978 (§§60.40a - 60.49a), affects each electric 

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 combination 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 potential electric output capacity and more than 

25 MW electrical output to any utility power distribution system for sale. Any steam supplied to 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 54

a steam distribution system for the purpose of providing steam to a steam-electric generator that 

would produce electrical energy for 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 generating unit of greater than 29 MW (100 million 

Btu/hr). Construction of the boilers commenced prior to the effective date and have not been 

modified or reconstructed and are 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 subject to the requirements of this subpart.

Subpart Y - “Standards of Performance for 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 (air tables), coal processing 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 coal 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 preceding unloading/conveying equipment are not affected 

facilities. However, it was also concluded “fugitive emissions from coal dumping at the site of a 

coal preparation plant must be counted 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 determine whether fugitive emissions from that facility 

are to be counted in determining whether the source as a whole 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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 55

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 and 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 equipment 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 described here are subject to this rule.

NESHAP, 40 CFR Part 61 [Potentially 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 disposal 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 existing 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. Georgia-Pacific uses secondary wood (recycled paper) 

fiber and is an affected facility. However, as a result of the processes and bleaching chemicals 

used in producing the secondary fiber pulp, the facility is not subject to any of the standards in 

the subpart.

Subpart KK - National Emission Standards for the Printing and Publishing Industry, applies to 

each new and existing facility that is a major source of hazardous air pollutants (HAP), as 

defined in 40 CFR 63.2, at which publication rotogravure, product and packaging rotogravure, or 

wide-web flexographic printing presses are operated and area sources as outlined in 

§63.820(a)(2). For product and packaging, affected 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 proof presses, and any product and packaging 

rotogravure or wide-web flexographic press which is used primarily for coating, laminating, or 

other operations which the owner or operator chooses to exclude under certain provisions listed 

in this section. The owner or operator of product and packaging rotogravure, or wide-web 

flexographic printing presses may also elect to include in that affected source stand-alone coating 

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

sources:
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 56

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

June, 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 Polyethylene Printer Bretting, 4-color, 78-inch wide June, 2005

Each product and packaging rotogravure or wide-web flexographic printing affected source at a 

facility that is a major source of HAP, as defined in 40 CFR 63.2, that applies no more than 400 

kg per month, for every month, of organic HAP on product and packaging rotogravure or wideweb flexographic printing presses, on and after the applicable compliance date as specified in 

§63.826 of this subpart is subject only to 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 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, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills, applies 

to each kraft, soda, sulfite, or stand-alone semichemical pulp mill that is a major source of 

hazardous air pollutants (HAP) emissions as defined in §63.2. The 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 pulp 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 mill; (4) Each new lime kiln located at a kraft or soda pulp mill; 

(5) Each new or existing sulfite combustion unit 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 semichemical combustion unit located at a standalone semichemical pulp mill; (7) The requirements of the alternative standard in §63.862(d)

apply to the hog fuel dryer at Weyerhaeuser Paper 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 Hazardous Air Pollutants for Industrial, 

Commercial and Institutional Boilers and Process Heaters. In March, 2007, the EPA filed a 

motion to vacate and remand this rule back to the agency. The rule was vacated by court order, 

subject to appeal, on June 8, 2007. No appeals were made and the rule was vacated on July 30, 

2007. Existing and new small gaseous fuel boilers and process heaters (less than 10 MMBtu/hr 

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

DDDDD.
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 57

EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting 

authorities should take regarding MACT determinations under either Section112(g) or Section 

112(j) for sources that were affected sources under Subpart DDDDD and other 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 potentially 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 emission unit at a major source 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 application that addresses “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 with the applicable emission limit or standard

It has potential emissions, prior to the control 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 TPY of a regulated pollutant or 10/25 TPY of a 

HAP), but they are not large emissions units since post-control emissions do not equal or exceed 

100 TPY. They will be subject to CAM upon renewal of the Title V permit.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

The emissions units subject to this determination do not process or store more than the threshold 

quantity of any regulated substance (Section 112r 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 CFR Part 82 [Subpart F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I 

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential 

products containing ozone-depleting substances (Subparts A & C); control servicing of motor 

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations 

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require 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 ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons 

(Subpart H).

