# Attachment H5

BART Permit Provisos

Solutia, Inc

International Paper Co- Courtland Mill

Rock-Tenn Mill Company, LLC (previously Gulf States Paper)



# Escambia Operating Company, LLC

Mobile Energy Services Company, LLC

Tronox LLC (previously Kerr McGee)PERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 2 - 

# AIR PERMIT

PERMITTEE: SOLUTIA, INC.

FACILITY NAME: SOLUTIA

LOCATION: DECATUR, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

712-0010-008 384 MMBTU/hr Riley Stoker Boiler No. 8 with Research Cottrell ESP Control (Coker No. 2)

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008PERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 3 - 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 4 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. This process including all air pollution control devices and capture systems for which this permit is issued shall be maintained and ope rated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Emission test are to be conducted for the fo llowing pollutants at in tervals not to exceed twelve (12) months following th e date of initial compliance te sting. All test reports must be submitted to the Department within 15 days of completion of testing.PERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 4 - Particulates () Carbon Monoxide ( ) Sulfur Dioxide () Nitrogen Oxides ( ) Volatile Organic Compounds ( )

11. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

12. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

13. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

14. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

15. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorousPERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 5 - emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

16. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

17. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

18. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

19. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

20. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

21. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

22. Records will be maintained of the occurr ence and duration of a ny startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable forPERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 6 - inspection and will be retained for at le ast two years following the date of each

occurrence.

23. A written report of the excess opacity emissions as defined below, shall be submitted to the Department for each six month period within 60 days following the end of the period. The reports will include the following information:

• The magnitude of excess emissions over 20% computed from six-minute averages (data recorded during peri od of opacity monitoring system breakdowns, repairs, calibration checks and zero and span adjust ments shall not be included in the data averages).

• The date and time of commencement a nd completion of each time period of excess emissions.

• The nature and cause of the excess emi ssions (if known) and the corrective action taken or preventative measures adopted.

• The date and time identifying each period during which the opacity monitoring system was inoperative (except for zero an d span checks) and the nature of the system repairs or adjustments.

• When no excess emissions have occurred and the opacity monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

24. The plume opacity in excess of the levels otherwise authorized in this Air Permit which occur as determined by the Director as a result of properly performed start-ups, shutdowns, or load changes will not be considered violations.

25. Particulate emissions from this s ource shall not exceed 0.12 lbs/MMBTU.

26. Sulfur dioxide emissions from this sour ce shall not exceed 3.57 lbs/MMBTU and 1,370.1 lb/hr.

27. Sulfur dioxide emissions from this source shall not exceed 4.0 lb/MMBTU.

28. This boiler shall be equipped with an electrostatic precipitator.

29. As an indicator of compliance with the SO 2 emission limits on Coker 2, the SO 2 emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and BTU ratings of the coal burned in these sour ces. A guaranteed analysis of each shipment of coal shall be obtained from the supplier.

30. Records of the calculated SO 2 emissions in lb/MMBTU for Coker 2 shall be maintained in a permanent form suitable for inspection for a period of at least five years. ThesePERMIT NO. 712-0010-008 Coker No. 2 Provisos

- 7 - records shall include the supporting calculatio ns, including the sulfur content and BTU ratings of the coal fired in these units (i.e., fuel certifications).

31. The opacity and particulate standards on Coke r 2 shall be indicate d by the continuous opacity monitoring system (COMS).- 8 - 1. Effective January 1, 2013, the nitrogen oxide (NOx) emissions from this unit shall not exceed 104.43 lb/hr.

2. Particulate emissions from this s ource shall not exceed 0.12 lbs/MMBTU.

3. Sulfur dioxide emissions from this sour ce shall not exceed 3.57 lbs/MMBTU and 1,370.1 lb/hr.

4. This boiler shall be equipped with an electrostatic precipitator.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date- 9 - 

# AIR PERMIT

PERMITTEE: SOLUTIA, INC.

FACILITY NAME: SOLUTIA

LOCATION: DECATUR, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

712-0010-008 384 MMBTU/hr Riley Stoker Boiler No. 8 with Research Cottrell ESP Control (Coker No. 2)

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008Solutia, Inc. Decatur, ALABAMA (PERMIT NO. 712-0010-007) Coker No. 1 Provisos

Page 10 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 4 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. This process including all air pollution control devices and capture systems for which this permit is issued shall be maintained and ope rated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 712-0010-007 Coker No. 1 Provisos

- 11 - 10. Emission test are to be conducted for the fo llowing pollutants at in tervals not to exceed twelve (12) months following th e date of initial compliance te sting. All test reports must be submitted to the Department within 15 days of completion of testing.

Particulates () Carbon Monoxide ( ) Sulfur Dioxide () Nitrogen Oxides ( ) Volatile Organic Compounds ( )

11. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

12. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

13. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

14. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the AirPERMIT NO. 712-0010-007 Coker No. 1 Provisos

- 12 - Division.

15. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

16. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

17. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

18. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

19. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

20. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

21. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.PERMIT NO. 712-0010-007 Coker No. 1 Provisos

- 13 - 22. Records will be maintained of the occurr ence and duration of a ny startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable for inspection and will be retained for at le ast two years following the date of each

occurrence.

23. A written report of the excess opacity emissions as defined below, shall be submitted to the Department for each six month period within 60 days following the end of the period. The reports will include the following information:

• The magnitude of excess emissions over 20% computed from six-minute averages (data recorded during peri od of opacity monitoring system breakdowns, repairs, calibration checks and zero and span adjust ments shall not be included in the data averages).

• The date and time of commencement a nd completion of each time period of excess emissions.

• The nature and cause of the excess emi ssions (if known) and the corrective action taken or preventative measures adopted.

• The date and time identifying each period during which the opacity monitoring system was inoperative (except for zero an d span checks) and the nature of the system repairs or adjustments.

• When no excess emissions have occurred and the opacity monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

24. The plume opacity in excess of the levels otherwise authorized in this Air Permit which occur as determined by the Director as a result of properly performed start-ups, shutdowns, or load changes will not be considered violations.

25. Particulate emissions from this s ource shall not exceed 0.12 lbs/MMBTU.

26. Sulfur dioxide emissions from this sour ce shall not exceed 3.57 lbs/MMBTU and 1,370.1 lb/hr.

27. Sulfur dioxide emissions from this source shall not exceed 4.0 lb/MMBTU.

28. This boiler shall be equipped with an electrostatic precipitator.

29. As an indicator of compliance with the SO 2 emission limits on Coker 2, the SO 2 emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and BTU ratings of the coal burned in these sour ces. A guaranteed analysis of each shipment of coal shall be obtained from the supplier.PERMIT NO. 712-0010-007 Coker No. 1 Provisos

- 14 - 30. Records of the calculated SO 2 emissions in lb/MMBTU for Coker 2 shall be maintained in a permanent form suitable for inspection for a period of at least five years. These records shall include the supporting calculatio ns, including the sulfur content and BTU ratings of the coal fired in these units (i.e., fuel certifications).

31. The opacity and particulate standards on Coke r 2 shall be indicate d by the continuous opacity monitoring system (COMS).- 15 - 1. Effective January 1, 2013, the nitrogen oxide (NOx) emissions from this unit shall not exceed 104.43 lb/hr.

