July 2, 20 12 

Mr. Douglas Aburano 

United States Enviroru11ental Protection Agency, Region 5 

Air and Radiation Division 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Re: Proposed Escanaba Paper Company Best Available Retrofit Technology Oxides of 

Nitrogen Emission Limits 

Dear Mr. Aburano: 

Based on our meeting on June 21, 20 12, Escanaba Paper Company (EPC) is providing U.S. EPA 

Region 5 and the Michigan Department of Envirorunental Quality (DEQ) with proposed Best 

Available Retrofit Technology (BART) oxides of nitrogen (NOx) emission limits for the No. 8 and 

No. 9 Boilers at the Escanaba, Michigan pulp and paper mill. In addition to the proposed emission 

limits, EPC is providing the basis for each limit as well as a proposed method of compliance for each 

limit. 

The No. 9 Boiler at the EPC Mill is a Babcock and Wilcox (B&W) stoker grate boiler rated at 

250,000 pounds (lbs) of steam per hour and 360 million British Thermal Units (MMBtu) per hour 

(i.e., heat input). The permitted fuels for the No. 9 Boiler include woodwaste, natural gas, and paper 

cores. The No. 9 Boiler is exhausted via two stacks (i.e. a north stack and a south stack). NOx 

emission testing was most recently performed in 2007 and 2008 and was conducted on both stacks. 

EPC reviewed the individual year 2007 and 2008 NOx emission test results for the twostacks. The 

peak hourly NOx emission factor was 0.24 1 lbs NOx per million British Thennal Units (MMBtu) o f 

heat input. Applying a 25% sa fety factor to the NOx emission factor equates to a 0 .30 lbs 

NOxfMMBtu emission factor. EPC proposes 0.30 lbs NOxfMMBtu, when firing woodwaste, as the 

limit for the No. 9 Boiler. EPC believes this emission factor limit provides sufficient assurance this 

limit can reasonably be achi eved during subsequent emission test programs conducted to document 

compliance. EPC proposes to demonstrate compliance with the 0.30 lbs NOxfMMBtu emission 

factor limit based on the average of three (3) one-hour test runs when the boiler is firing wood waste at 

peak levels. Emission testing would be required using the same schedule required by Michigan DEQ 

under the State 's Title V program (i.e., emission testing is required within three years of renewal of 

the Title V permit). 

The No. 8 Boiler is a Combustion Engineering boiler. It is rated at 450,000 lbs of steam per hour 

with nominal heat ratings of 594 MMBtu/hr for oil and 560 MMBtu/hr for natura l gas. These two 

fuels are the only fuels that are permitted to be fired. The No. 8 Boiler is currently subject to 

Michigan DEQ's Rule 336.180 I which establishes average NOx ozone season emission factor limits 

of 0.40 lbs NOxfMMBtu and 0.20 lbs NOx/MMBtu for fuel oil and natural gas respectively. EPC 

File: 18.9.1 EPC Proposed BART NOx Emission Limits 

Page I of 2 

July 2. 2012 
operates a continuous emissions monitor (CEM) to demonstrate compliance with the respective 

emission limits. 

EPC is proposing to accept a NOx emission factor limit of 0.40 lbs NOxiMMBtu and to demonstrate 

compliance with this limit based on a 30 day rolling average. The 30 day rolling average would be 

applicable during days when the No. 8 Boiler is operating but would exclude days when one of the 

other Mill's steam boilers (No. 9 Boiler and No. II Boiler) or the No. 10 Recovery Furnace is not 

operating. Compliance with the 0.40 lbs NOx/MMBtu emission factor limit would generally follow 

the calculations and methodology contained in 40 CFR Part 60.40(b) (New Source Perfmmance 

Standards) as it applies to NOx emissions. 

EPC believes the proposed limits and compliance demonstrations for the No. 8 and No.9 Boilers are 

consistent with historical emissions for these two emission units as well as emission limits and 

compliance requirements that are contained in state and federal regulatory programs (i.e. Michigan 

Rule 336. 1801 and 40 CFR Part 60). In addition, EPC believes the proposed limits reflect the basic 

approach to establishing limits discussed and agreed upon by U.S. EPA Region 5, Michigan DEQ, 

and EPC. EPC appreciates the attention that both U.S. EPA Region 5 and Michigan DEQ have 

devoted to this matter. If there are any questions regarding the information presented in this letter, 

please contact me at 906-233-2929 or via e-mail at tfs5@newpagecorn.com. 

Sincerely, 

Escanaba Paper Company 

c=- ~::2~~~€?~~~~; ~'~/5Si~~~~;s~~~~ Todd Schmidt 

Environmental Manager 

cc: Robert Irvine (DEQ) 

Chris Hare (DEQ) 

File: 18.9.1 EPC Proposed BART NOx Emission Limits 

Page 2 of2 

July 2, 201 2