Subpart A applies to any person that produces, transforms, destroys, imports or exports a 

controlled substance or imports or exports a controlled product. It identifies ozone-depleting 

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 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 58

tetrachloride (Class I, Group IV) and methyl chloroform (Class 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, scheduled 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, maintaining, 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, manufacturers of appliances, manufacturers of 

recycling and recovery equipment, approved recycling and recovery equipment testing 

organizations, persons selling class I or class II refrigerants or offering class 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 class II refrigerants and their substitutes to the 

lowest achievable level by maximizing the recapture and recycling of such refrigerants during 

the service, maintenance, repair, and disposal of appliances and restricting the sale of refrigerants 

consisting in whole or in part of a class I and class II ODS in accordance with Title VI of the 

Clean Air Act.

The facility performs maintenance that involves recycling 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 repair requirements, standards for 

recycling and recovery equipment, technician certification, and recordkeeping requirements. 

Additional applicable requirements are found in the rule.

SECTION IX. COMPLIANCE

Inspection

An inspection is not required for this permit modification since there is no physical or 

operational change being made 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 determined to be a Tier II based on the request for a significant 

modification as described in OAC 252:100-8-7.2(b)(2), of an operating permit that is not based on 

an underlying construction permit processed under Tier II or Tier III, and OAC 252:100-8-8.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any 

operation upon land owned by others without their knowledge. The affidavit certifies that the 
PERMIT MEMORANDUM 99-113-TV (M-5) DRAFT 59

applicant owns the real property. The applicant has not published the notice for the Tier II 

application. That will be done concurrently with the notice of Tier II draft permit.

This site is not within 50 miles of the Oklahoma border. Information on all permit actions is 

available for review by the public in the Air Quality section of the DEQ Web page: 

www.deq.state.ok.us/.

Fee Paid

Significant modification fee of $1,000.

SECTION X. SUMMARY

There are no active Air Quality compliance or enforcement issues that would affect the issuance 

of this permit. Issuance of the operating permit is recommended contingent on Public and EPA 

review.
DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Georgia Pacific Company Permit No. 99-113-TV (M-5)

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 for an operating permit modification on May 7, 

2009. The Evaluation Memorandum dated August 23, 2010, explains the derivation of 

applicable permit requirements and the estimates of emissions, however, it does not contain 

operating limitations or permit requirements. Continuing operations under this permit constitutes 

acceptance of, and consent to, the 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 single 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)

SO2

(lbs/MMBTU)

NOX

(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 0.000009
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 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 Performance for Fossil-Fuel-Fired 

Steam Generators for Which Construction is Commenced After August 17, 1971. The 

permittee shall comply with all applicable requirements including standards, emission 

and fuel monitoring, test methods and procedures. Compliance with the emission limits 

specified in this permit shall be demonstrated 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 applicable requirements including, but not limited to, 

standards, operating limits, work practice standards, emission and fuel monitoring, test 

methods and procedures, and recordkeeping and reporting.

C. Additional limitations for Boiler B-1. [OAC 252:100-8-6(a)], [40 CFR, 51, Appendix Y]

Permittee shall implement the requirements of this permit condition within five (5) 

years of EPA’s approval of DEQ’s Regional Haze SIP submitted in 2010. Emissions of 

NOX from Boiler B-1 shall be limited to no more than 744 lbs/day on a 30-day rolling 

average. Initial compliance with this limit shall be demonstrated by initial stack testing. 

Continuous compliance shall be demonstrated by monitoring fuel consumption at least 

daily using the existing fuel meter and calculating a 30-day rolling average. 

Performance testing shall be conducted on Boiler B-1 for NOx. Testing for Boiler B-1 

shall be conducted while it is being operated at least 90% of maximum operating hourly 

capacity. A sampling protocol utilizing the proper USEPA methods and notification of 

testing date(s) shall be submitted at least 30 days in advance of commencement of 

testing.