2. Particulate emissions from this s ource shall not exceed 0.12 lbs/MMBTU.

3. Sulfur dioxide emissions from this sour ce shall not exceed 3.57 lbs/MMBTU and 1,370.1 lb/hr.

4. This boiler shall be equipped with an electrostatic precipitator.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date- 16 - 

# AIR PERMIT

PERMITTEE: SOLUTIA, INC.

FACILITY NAME: SOLUTIA

LOCATION: DECATUR, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

712-0010-005 290 MMBTU/HR BOILER WITH AN ELECTROSTATIC PRECIPITATOR (BOILER NO. 5)

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008Solutia, Inc. Decatur, ALABAMA (PERMIT NO. 712-0010-005) Boiler No. 5 Provisos

Page 17 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 4 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. This process including all air pollution control devices and capture systems for which this permit is issued shall be maintained and ope rated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 712-0010-005 Boiler No. 5 Provisos

- 18 - 10. Emission test are to be conducted for the follo wing pollutants at inte rvals not to exceed twelve (12) months following th e date of initial compliance te sting. All test reports must be submitted to the Department within 15 days of completion of testing.

Particulates (X ) Carbon Monoxide ( ) Sulfur Dioxide ( ) Nitrogen Oxides ( ) Volatile Organic Compounds ( )

11. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

12. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

13. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

14. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the AirPERMIT NO. 712-0010-005 Boiler No. 5 Provisos

- 19 - Division.

15. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

16. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

17. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time the road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

18. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

19. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

20. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

21. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.PERMIT NO. 712-0010-005 Boiler No. 5 Provisos

- 20 - 22. Records will be maintained of the occurr ence and duration of a ny startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable for inspection and will be retained for at le ast two years following the date of each

occurrence.

23. A written report of the excess opacity emissions as defined below, shall be submitted to the Department for each six month period within 60 days following the end of the period. The reports will include the following information:

• The magnitude of excess emissions over 20% computed from six-minute averages (data recorded during peri od of opacity monitoring system breakdowns, repairs, calibration checks and zero and span adjust ments shall not be included in the data averages).

• The date and time of commencement a nd completion of each time period of excess emissions.

• The nature and cause of the excess emi ssions (if known) and the corrective action taken or preventative measures adopted.

• The date and time identifying each period during which the opacity monitoring system was inoperative (except for zero an d span checks) and the nature of the system repairs or adjustments.

• When no excess emissions have occurred and the opacity monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

24. The plume opacity in excess of the levels otherwise authorized in this Air Permit which occur as determined by the Director as a result of properly performed start-ups, shutdowns, or load changes will not be considered violations.

25. Particulate emissions from this source shall not exceed 0.12 lbs/MMBTU and 34.8 lb/hr, measured in accordance with 40 CFR Part 60, Method 5.

26. Sulfur dioxide emissions from this s ource shall not exceed 3.9 lbs/MMBTU and 1,131 lb/hr as measured in accordance with 40 CFR Part 60, Method 6.

27. This unit is subjec t to the provisions of ADEM Admin Code R. 335-3-8-.05, “NOx Budget Trading Program”.

28. This boiler shall be equipped with an electrostatic precipitator. 29. As an indicator of compliance with the SO 2 emission limits on Boiler No. 5, the SO 2 emissions (lb/MMBTU) from each source shall be calculated from the sulfur content andPERMIT NO. 712-0010-005 Boiler No. 5 Provisos

- 21 - BTU ratings of the coal burned in these sour ces. A guaranteed analysis of each shipment of coal shall be obtained from the supplier.

30. Records of the calculated SO 2 emissions in lb/MMBTU for Boiler No. 5 shall be maintained in a permanent form suitable for in spection for a period of at least five years. These records shall include the supporting calc ulations, including the sulfur content and BTU ratings of the coal fired in th ese units (i.e., fuel certifications).- 22 - 1. Effective January 1, 2013, the sulfur dioxide (SO 2 ) emission rate from this boiler shall not exceed 1.4 lb/MMBTU and 406 lb/hr as m easured in accordance with 40 CFR Part 60, Method 6. Continuous monitoring for indica tion of compliance with these limits shall continue to be as required in Boiler No. 5 Proviso No. 29.

2. Effective January 1, 2013, the nitrogen oxide (NOx) emissions from this boiler shall not exceed 101.22 lb/hr.

3. Effective January 1, 2013, emission tests are to be conducted for sulfur dioxide at intervals not to exceed twelve (12) months. Test reports must be submitted to the Department within 15 days of completion of testing.

4. Particulate emissions from this source shall not exceed 0.12 lbs/MMBTU and 34.8 lb/hr, measured in accordance with 40 CFR Part 60, Method 5.

5. This boiler shall be equipped with an electrostatic precipitator.

6. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date- 23 - 

# AIR PERMIT

PERMITTEE: SOLUTIA, INC.

FACILITY NAME: SOLUTIA

LOCATION: DECATUR, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

712-0010-006 320 MMBTU/HR BOILER WITH AN ELECTROSTATIC PRECIPITATOR (BOILER NO. 6)

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008Solutia, Inc. Decatur, ALABAMA (PERMIT NO. 712-0010-006) PROVISOS

Page 24 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 4 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. This process including all air pollution control devices and capture systems for which this permit is issued shall be maintained and ope rated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 712-0010-006 Boiler No. 6 Provisos

- 25 - 10. Emission test are to be conducted for the fo llowing pollutants at in tervals not to exceed twelve (12) months following th e date of initial compliance te sting. All test reports must be submitted to the Department within 15 days of completion of testing.

Particulates (X) Carbon Monoxide ( ) Sulfur Dioxide ( ) Nitrogen Oxides ( ) Volatile Organic Compounds ( )

11. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

12. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

13. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

14. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the AirPERMIT NO. 712-0010-006 Boiler No. 6 Provisos

- 26 - Division.

15. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

16. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

17. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

18. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

19. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

20. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

21. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.PERMIT NO. 712-0010-006 Boiler No. 6 Provisos

- 27 - 22. Records will be maintained of the occurr ence and duration of a ny startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable for inspection and will be retained for at le ast two years following the date of each

occurrence.

23. A written report of the excess opacity emissions as defined below, shall be submitted to the Department for each six month period within 60 days following the end of the period. The reports will include the following information:

• The magnitude of excess emissions over 20% computed from six-minute averages (data recorded during peri od of opacity monitoring system breakdowns, repairs, calibration checks and zero and span adjust ments shall not be included in the data averages).

• The date and time of commencement a nd completion of each time period of excess emissions.

• The nature and cause of the excess emi ssions (if known) and the corrective action taken or preventative measures adopted.

• The date and time identifying each period during which the opacity monitoring system was inoperative (except for zero an d span checks) and the nature of the system repairs or adjustments.

• When no excess emissions have occurred and the opacity monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

24. The plume opacity in excess of the levels otherwise authorized in this Air Permit which occur as determined by the Director as a result of properly performed start-ups, shutdowns, or load changes will not be considered violations.

25. Particulate emissions from this source shall not exceed 0.12 lbs/MMBTU and 38.4 lb/hr, measured in accordance with 40 CFR Part 60, Method 5.

26. Sulfur dioxide emissions from this s ource shall not exceed 3.9 lbs/MMBTU and 1,248 lb/hr as measured in accordance with 40 CFR Part 60, Method 6.

27. This unit is subjec t to the provisions of ADEM Admin Code R. 335-3-8-.05, “NOx Budget Trading Program”.

28. This boiler shall be equipped with an electrostatic precipitator. 29. As an indicator of compliance with the SO 2 emission limits on Boilers No. 6, the SO 2 emissions (lb/MMBTU) from each source shall be calculated from the sulfur content andPERMIT NO. 712-0010-006 Boiler No. 6 Provisos

- 28 - BTU ratings of the coal burned in these sour ces. A guaranteed analysis of each shipment of coal shall be obtained from the supplier.

30. Records of the calculated SO 2 emissions in lb/MMBTU for Boiler No. 6 shall be maintained in a permanent form suitable for in spection for a period of at least five years. These records shall include the supporting calc ulations, including the sulfur content and BTU ratings of the coal fired in thes e units (i.e., fuel certifications).- 29 - 1. Effective January 1, 2013, the sulfur dioxide (SO 2 ) emission rate from this boiler shall not exceed 1.4 lb/MMBTU and 448 lb/hr as m easured in accordance with 40 CFR Part 60, Method 6. Continuous monitoring for indica tion of compliance with these limits shall continue to be as required in Boiler No. 6 Proviso No. 29.

2. Effective January 1, 2013, the nitrogen oxide (NOx) emissions from this boiler shall not exceed 109.72 lb/hr.

3. Effective January 1, 2013, emission tests are to be conducted for sulfur dioxide at intervals not to exceed twelve (12) months. Test reports must be submitted to the Department within 15 days of completion of testing.

4. Particulate emissions from this source shall not exceed 0.12 lbs/MMBTU and 38.4 lb/hr, measured in accordance with 40 CFR Part 60, Method 5.

5. This boiler shall be equipped with an electrostatic precipitator.

6. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date- 30 - 

# AIR PERMIT

PERMITTEE: SOLUTIA, INC.

FACILITY NAME: SOLUTIA

LOCATION: DECATUR, AL

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

712-0010-X015 536.1 MMBTU/HR BOILER WITH AN ELECTROSTATIC PRECIPITATOR (NO. 7 BOILER)

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008Solutia, Inc. Decatur, ALABAMA (PERMIT NO. 712-0010-X015) PROVISOS

Page 31 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 4 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. This process including all air pollution control devices and capture systems for which this permit is issued shall be maintained and ope rated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 712-0010-X015 Boiler No. 7 Provisos

- 32 - 10. Emission test are to be conducted for the fo llowing pollutants at in tervals not to exceed twelve (12) months following th e date of initial compliance te sting. All test reports must be submitted to the Department within 15 days of completion of testing.

Particulates (X ) Carbon Monoxide ( ) Sulfur Dioxide ( ) Nitrogen Oxides ( ) Volatile Organic Compounds ( )

11. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

12. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

13. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

14. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actualPERMIT NO. 712-0010-X015 Boiler No. 7 Provisos

- 33 - completion of the test, unless an extension of time is specifically approved by the Air Division.

15. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

16. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

17. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

18. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

19. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

20. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

21. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.PERMIT NO. 712-0010-X015 Boiler No. 7 Provisos

- 34 - 22. Records will be maintained of the occurr ence and duration of a ny startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable for inspection and will be retained for at le ast two years following the date of each

occurrence.

23. A written report of the excess opacity emissions, SO 2 , and NOx emissions as defined below, will be submitted to the Department for each six month pe riod within the month following the end of the period. The reports will include the following information:

• Opacity: the magnitude of excess emissions over 20% computed from six-minute

averages NOx : the magnitude of excess emissions over 0.7 lb/MMBTU computed from one-hour averages.

Note: Data recorded during periods of system breakdowns , repairs, adjustments, and calibration checks and zero and span adjustments shall not be included in any of the above data averages.

• The date and time of commencement a nd completion of each time period of excess emissions.

• The nature and cause of the excess emi ssions (if known) and the corrective action taken or preventative measures adopted.

• The date and time identifying each period during which the opacity monitoring system was inoperative (except for zero an d span checks) and the nature of the system repairs or adjustments.

• Equations used to convert SO 2 and NOx emission data as monitored to be required reporting standard (lb/MMBTU) will be included in the reports.

• When no excess emissions have occurred and the opacity monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

24. Particulate emissions from this source sh all not exceed 0.12 lbs/MMBTU and 63.33 lb/hr, measured in accordance with 40 CFR Part 60, Method 5.

25. Sulfur dioxide emissions from this s ource shall not exceed 1.17 lbs/MMBTU and 627.2 lb/hr as measured in accordance with 40 CFR Part 60, Method 6. 26. NOx emissions from this source shall not exceed 0.7 lbs/MMB TU and 375.27 lb/hr as measured in accordance with 40 CFR Part 60, Method 7 or 7E.PERMIT NO. 712-0010-X015 Boiler No. 7 Provisos

- 35 - 27. This boiler is subject to the Federal New Source Performance Standards (NSPS) as listed in 40 CFR 60, Subpart D.

28. Particulate emissions from this source shall not exceed 0.10 lbs/MMBTU as required by 40 CFR 60, Subpart D.

29. Compliance with the NOx emission limits sh all be determined by the NOx continuous emissions monitoring system required by this permit and NSPS Subpart D or Reference Methods 7 or 7E in Appendix A of 40 CFR 60.

30. This boiler may utilize Propionitrile (PN) vapor from the PN Refiner as fuel. Liquid PN may not be burned in this boiler.

31. This unit subject to the pr ovisions of ADEM Admin Code R. 335-3-8-.05, “NOx Budget Trading Program”.

32. This boiler shall be equipped with an electrostatic precipitator.- 36 - 1. Effective January 1, 2013, the sulfur dioxide (SO 2 ) emission rate from this boiler shall not exceed 0.47 lb/MMBTU and 252 lb/hr as measured with a continuous emission monitoring system.

2. Effective January 1, 2013, this boiler would m eet the required limit in Proviso No. 32 by installing a sorbent injection syst em (FSI) or comparable technology.

3. Effective January 1, 2013, the nitrogen oxide (NOx) emission rate from this boiler shall not exceed 0.36 lb/MMBTU and 193 lb/hr as measured with a continuous emission monitoring system.

4. Effective January 1, 2013, this boiler would m eet the required limit in Proviso No. 34 by installing a rotating opposed fired air sy stem (ROFA) or comparable technology.

5. Effective January 1, 2013, this boile r shall be equipped with a SO 2 continuous emissions monitoring system for determination of compliance with the SO 2 emission rate. This monitor shall meet the requirement s of 40 CFR Part 60, Appendix F.

6. Effective January 1, 2013, the continuous NOx monitoring system shall be used for determination of compliance w ith the NOx emission rate as indicated in Proviso No. 34. This monitor shall meet the requirements of 40 CFR Part 60, Appendix F.

7. Particulate emissions from this s ource shall not exceed 0.10 lbs/MMBTU.

8. This boiler shall be equipped with an electrostatic precipitator.

9. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date- 37 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X006 No. 1 Combination Boiler

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X006) No. 1 Combination Boiler Provisos

Page 38 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 707-0001-X006 No. 1 Combination Boiler Provisos

- 39 - 10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.PERMIT NO. 707-0001-X006 No. 1 Combination Boiler Provisos

- 40 - 15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to the applicab le requirements of Rule 335-3-4-. 08.