D. Additional limitations for Boiler B-4. [Permit No. PSD-OK-404]

i. Upon the first firing of natural gas, compliance with the emission limits of this 

condition shall be demonstrated by test methods and procedures as set forth in 40 

CFR Part 60 Appendix A; Method 7, Determination of nitrogen oxide emissions 

from stationary sources; Method 10, Determination of carbon monoxide emissions 

from stationary sources; and Method 9, Visual 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 NOX CO SO2 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 

Gas (lb/MMBtu) 0.2 0.084* 0.001 0.005 0.006* Emissions

* 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 Specific Condition Nos. 3.F., G., J., and K.
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 3

EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP

EU ID Manufacturer & Serial Number Fuels Construc

t Date

Burner 

Replace

PM-11 Kinedizer 27M Gas/Propane 1975 1999

PM-12 Oven-Pak EB6 Model 400 Gas/Propane 1975 2003

PM-13 Oven-Pak EB6 Model 400 Gas/Propane 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 SO2 (lbs/MMBTU)

Natural Gas 20/60 0.2

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

EU ID NOX (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-5) DRAFT 4

40 CFR 60 Subpart Y

Grizzly Feeder

Coal Sizer/Crusher

Conveying

Coal Bunkers

Coal Feeders

Pulverizers

F. Coal Preparation Plant. [OAC 252:100-4], [40 CFR 60 Subpart Y]

i. The sources listed in the table above identified as “40 CFR 60 Subpart Y” are subject 

to 40 CFR 60, Subpart Y, Standards of Performance for Coal Preparation Plants. 

The initial performance testing requirements to demonstrate compliance with the 

opacity standards were completed and the standards were met.

G. 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, Subpart S, National Emission Standards for 

Hazardous Air Pollutants from the Pulp and 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 not use chlorine or chlorine dioxide to bleach pulp. The use of these 

bleaching agents shall make the facility subject to the standards of 40 CFR Part 63, 

Subpart S and require submittal of an application for a permit 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 Bretting, 4-color, 78-inch wide 2005
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 5

H. All presses, Subpart KK Flexographic Printing. [40 CFR 63 Subpart KK]

i. EUG 5 is subject to Subpart KK - National Emission Standards for the Printing and 

Publishing Industry. The permittee shall comply with all applicable requirements.

ii. The application of organic HAP on product 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 rotogravure 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 Flexo #7 – PCMC/Model No. 6725 1997

FP-8 Flexographic Printer Bretting, 4-color, 78-inch wide 2005
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 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 Printer (six printers)

FP-7/Flexographic Paper Printer

FP-8/Flexographic Paper Printer

92.28 TPY

I. 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

J. 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.

K. PP-1 Paper Pulping.

i. Total combined VOC emissions from the 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 emission factor of 0.45 lbs/ton 

finished pulp stock.

L. 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 paper machine additives 
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 7

shall not exceed 90.0 TPY, 12-month rolling cumulative, based on the permittee’s 

fiscal month accounting basis.

ii. Emissions of VOCs from solvent 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 fiscal 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.

M.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 specified in the above table as allowed by 

Permit No. 83-062-O (PSD) for PO-1 and supplemented by this permit for FP-1, FP-7, 

and FP-8.

i. Emission calculations shall be based on mass balance, assuming 100% evaporation 

of the maximum VOC content of the inks and cleaning solvents. Emissions from the 

PO-1 Flexographic Printer shall be prorated into uncontrolled and controlled using 

factors of 30% and 70%, respectively, with an additional efficiency factor applied to 

controlled emissions to account for thermal destruction through the PO-1 Catalytic 

Oxidation Incinerator.

ii. The Enercon Model ASO41V-300 shall be operated only with a properly functioning 

decomposer.

N. Additional limitations for the PO-1 Flexographic Printing Press and Platemaking.

[Permit No. 83-062-O (PSD)]

i. The permittee is authorized to use both corona treaters at the same time.

ii. Total VOC emissions from ink and solvent 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 permittee’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 1992

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
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 8

O. 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 methods and procedures, when firing a fuel 

not previously tested for initial compliance and evaluation of monitoring.

ii. In conducting the performance tests required in §60.8, the owner or operator shall 

use as reference methods and procedures the 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 alternative 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, compliance with the emission limitations shall be 

determined by the permittee using test methods and procedures as set out in 40 

CFR Part 60 Appendix A, and Subpart D.

ii. During the initial performance test, sulfur 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. Testing 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 and General Conditions of this permit. 

The permittee shall be allowed an additional mechanical checkout period not 

exceeding 16 hours in length.

v. Should any combustion equipment modifications be made such as different type 

burners, combustion air relocation, fuel conversion, tube removal or addition, etc., 

then emission correlations as described in the attachment to Permit No. PSD-OK404 titled “Use Of Flue Gas Oxygen Meter 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 days of attaining full operation after 

such modification. The permittee shall be exempt from this requirement and the 

requirement to install a continuous recording 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.
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 9

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 required in the specific conditions. This 

requirement has been met for firing coal.

ii. Each emission point for which an emission test method is established in this 

permit shall be tested in order to determine compliance with the emission 

limitations contained herein within sixty (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 continued 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 fired 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 Flexographic Printing Press 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 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 its proper operation, the permittee shall record the 

before (Thermocouple T/C 1) and after (Thermocouple T/C 2) catalytic cell 

temperature daily. The catalyst shall be evaluated at least 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.
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 10

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 sulfur content and gross calorific value using 

the most recent ASTM methods for sample preparation, sulfur analysis, and gross 

calorific value determination. Coal shall 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 confirm 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 Monitoring. 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 installed, 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 the specifications of 40 CFR, Part 60. The 

continuous monitoring data may, at the discretion of the permitting authority, be 

used to determine violations of the conditions of this permit.

iv. The opacity limits of Specific Condition No. 1 shall apply at all times.

v. The emission of any pollutant more frequently or at a level in excess of that 

authorized by this permit shall constitute a violation of the terms and conditions of 

this permit.

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

The permittee shall utilize all wet suppression equipment, e.g., “spray-bars”, on the 

conveyors preceding the coal-pile whenever necessary to meet the opacity standards of 

OAC 252:100-25 while coal is being unloaded and/or transferred to the coal-pile. A 
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 11

visual inspection of the wet suppression equipment 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 changing 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 Method 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 duration 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 whether the corrective actions were successful. If visible 

emissions are observed in duration of greater than one minute following 

implementation of corrective actions, then the permittee shall conduct, before 

nightfall, two visual observations of emissions each hour for the next four hours 

in accordance with 40 CFR Part 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 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.

ii. The permittee shall conduct an EPA Method 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 Condition 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 immediate corrective actions to reduce the 

opacity. Following implementation of corrective actions, a Method 9 shall be 

conducted at the affected emission point(s) to document whether the corrective 

actions were successful. If the opacity from the Method 9 is greater than 20% 

following implementation of corrective actions, 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; 
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 12

except that if any of the additional Method 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 specifications are not available, a 

published industry standard shall suffice.

iii.A minimum and maximum oxygen concentration action level(s) (e.g., load-based 

concentrations) representing “good combustion practice” 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.

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 action level(s), a boiler operational plan (including a 

corrective action plan to ensure good combustion practices), as well as supporting 

information documenting good combustion shall be maintained on-site in an 

operation and maintenance (O&M) manual for the boiler. Supporting information 

necessary to document good combustion includes calibration and maintenance 

records, strip-chart or other data recordings, performance tests or portable 

combustion analysis results for NOX, 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.