22. This source is subject to the applicable requ irements of Rule 335-3-14 for sulfur dioxide.

23. This source is subject to the applicable re quirements of Rule 335-3-4-. 01 for opacity.

24. Particulate matter emissions shall not ex ceed the limits found the Department’s Air Division Rules and Regula tions Chapter 335-3-4-. 08.PERMIT NO. 707-0001-X006 No. 1 Combination Boiler Provisos

- 41 - 25. This unit shall not emit gr eater than 0.17 gr/sdcf corre cted to 50 % excess air

26. Sulfur dioxide emissions shall not exceed 147.3 pounds per hour.

27. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may di scharge into the atmosphere from any source of emission, partic ulate of an opacity not greater than that designated as forty percent.

28. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5 or 17. Alte rnate test methods may be used provided prior approval by the Department is granted.

29. Compliance with the sulfur dioxide emission limit shall be determined in accordance with 40 CFR Chapter 1 Part 60 Appendix A Method 6. Alternate test methods may be used provided prior approval by the Department is granted.

30. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 7. Alternate test methods may be used provided prior approval by the Department is granted.

31. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

32. A particulate matter emission test shall be performed at least once per year.

33. For particulate matter and sulfur dioxide pe riodic monitoring, if any three-hour block average steam production rate is greater than 110 percent of its average value set by the required complying periodic test or a comply ing test approved by the Department, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate.

34. For particulate matter and sulfur dioxide pe riodic monitoring, if any three-hour block average wet scrubber pressure drop or liquid flow rate is less than 90 percent of its respective average value recorded at the time of a required periodic test that showed compliance or a test approved by the Department that showed compliance, the cause is to be investigated and appropriate corrective action is to be ta ken within twenty-four hours.

35. A sulfur dioxide emission test shall be performed at least once every 5 years.

36. A particulate matter emission test report shal l be submitted to the Department at least

once per year.

37. Records of all three-hour block average steam production rates shall be made and maintained on file available for inspection for at least five years.

38. Records of all three-hour block average wet scrubber pressure drop and liquid flow rates shall be made and maintained on file availa ble for inspection for at least five years.PERMIT NO. 707-0001-X006 No. 1 Combination Boiler Provisos

- 42 - 39. A sulfur dioxide emission test report shall be submitted to the Department at least once every five years.- 43 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Effective January 1, 2013, this unit sh all only be operated as follows

(a) As a standby unit that may be operated when:

i) One or more of the following units is either not operating of is in start-up or shutdown mode: the No. 2 Combination Boiler the No. 2 Recovery Furnace, the No. 3 Combination Boiler, or the No. 3 Recovery Furnace.

ii) As necessary to complete any required re gulatory emissions te sting without taking another unit off-line.

(b) As a primary operational unit, provided that:

i) The unit reduces NO x emissions to 93.15 lb/hr.

ii) Emissions testing has been conducted wh ich demonstrates compliance with the emission limit; after which yearly compliance testing will be performed for NO x and submitted to the Department.

3. This unit shall not emit gr eater than 0.17 gr/sdcf corre cted to 50 % excess air

4. Sulfur dioxide emissions shall not exceed 147.3 pounds per hour.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

6. Effective January 1, 201 3, a sulfur dioxide emissions test shall be performed at least once per calendar year.

7. Effective January 1, 2013, a sulfur dioxide emissions test report shall be submitted to the Department at least once per calendar year.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-08 PER CSS FINAL BART NO 1 COMBO BOILER X006- 44 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X006
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 1 Combination Boiler
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 45 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X003 No. 1 Lime Kiln

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X003) No. 1 Lime Kiln Provisos

Page 46 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.PERMIT NO. 707-0001-X003 No. 1 Lime Kiln Provisos

- 47 - 11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.PERMIT NO. 707-0001-X003 No. 1 Lime Kiln Provisos

- 48 - 16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to th e requirements of ADEM Admi n. Code 335-3-4-. 07 (2) (c) particulate matter from kr aft pulp mill lime kilns.

22. This source is subject to the requirem ents of ADEM Admin. C ode 335-3-4-. 01 for opacity.

23. This source is subject to th e requirements of National Emi ssion Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code 335-3-11 -.06 (38) with a compliance date of March 13, 2004. The initial performance test is to be performed within 180 days after the compliance date. A permit modification re quest and the initialPERMIT NO. 707-0001-X003 No. 1 Lime Kiln Provisos

- 49 - performance test report shall be submitted to the Department not later than 60 business days after the performance test.

24. Particulate matter emissions shall not exceed 1.0 pound per air-dried ton of pulp.

25. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may di scharge into the atmosphere from any source of emission, partic ulate of an opacity not greater than that designated as forty percent.

26. Compliance with the particulate matter emissi on limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted.

27. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate te st methods may be used provided prior approval by the Department is granted.

28. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 7 or 7e. A lternate test methods may be used provided prior approval by the Department is granted.

29. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

30. A particulate matter emission test shall be performed at least once per calendar year.

31. For particulate matter periodic monitoring, if any three-hour bl ock average lime mud flow rate is greater than 110 percent of its average value record ed at the time of a required periodic test that s howed compliance or a test a pproved by the Department that showed compliance, the mud flow rate is to be lowered until compliance is successfully demonstrated at the higher rate.

32. For particulate matter periodic monitoring, if any three-hour block average wet scrubber pressure drop or liquid flow rate is less th an 90 percent of its respective average value recorded at the time of a required periodic test that showed compliance or a test approved by the Department that showed compliance, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours.

33. A particulate matter emission test report shal l be submitted to the Department at least once per calendar year.

34. Records of all three-hour block average lime mud flow rates shall be made and maintained on file available for inspection for at least five years.

35. This source is subject to th e requirements of ADEM Admin. Code 335-3-5-. 04 (6) total reduced sulfur from kraft pulp mill lime kilns.PERMIT NO. 707-0001-X003 No. 1 Lime Kiln Provisos

- 50 - 36. Total reduced sulfur emissions shall not exceed 20 parts per million at 10 percent oxygen averaged over discrete 12 hour periods. If an owner or operator demonstrates to the satisfaction of the Director that emissions in excess of the levels otherwise authorized in this regulation occur as a resu lt of properly performed startu ps, shutdowns or unavoidable malfunctions these emissions will not constitute a violation.

37. Compliance with the total reduced sulfur emission limit shall be determined in accordance with the continuous emission m onitor, 40 CFR Part 60 Method 16, 16A or 16B. Alternate test methods may be used provided prior approval by the Department is granted

38. A total reduced sulfur continuous emission monitor shall be in stalled, calibrated, maintained and operated in accordance with 40 CFR §60.284, except that monitoring spans may be approved by the Director.PERMIT NO. 707-0001-X003 No. 1 Lime Kiln BART Provisos

- 51 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate matter emissions shall not exceed 1.0 pound per air-dried ton of pulp.

3. Effective January 1, 2013, sulfur dioxid e emissions shall not exceed 0.10 lb/hr.

4. Effective January 1, 2013, nitrogen oxid e emissions shall not exceed 3.50 lb/hr.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

6. Effective January 1, 2013, a sulfur dioxide emi ssion test shall be performed at least once per calendar year.

7. Effective January 1, 2013, a nitrogen oxide emission test shall be pe rformed at least once per calendar year.

8. Effective January 1, 2013, a sulfur dioxide em ission test report shall be submitted to the Department at least once per calendar year.

9. Effective January 1, 2013, a nitrogen oxide emission test report shall be submitted to the Department at least once per calendar year.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FINAL BART NO 1 LIME KILN X003- 52 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X003
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 1 Lime Kiln
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 53 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X015 No. 2 Combination Boiler

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X015) No. 2 Combination Boiler Provisos

Page 54 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipmen t in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.PERMIT NO. 707-0001-X015 No. 2 Combination Boiler Provisos

- 55 - 11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.PERMIT NO. 707-0001-X015 No. 2 Combination Boiler Provisos

- 56 - 16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to the applicable requirements of Rule 335-3-10-. 02 (1) and (2) and Rule 335-3-14-. 04.

22. Particulate emissions shall not exceed 0.10 pounds per million Btu heat input

23. Sulfur dioxide emissions shall not exceed the more stringent of 1.20 pounds per million Btu derived from solid fossil fuel or so lid fossil fuel and wo od waste and 65.50 pounds per hour.

24. Sulfur dioxide emissions shall not exceed 280.70 tons per year rolling twelve-month

average.PERMIT NO. 707-0001-X015 No. 2 Combination Boiler Provisos

- 57 - 25. Nitrogen oxide emissions shall not exceed 0.7 pounds per million Btu heat input.

26. This source shall not exceed a ratio of 50 percent, fossil fuel to bark heat input each calendar year.

27. Opacity shall not be greater than 20 percent except for one six-minute period per hour of not more than 27 percent.

28. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted.

29. Compliance with the sulfur dioxide pound per million Btu emission limit and the tons per year limit shall be determined by th e continuous emission monitoring system.

30. Compliance with the sulfur dioxide pound pe r hour limit shall be determined in accordance with 40 CFR Part 60 Method 6. Altern ate test methods may be used provided prior approval by the Department is granted.

31. Compliance with the nitrogen oxide limit shall be determined in accordance with the 40 CFR Part 60 Method 7e. Alternate test methods may be used provided prior approval by the Department is granted.

32. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

33. A particulate matter emission test shall be performed at least once per year.

34. For particulate matter and nitrogen oxide periodic monitoring, if any three-hour block average steam production rate is greater than 110 percent of its average value set by the required complying periodic test or a comply ing test approved by the Department, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate.

35. For particulate matter and opacity periodic monitoring, if the average of any ten consecutive six-minute opacity averages exceeds 15 percent the cause is to be investigated and appropriate co rrective action is to be taken.

36. A continuous emission monitoring system for th e measurement of sulf ur dioxide shall be installed, calibrated, operated and maintained.

37. A nitrogen oxide emission test shall be pe rformed at least once every 5 years.

38. The fossil fuel to bark ratio shall be monito red and an annual ratio shall be calculated and recorded.

39. A continuous emission monitoring system for the measurement of opacity shall be installed, operated and maintained.PERMIT NO. 707-0001-X015 No. 2 Combination Boiler Provisos

- 58 - 40. A particulate matter emission test report shal l be submitted to the Department at least

once per year.

41. Records of all three-hour block average steam production rates shall be made and maintained on file available for inspection for at least five years.

42. All six-minute average opacities are to be r ecorded and maintained on file available for inspection for at least five years.

43. A report of excess opacity emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information:

(a) The magnitude of emissions greater than 20 percent computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adju stments shall not be included in the data averages).

(b) The date and time of commencement and completion of each time period of excess emissions.

(c) The nature and cause of the excess em issions (if known) and the corrective action taken or preventative measures adopted.

(d) The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the natu re of the system repairs or adjustments.

(e) When no excess emissions have occurr ed and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

44. A nitrogen oxide emission test report shall be submitted to the Department at least once every five years.

45. The fossil fuel to bark ratio for each calenda r year shall be recorded and maintained on file available for inspection for at least five years.

46. Records of the emission unit’s running twel ve-month average tons of sulfur dioxide emissions shall be made using continuous monitoring system data. Any exceedance of the twelve-month limit shall be reported to the Department within five days of its occurrence (i.e., within five days of the end of the mont h that completes any twelvemonth period). The records shall be maintain ed on file available fo r review for a period of at least two yearsPERMIT NO. 707-0001-X015 No. 2 Combination Boiler Provisos

- 59 - 47. A report of excess sulfur dioxide emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information:

(a) The magnitude of emissions greater than 65.5 pounds per hour computed on a three-hour rolling average (data r ecorded during peri ods of monitor breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages).

(b) The date and time of commencement and completion of each time period of excess emissions.

(c) The nature and cause of the excess em issions (if known) and the corrective action taken or preventative measures adopted.

(d) The date and time identifying each pe riod during which the monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments.

(e) When no excess emissions have occurred and the monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report.PERMIT NO. 707-0001-X015 No. 2 Combination Boiler BART Provisos

- 60 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate emissions shall not exceed 0.10 pounds per million Btu heat input.

3. Sulfur dioxide emissions shall not exceed the more stringent of 1.20 pounds per million Btu derived from solid fossil fuel or so lid fossil fuel and wo od waste and 65.50 pounds per hour.

4. Sulfur dioxide emissions shall not exceed 280.70 tons per year rolling twelve-month

average.

5. Nitrogen oxide emissions shall not exceed 0.7 pounds per million Btu heat input.

6. Effective January 1, 2013, nitrogen oxide emissions shall not exceed 338.13 lb/hr.

7. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

8. Effective January 1, 2013, a nitrogen oxide emi ssions test shall be performed at least once per calendar year.

9. Effective January 1, 2013, a nitrogen oxide emissions test report shall be submitted to the Department at least once per calendar year.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FINAL BART NO 2 COMBO BOILER X015- 61 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X015
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 2 Combination Boiler
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 62 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X013 No. 2 Lime Kiln

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X013) No. 2 Lime Kiln Provisos

Page 63 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.PERMIT NO. 707-0001-X013 No. 2 Lime Kiln Provisos

- 64 - 11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.PERMIT NO. 707-0001-X013 No. 2 Lime Kiln Provisos

- 65 - 16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time the road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to federal New S ource Performance Standards 40 CFR 60 Subpart A and Subpart BB.

22. This Source is subject to the requiremen ts of ADEM Admin. Code 335-3-14-. 04 (9).

23. This source is subject to the requirem ents of ADEM Admin. C ode 335-3-4-. 01 for opacity.PERMIT NO. 707-0001-X013 No. 2 Lime Kiln Provisos

- 66 - 24. This source is subject to th e requirements of National Emi ssion Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code 335- 3-11-. 06 (38) with a compliance date of March 13, 2004. The initial performance test is to be performed within 180 days after the compliance date. A permit modification re quest and the initial performance test report shall be submitted to the Department not later than 60 business days after the performance test.

25. Particulate emissions shall not ex ceed 0.067 gr/sdcf at 10 percent oxygen.

26. Total reduced sulfur shall not exceed 8 parts per million at 10 percent oxygen.

27. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may di scharge into the atmosphere from any source of emission, partic ulate of an opacity not greater than that designated as forty percent.

28. Compliance with the particulate matter emissi on limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted.

29. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate te st methods may be used provided prior approval by the Department is granted.

30. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 7 or 7e. A lternate test methods may be used provided prior approval by the Department is granted.

31. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

32. A particulate matter emission test shall be performed at least once per year.

33. For particulate matter periodic monitoring, if any three-hour bl ock average lime mud flow rate is greater than 110 percent of its average value set by th e required complying periodic test or a complying test approved by the Department , the feed rate is to be lowered until compliance is successfu lly demonstrated at the higher rate.