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 action level representing “good operating 

conditions” shall be established using the most appropriate of the following:

(1)the most recent performance test data;

(2)manufacturer’s recommendations;
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 13

(3)engineering calculations; 

(4)operator knowledge; and/or 

(5)historical data

The permittee shall record any exceedance outside the established opacity action level 

and take immediate corrective action to return the affected 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 recordkeeping 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 field operational status and opacity for 

increasing trends in opacity caused by potential malfunctions of the ESP. In the 

event of a maximum opacity action level exceedance, the permittee shall verify that 

the electrostatic precipitator is properly functioning. The permittee shall record any 

exceedance outside the established opacity action level and take immediate 

corrective action to return the electrostatic precipitator to good operating conditions.

ii. The permittee shall develop and implement an operation and maintenance (O&M) 

manual for the electrostatic precipitator for determining and documenting good 

operation. At a minimum the plan shall contain the following provisions.

(1)The maximum opacity action level(s) for opacity.

(2)Improper dust accumulation.

(3)A description of scheduled electrostatic precipitator maintenance activities.

(4)A description of electrostatic precipitator recordkeeping activities.

4. Hours of Operation. [OAC 252:100-8-6(a)(1)]

i. The facility is authorized to operate 24-hours per day, every day of the year.

ii. Emergency Generator units DG-1 and DG-2 are limited to 1,440 hours 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.

(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 modified or replaced, upon prior approval of 

the Air Quality Division, provided that it can be demonstrated that the replacement 
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 14

equipment is at least as efficient in controlling 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 through 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 NOX emissions shall consist of the use of low NOX burners to limit 

emissions to 0.7 lbs/MMBtu.

(2)BACT for PM emissions shall consist of a fabric filter collection system to limit 

emissions to 0.1 lbs/MMBtu.

(3)BACT for SO2 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 consist of boiler design, efficient equipment 

operation, and the use of combustion controls shall be utilized to ensure 

minimization of CO and VOCs and to ensure 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 shall consist of the use of low NOX burners and 

natural gas for the primary fuel. All other 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 requirements incorporated from existing permits.

A. Boiler B-4.

[General Conditions, Permit No. PSD-OK-404]

i. The permittee shall notify the permitting 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.

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);
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 15

(2) cause of noncompliance;

(3)anticipated time the noncompliance is expected 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 prevent recurrence of the noncomplying 

emission.

Failure to provide the above information when appropriate shall constitute a 

violation of the terms and conditions 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 submitted in the application regarding facility 

emissions or changes in the quantity or quality 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 necessary changes in the permit 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 succeeding 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 shall 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 permittee 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 provided to regulatory personnel upon request.

[OAC 252:100-8-6(a)(3)(B)]

All EUGs

A. Either a material safety data sheet (MSDS) or a certified product data sheet, that 

documents the volatile organic solvent content and the HAP content of each raw 

material for which VOC emissions are regulated by this permit, including printing inks, 

cleaning solvents, and paper machine additives.

EUGs 1, 2, and 3

B. Records of fuel analyses, pollution control monitoring/inspection/maintenance, and 

continuous monitoring, and Method 9 and or Method 22 opacity monitoring required by 

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

Specific Condition No. 3).
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 16

EUGs 1 and 2

C. Information necessary to identify the equipment 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, Systems 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/VOC limitations by the appropriate method 

specified.

G. Usage of VOC -containing raw materials and calculations of VOC emissions based on 

the authorized emission factors and methodologies (monthly, 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 CFR Part 60, Subpart D. This information 

shall be recorded in a permanent form suitable for inspection and shall be retained for at 

least five years following the date of such measurements, maintenance, reports and 

records.

I. Records required by Specific Conditions 3.J., K., and L., including required data 

recording, supporting information 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 operations which qualify as Trivial Activities.

[OAC 252:100-8-6 (a)(3)(B)]

A. For fuel storage/dispensing equipment operated solely for facility 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 barrels less than or equal to 55 gallons with less than three 

percent by volume of residual material: Emissions from products contained in these 

drums are already accounted for at 100% product usage in other operations, therefore no 

records will be required.
SPECIFIC CONDITIONS 99-113-TV (M-5) DRAFT 17

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).

F. Records required to demonstrate compliance with the BART requirements (Specific 

Condition No. 1.C) of this permit beginning at the effective date of Specific Condition 

No. 1.C.

10. The Permit Shield (Standard Conditions, Section VI) is extended 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 Certification for each twelve (12) month period, no later than 30 

days after February 28, 2010 and each 12 month anniversary 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 Monitoring 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 thereafter 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.

13. This permit supersedes all previous Air Quality permits for this facility which are now null 

and void, except Permit No. 99-113-C (M-4) (PSD).
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. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the 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 Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance 

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement 

action, permit termination, revocation and reissuance, or modification, or for denial of a permit 

renewal application. All terms and conditions 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). This permit is valid for operations only at the 

specific location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and 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 this 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 environmental impacts of halting or reducing operations 

would be more serious than the impacts of continuing operations. [OAC 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 environment shall be reported in accordance with Section 

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported 

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III 

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2

SECTION III. MONITORING, TESTING, 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-site or at a nearby field 

office for a period of at least five years from the date of the monitoring sample, measurement, 

report, or application, and shall be made available for inspection by regulatory personnel upon 

request. Support information includes all original strip-chart recordings for continuous 

monitoring instrumentation, and copies of all reports required by this permit. 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 techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the 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 requirements since the previous 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 Section II (Reporting Of Deviations From Permit 

Terms) of these standard conditions. [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 required under the provisions of OAC 252:100-43, 

Testing, Monitoring, and Recordkeeping, or as required by any provision 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 Inventory submitted in accordance with this 

permit shall be certified by a responsible official. This certification shall be signed by a 

responsible official, and shall contain the following language: “I certify, based on information 

and belief formed after reasonable inquiry, the statements 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 subject to the provisions of New Source Performance Standards 

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants 

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other 

information required by the applicable general provisions and subpart(s). These records shall be 

maintained in a permanent file suitable for inspection, shall be retained for a period of at least 

five years as required by Paragraph A of this Section, and shall include records of the occurrence 

and duration of any start-up, shutdown, or malfunction in the operation 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-annually. 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 compliance was achieved. The 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 shall 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 manufacturer’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 emissions as required in Part 7 of OAC 252:100-8 

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and 

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing 

or calculation procedures, modified to include back-half condensables, for the concentration of 

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only 

particulate matter emissions caught in the filter (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. COMPLIANCE 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 specifically 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 effective 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 shall describe the operating permit term or condition that is the 

basis of the certification; the current compliance status; whether 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 the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the 

results of the required monitoring. This certification shall be signed by a responsible official, 

and shall contain the following language: “I certify, based on information and belief formed 

after reasonable inquiry, the statements and information 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 compliance with all applicable requirements. This 

schedule shall include a schedule of remedial measures, including an enforceable sequence of 

actions with milestones, leading to compliance with 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, except 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 facility. Compliance with all new requirements shall 

be certified in the next annual certification. [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 listed in the Standard Conditions and the Specific 

Conditions of this permit. Those requirements that the applicant requested be determined as not 

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 5

SECTION VII. ANNUAL EMISSIONS 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 available 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, the term of an operating permit shall 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 expiration of its permit unless a timely 

and complete renewal application has been submitted 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 provided 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 shall apply for a permit to operate (or modified 

operating permit) within 180 days following the first 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 permit, or the application 

of any provision of this permit to any circumstance, is held invalid, the application of such 

provision to other circumstances, and 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 property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon 

which the equipment is located and does not release the permittee from any liability for damage 

to persons or property caused by or resulting from the maintenance 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 receipt of a written request and within sixty 

(60) days of the request unless the DEQ specifies 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 the 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 shall be clearly labeled 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 facility is required and 

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened 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, termination, 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 Act 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 effective 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 inaccurate information was used in establishing the 

emission standards, limitations, or other conditions 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 changes other than those described in Section 

XVIII (Operational Flexibility), those qualifying for 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 changes 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 that exceed the trivial/insignificant levels and that 

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the 

permittee shall allow authorized regulatory officials to perform the following (subject to the 

permittee's right to seek confidential 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 pollution 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 compliance 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 after the permittee first becomes aware of the 

exceedance. This notice shall contain a description of the emergency, the probable cause of the 

exceedance, any steps taken to mitigate emissions, and corrective actions taken. 