34. For particulate matter periodic monitoring, if any three-hour block average wet scrubber pressure drop or liquid flow rate is less th an 90 percent of its respective average value recorded at the time of a required periodic test that showed compliance or a test approved by the Department that showed compliance, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours.

35. A total reduced sulfur continuous emission monitor shall be in stalled, calibrated, maintained and operated in accordance with 40 CFR §60.284.PERMIT NO. 707-0001-X013 No. 2 Lime Kiln Provisos

- 67 - 36. A particulate matter emission test report shal l be submitted to the Department at least

once per year.

37. A report of excess total reduced sulfur emissions, as defined below, will be submitted to the Department for each calendar quarter w ithin the month following the end of the quarter. The reports will incl ude the following information:

a. The magnitude of excess emissions greater than 8 parts per million adjusted to 10 percent oxygen computed from twelve hour averages (data recorded during periods of total reduced sulfur emission monitori ng system breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in th e data averages).

b. The date and time of commencement and co mpletion of each time period of excess emissions.

c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted.

d. The date and time identifying each period during which the total reduced sulfur emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments.

e. When no excess emissions have occurred and the total reduced sulfur emission monitoring system was not i noperative or did not require repairs or adjustments, such information will be stated in the report.

38. Records of all three-hour block average lime mud flow rates shall be made and maintained on file available for inspection for at least five years.

39. Records of all three-hour block average wet sc rubber pressure drops and liquid flow rates shall be made and maintained on file available for inspection for at least five years.PERMIT NO. 707-0001-X013 No. 2 Lime Kiln BART Provisos

- 68 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate emissions shall not ex ceed 0.067 gr/sdcf at 10 percent oxygen.

3. Total reduced sulfur shall not exceed 8 parts per million at 10 percent oxygen.

4. Effective January 1, 2013, sulfur dioxid e emissions shall not exceed 0.23 lb/hr.

5. Effective January 1, 2013, nitrogen oxide emissions shall not exceed 19.40 lb/hr.

6. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

7. Effective January 1, 2013, a sulfur dioxide emi ssion test shall be performed at least once per calendar year.

8. Effective January 1, 2013, a nitrogen oxide emission test shall be pe rformed at least once per calendar year.

9. Effective January 1, 2013, a sulfur dioxide em ission test report shall be submitted to the Department at least once per calendar year.

10. Effective January 1, 2013, a nitrogen oxide emission test report shall be submitted to the Department at least once per calendar year.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FINAL BART NO 2 LIME KILN X013- 69 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X013
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 2 Lime Kiln
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 70 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X010 No. 2 Recovery Furnace

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X010) No. 2 Recovery Furnace Provisos

Page 71 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace Provisos

- 72 - 11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace Provisos

- 73 - 16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to th e applicable requirements of Rule 335-3-10-. 02 (1) and (28) New Source Performance Standards Subpart BB for kraft pulp mills and Rule 335-3-14.

22. This source is subject to th e requirements of National Emi ssion Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code 335- 3-11-. 06 (38) with a compliance date of March 13, 2004. The initial performance test is to be performed within 180 days after the compliance date. A permit modification re quest and the initial performance test report shall be submitted to the Department not later than 60 business days after the performance test.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace Provisos

- 74 - 23. Particulate matter emissions shall not exceed the more stringent of 0.044 grains per SDCF at 8 % oxygen and 67 pounds per hour.

24. Total reduced sulfur emissions shall not exceed the more stringent of 5 parts per million by volume at 8% oxygen and 6.8 pounds per hour.

25. Sulfur dioxide emissions shall not exceed 432 pounds per hour.

26. Nitrogen oxide emissions shall not exceed 152 pounds per hour.

27. Volatile organic compounds shall not exceed 121 pounds per hour.

28. Carbon monoxide emissions sh all not exceed 415 pounds per hour.

29. Opacity shall not exhibit 35 percent or greater.

30. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted.

31. Compliance with the total reduced sulfur emission limit shall be determined in accordance with 40 CFR Part 60 Method 16, 16A or 16B. Alternate test methods may be used provided prior approval by the Department is granted.

32. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate te st methods may be used provided prior approval by the Department is granted.

33. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 7 or 7e. A lternate test methods may be used provided prior approval by the Department is granted.

34. Compliance with the volatile organic com pound emission limit shall be determined in accordance with the 40 CFR Part 60 Method 25, 25A or 25B. Alternate test methods may be used provided prior approv al by the Department is granted.

35. Compliance with the carbon monoxide emission limit shall be determ ined in accordance with the 40 CFR Part 60 Method 10. Alternat e test methods may be used provided prior approval by the Department is granted.

36. Compliance with the opacity limit shall be de termined in accordance with 40 CFR Part 60 Appendix A Method 9. Alternate test met hods may be used provided prior approval by the Department is granted.

37. A particulate matter emission test shall be performed at least once per year.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace Provisos

- 75 - 38. For particulate matter and opacity periodic monitoring, if the average of any ten consecutive six-minute opacity averages exceeds 20 percent the cause is to be investigated and appropriate co rrective action is to be taken.

39. For particulate matter, sulfur dioxide, ni trogen oxide, volatile organic compounds and carbon monoxide periodic monitoring, if any three-hour block average liquor firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Depart ment, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate.

40. A continuous emission monitoring system for the measurement of total reduced sulfur and oxygen shall be installed, operated and maintained.

41. A continuous emission monitoring system for the measurement of opacity shall be installed, operated and maintained.

42. A sulfur dioxide emission test shall be pe rformed at least once every five years.

43. A nitrogen oxide emission test shall be perf ormed at least once every five years.

44. A carbon monoxide emission test shall be perf ormed at least once every five years.

45. A volatile organic compound emission test sha ll be performed at least once every five

years.

46. A particulate matter emission test report shal l be submitted to the Department at least

once per year.

47. Records of all six-minute average opacities shall be made and maintained on file available for inspection for a period of five years.

48. Records of all three-ho ur block average liquor-firing rates shall be made and maintained on file available for inspecti on for at least five years.

49. A report of excess total reduced sulfur emissions, as defined below, will be submitted to the Department for each calendar quarter w ithin the month following the end of the quarter. The reports will incl ude the following information:

a. The magnitude of excess emissions greater than 5 parts per million adjusted to 8 percent oxygen computed from twelve hour averages (data recorded during periods of total reduced sulfur emissi on monitoring system breakdowns, repairs, calibration checks and zero and span adjustme nts shall not be included in the data averages).

b. The date and time of commencement and co mpletion of each time period of excess emissions.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace Provisos

- 76 - c. The nature and cause of the excess emissions (if known) and the co rrective action taken or preventative measures adopted.

d. The date and time identifying each period during which the total reduced sulfur emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments.

e. When no excess emissions have occurred and the total reduced sulfur emission monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

50. A report of excess opacity emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information:

a. The magnitude of emissions 35 percent and greater computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adjustme nts shall not be included in the data averages).

b. The date and time of commencement and co mpletion of each time period of excess emissions.

c. The nature and cause of the excess emissions (if known) and the co rrective action taken or preventative measures adopted.

d. The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments.

e. When no excess emissions have occurred and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report.

51. A sulfur dioxide emission test report shall be submitted to the Department at least every five years. Effective January 1, 2013, a sulfur dioxide emission test shall be submitted to the Department at least once per calendar year.

52. A nitrogen oxide emission test report shall be submitted to the Department at least every five years. Effective January 1, 2013, a nitrogen oxide emission test shall be submitted to the Department at least once per calendar year.

53. A volatile organic compound emission test report shall be submitted to the Department at least every five years.

54. A carbon monoxide emission test report shall be submitted to the Department at least every five years.PERMIT NO. 707-0001-X010 No. 2 Recovery Furnace BART Provisos

- 77 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate matter emissions shall not exceed the more stringent of 0.044 grains per SDCF at 8 % oxygen and 67 pounds per hour.

3. Total reduced sulfur emissions shall not exceed the more stringent of 5 parts per million by volume at 8% oxygen and 6.8 pounds per hour.

4. Sulfur dioxide emissions shall not exceed 432 pounds per hour.

5. Nitrogen oxide emissions shall not exceed 152 pounds per hour.

6. Volatile organic compounds shall not exceed 121 pounds per hour.

7. Carbon monoxide emissions sh all not exceed 415 pounds per hour.

8. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

9. Effective January 1, 2013, a sulfur dioxide emissi on test shall be performed at least once per calendar year.

10. Effective January 1, 2013, a nitrogen oxide emission test shall be perf ormed at least once per calendar year.

11. Effective January 1, 2013, a carbon monoxide emi ssion test shall be performed at least once per calendar year.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FI NAL BART NO 2 RECOVERY FURNACE X010- 78 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X010
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 2 Recovery Furnace
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 79 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X011 No. 2 Smelt Tank

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X011)

No. 2 Smelt Tank Provisos

Page 80 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.

10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.PERMIT NO. 707-0001-X011 No. 2 Smelt Tank Provisos

- 81 - 11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.

15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.PERMIT NO. 707-0001-X011 No. 2 Smelt Tank Provisos

- 82 - 16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to th e applicable requirements of Rule 335-3-10-. 02 (1) and (28) New Source Performance Standards Subpart BB for kraft pulp mills and Rule 335-3-14.

22. This source is subject to the requirem ents of ADEM Admin. C ode 335-3-4-. 01 for opacity.

23. This source is subject to th e requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code 335- 3-11-. 06 (38) with a compliance date of March 13, 2004. The initial performance test is to be performed within 180 days after the compliance date. A permit modification re quest and the initialPERMIT NO. 707-0001-X011 No. 2 Smelt Tank Provisos

- 83 - performance test report shall be submitted to the Department not later than 60 business days after the performance test.

24. Particulate matter emissions shall not ex ceed 0.2 pounds per ton of black liquor solids (dry weight).

25. Total reduced sulfur emissions shall not exceed 0.033 pounds per ton of black liquor solids.

26. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may di scharge into the atmosphere from any source of emission, partic ulate of an opacity not greater than that designated as forty percent.

27. Compliance with the particulate matter emissi on limit shall be determined in accordance with the 40 CFR Part 60 Met hod 5. Alternate test methods may be used provided prior approval by the Department is granted.

28. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate test methods may be used provided prior approval by the Department is granted

29. Compliance with the total reduced sulfur emission limit shall be determined in accordance with 40 CFR Part 60 Method 16, 16A or 16B. Alternate test methods may be used provided prior approval by the Department is granted.

30. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

31. A particulate matter emission test shall be performed at least once per year.

32. A total reduced sulfur emission test shall be performed within 90 days of permit issuance or re-issuance to certify compliance a nd set periodic monitoring parameters.

33. For particulate matter and total reduced sulf ur periodic monitori ng, if any three-hour block average liquor firing rate is greater than 110 percent of its value set by the required complying periodic test or a complying test approved by the Department, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate.

34. For particulate matter periodic monitoring, if any three-hour block average total liquid flow to the scrubber is less th an 90 percent of its respec tive average value set by the required complying periodic test or a complyi ng test approved by the Department or if fan ampere readings indicate the fan is not ope rating, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours.

35. A particulate matter emission test report shal l be submitted to the Department at least

once per year.PERMIT NO. 707-0001-X011 No. 2 Smelt Tank Provisos

- 84 - 36. A total reduced sulfur emission test report sh all be submitted to the Department at least once every five years.

37. Records of all three-ho ur block average liquor firing rate s shall be made and maintained on file available for inspecti on for at least five years.

38. Records of all three- hour block average wet scrubber liquid flow rates and hourly fan ampere readings shall be made and maintained on file available for inspection for at least five years.PERMIT NO. 707-0001-X011 No. 2 Smelt Tank BART Provisos

- 85 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate matter emissions shall not ex ceed 0.2 pounds per ton of black liquor solids (dry weight).

3. Total reduced sulfur emissions shall not exceed 0.033 pounds per ton of black liquor solids.

4. Effective January 1, 2013, sulfur dioxid e emissions shall not exceed 0.20 lb/hr.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

6. Effective January 1, 2013, a sulfur dioxide emissi on test shall be performed at least once per calendar year

7. Effective January 1, 2013, a sulfur dioxide em ission test report shall be submitted to the Department at least once per calendar year

8.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FINAL BART NO 2 SMELT X011- 86 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X011
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit No. 2 Smelt Tank
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART- 87 - 

# AIR PERMIT

PERMITTEE: International Paper

FACILITY NAME: Courtland Mill

LOCATION: Courtland Alabama

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

707-0001-X007 Package Boiler

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: February 5, 2008International Paper, Courtland Mill Courtland, ALABAMA (PERMIT NO. 707-0001-X007) Package Boiler Provisos

Page 88 of 122 1. This permit is issued on the basis of Rule s and Regulations existing on the date of issuance. In the event additional Rules and Re gulations are adopted, it shall be the permit holder's responsibility to co mply with such rules.

2. This permit is not transferable. Upon sale or legal transfer, the new owner or operator must apply for a permit within 30 days.

3. A new permit application must be made fo r new sources, replacements, alterations or design changes which may result in the issuance of , or an increase in the issuance of, air contaminants, or the use of which may elimin ate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided w ith sampling ports, ladders, platforms, and other safety equipment to facilitate testi ng performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air po llution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment in such a manner as to cause increased emission of air contaminants for a period greater than 1 hour , the person responsible for such equipment shall notify the Air Division within an additional 24 hours and provide a statement giving all pertinent facts, including th e duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a ma nner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. This permit expires and the ap plication is cancelled if c onstruction has not begun within 24 months of the date of issuance of the permit.

9. On completion of construction of the device for which this permit is issued, notification of the fact is to be given to the Chief of the Air Division. Author ization to operate the unit must be received from the Chief of the Air Division. Failure to notify the Chief of the Air Division of completion of construction and/or oper ation without authorization could result in revoca tion of this permit.PERMIT NO. 707-0001-X007 Package Boiler Provisos

- 89 - 10. Submittal of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and re gulations. The Department may require stack emission testing at any time.

11. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution co ntrol rules and regulati ons are not violated.

12. Nothing in this permit or conditions thereto sh all negate any authority granted to the Air Division pursuant to the Alabama Environmenta l Management Act or regulations issued thereunder.

13. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitt ed as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(a) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing co mpany that will conduct the tests.

(b) A complete description of each sampling tr ain to be used, including type of media used in determining gas stream component s, type of probe lining, type of filter media, and probe cleaning method and solv ent to be used (if test procedure requires probe cleaning).

(c) A description of the process( es) to be tested, including the feed rate, any operating parameter used to control or influen ce the operations, and the rated capacity.