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial 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 arising 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 operation, 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 emergency 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 shall be demonstrated through properly signed, 

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 8

(1) an emergency occurred and the permittee can 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 emission 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 under this section shall be certified as required 

by Section III (Monitoring, 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 Section 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 either on the list in Appendix I to OAC Title 252, 

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. 

Any activity to which a State or Federal applicable 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 pollutant (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 emissions 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. OPERATIONAL 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 the 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 9

permit). When an operating scenario is changed, the permittee shall record in a log at the facility 

the scenario under which it is operating. [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 emission rate of any existing emissions unit 

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required 

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or 

twenty four (24) hours for emergencies as defined 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 required above shall include a brief 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 longer applicable as a result of the change. The 

permit shield provided by this permit does not apply 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 more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized 

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated 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 opacity 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 such periods in any consecutive 24 hours. 

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7; 

(c) An emission, where the presence of uncombined 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 and immediate control of the facility and 

the immediate constriction of the fuel flow at the facility 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 standards to be exceeded, or interfere with the 

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur 

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and 

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia 

or greater under actual conditions shall be equipped 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 following standards for production and consumption of 

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation 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, trichloroethane (methyl chloroform), and bromomethane 

(Methyl Bromide). Class II substances (listed 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 refrigerant (or regulated substitute substance) in the motor vehicle air 

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart 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 refrigerated cargo, or the system used on passenger 

buses using HCFC-22 refrigerant. [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, service, repair, or disposal must comply 

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must 
MAJOR 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, repair, or disposal of appliances must be 

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply 

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply 

with leak repair requirements 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 associated with permit review 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 process 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 State, 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 provided 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 the administrative amendment process, by 
MAJOR 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 administrative permit amendment if performance tests fail 

to demonstrate that the source is operating 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 certifications or establishing whether or not a person 

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing 

shall preclude the use, including the exclusive use, of any credible evidence or information, 

relevant to whether a source would have been in compliance with applicable requirements if the 

appropriate performance or compliance test or procedure had been performed.

[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-5)

Georgia-Pacific Consumer Products 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 specific 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 approved AQD forms and submitted (hardcopy or 

electronically) every year by April 1st. Any questions concerning the form or submittal process 

should be referred to the Emission 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., Professional Engineer III

AIR QUALITY DIVISION

Enclosures
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-5)

Georgia-Pacific Consumer Products LP – Muskogee Mill

Dear Mr. Bond:

Air Quality has received the permit application for the referenced facility and completed initial 

review. This application has been determined to be a Tier II application. In accordance with 

27A O.S. 2-14-301 and 302 and OAC 252:4-7-13(c), the enclosed draft permit is now ready for 

public review. The requirements for public review of the draft permit include the following 

steps, which you must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation 

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper 

announcement) a copy of the application and draft permit at a convenient location 

(preferentially at a public location) within the county of the facility.

3. Send AQD a written affidavit of publication for the notices from Item #1 above together 

with any additional comments or requested changes, which you may have for the permit 

application within 20 days of publication.

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., Professional Engineer III

AIR QUALITY DIVISION

Enclosures
PART 70 PERMIT

AIR QUALITY DIVISION

STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 99-113-TV (M-5)

GEORGIA-PACIFIC CONSUMER PRODUCTS LP,

having complied with the requirements of the law, is hereby granted permission to operate

the Muskogee Paper Mill located at 4901 Chandler Road, Muskogee, Oklahoma, Muskogee

County, having the legal description of Section 33 & W/2 Section 34, T15N, R19EIM,

subject to standard conditions dated July 21, 2009, and specific conditions, both attached.

This permit shall March 13, 2011, except as authorized under Section VIII of the Standard 

Conditions.

______________________________

Eddie Terrill, Date

Division Director