(d) A sketch or sketches showing sampling poi nt locations and their relative positions to the nearest upstream and downs tream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. The necessity for such a meeting and the require d attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

14. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determin ation by the Alabama Department of Environmental Management that these m easures are technical ly and economically feasible.PERMIT NO. 707-0001-X007 Package Boiler Provisos

- 90 - 15. Precautions shall be taken to prevent fugitive dust emanating from plant roads, grounds, stockpiles, screens, dryers, hoppers, ductwork, etc.

16. Plant or haul roads and grounds will be maintained in the following manner so that dust will not become airborne. A minimum of one, or a combination, of the following methods shall be utilized to minimize airborne dust from plant or haul roads and grounds:

(a) by the application of water any time the su rface of the road is sufficiently dry to allow the creation of dust emissions by the act of wind or vehicular traffic;

(b) by reducing the speed of vehicular traffi c to a point below that at which dust emissions are created;

(c) by paving;

(d) by the application of binders to the road surface at any time th e road surface is found to allow the creation of dust emissions;

Should one, or a combination, of the above me thods fail to adequately reduce airborne dust from plant or haul roads and grounds, a lternative methods shall be employed, either exclusively or in combination with one or all of the above control techniques, so that dust will not become airborne. Alternative me thods shall be approved by the Department prior to utilization.

17. This process shall be operated at all times in a manner so as to minimize the emission of air contaminants. Procedures for ensuring that the process is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

18. Precautions shall be taken by the permittee and its personnel to ensure that no person shall ignite, cause to be ignited, permit to be ignited, or maintain any open fire in such a manner as to cause the Department’s rules a nd regulations applicable to open burning to be violated.

19. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit w ould have required halting or reducing the permitted activity.

20. The issuance of this permit does not conve y any property rights of any sort, or any exclusive privilege.

21. This source is subject to the applicable requirements of Rule 335-3-10-. 02 (2 )(b) or Rule 335-3-14-. 04.

22. This source is subject to the applicable re quirements of Rule 335-3-4-. 01 for opacity.

23. This source is subject to the applicable requirements of Rule 335-3-8-. 05 the Nitrogen Oxide Budget Trading Program. The initia l NOx budget permit shall become effective May 31, 2004 per Rule 335-3-8-. 07.PERMIT NO. 707-0001-X007 Package Boiler Provisos

- 91 - 24. Particulate matter emissions shall not exceed 0.10 pounds per million Btu.

25. Nitrogen oxide emissions shall not exceed 0.20 pounds per million Btu.

26. This boiler shall only be fired with natural gas.

27. This emission source is limited to firing no more than 1,200 million cubic feet of natural gas in any rolling twelve-month period.

28. The amount of natural gas fired sh all be monitored and recorded.

29. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may di scharge into the atmosphere from any source of emission, partic ulate of an opacity not greater than that designated as forty percent.

30. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted.

31. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate te st methods may be used provided prior approval by the Department is granted.

32. Compliance with the nitrogen oxide emission limit shall be determined in accordance with 40 CFR Chapter 1 Part 60 Appendix A Met hod 7 or 7E. Alternate test methods may be used provided prior approval by the Department is granted.

33. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60 Method 9. Alternate test methods ma y be used provided prior approval by the Department is granted.

34. A continuous emission monitoring system for the measurement of nitrogen oxides shall be installed, calibrated, opera ted and maintained per the re quirements of Rule 335-3-8- .12 for the ozone season each year (May fi rst through September thirtieth). The remainder of each year, the monitor shall be operated and maintained in accordance with the requirements of 40 CFR Part 60 Appendix B Specification 2.

35. For nitrogen oxide periodic monitoring, if any three-hour block average emission rate exceeds 0.15 pounds per million Btu the cause is to be investigated and appropriate corrective action is to be ta ken within twenty-four hours.

36. All three-hour block nitrogen oxide emission rates shall be recorded and maintained on file available for inspection for at least five years.

37. The 1,200 million cubic feet of natural gas fire d in any rolling twelve-month period shall be recorded and maintained on file availabl e for inspection for at least five years.PERMIT NO. 707-0001-X007 Package Boiler Provisos

- 92 - 38. The nitrogen oxide budget prog ram recordkeeping and reporting shall be in accordance with Rule 335-3-8-.12.PERMIT NO. 707-0001-X007 Package Boiler BART Provisos

- 93 - 1. This source is subject to th e applicable requirements of 40 CFR Part 51, Subpart P and Appendix Y.

2. Particulate matter emissions shall not exceed 0.10 pounds per million Btu.

3. Nitrogen oxide emissions shall not exceed 0.20 pounds per million Btu.

4. Effective January 1, 2013, Sulfur Dioxide emissions shall not exceed 1.80 pounds per million Btu.

5. The limitations established under BART (Best Available Retrofit Technology) may be changed through the NSR (New Source Review ) permit process which should include a visibility analysis prior to the modification.

February 5, 2008 Date

File ID: 2702 707-0001 079 02-05-2008 PER CSS FINAL BART PACKAGE BOILER X007

### Table of Contents

- 94 - 

### CHECKLIST FOR ISSUAN CE OF AIR PERMIT

Permit Number: 707-0001-X007
Company: International Paper, Courtland Mill

Location: Courtland, Alabama
Description of Permit Unit Package Boiler
Pollutant Type:

Particulates 01 Total Reduced Sulfur 06 Lead 11 Sulfur Oxides 02 Asbestos 07 Mercury 12 Carbon Monoxide 03 Beryllium 08 Benzene 13 Hydrocarbons 04 Chlorine 09 Nitrogen Oxides 05 Hydrogen Sulfide 10 Pollutant Type Expected Emissions

(lbs/hr) Method of Estimate Uncontrolled Emissions

(lbs/hr) Controlled Emissions

(lbs/hr) Allowable Emissions

(lbs/hr)

Operating Hours per year: 8760

Provisos: See Attached

Mail to: Mr. Russell Foulke Environmental Manager International Paper P. O. Box 189 Courtland, Alabama 35618 Engineer:

Date: C. Scott Sanders
February 5, 2008

Type: PSD SMS NAME MOD X TEMP OTHE BART
Source: NSPS NESHAP SIP X OTHER: BART

### Table of Contents

- 95 - 

# MAJOR SOURCE OPERATING PERMIT

PERMITTEE: Rock-Tenn Mill Company, LLC

FACILITY NAME: Rock-Tenn Mill Company, LLC

FACILITY/PERMIT NO.: 105-0001

LOCATION: Demopolis, AL

In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of 1971, as amended, Ala. Code 1975, §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code 1975, §§22-22A-1 to 22-22A-15, (1997 Rplc. Vol. and 2006 Cum. Supp.) and rules and regulations adopted thereunder, and subject further to the conditions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

Pursuant to the Clean Air Act of 1990 , all conditions of this permit are federally enforceable by EPA, the Alabama Department of Environmental Management, and citizens in general. Those provisions which are not required under the Clean Air Act of 1990 are considered to be state permit provisions and are not federally enforceable by EPA and citizens in general. Those provisions are contained in separate sections of this permit.

Issuance Date: January 1, 2004

Mod. Date: July 13, 2007

Expiration Date: December 31, 2008

Alabama Department of Environmental Management

### Table of Contents

- 96 - 

### Summary Page for No. 2 Power Boiler

Permitted Operating Schedule: 24 Hrs/day x 7 Days/week x 52 Weeks/yr = 8760 Hrs/yr

Emission limitations:

Emission Point # Description Pollutant Emission limit Regulation Z007 No. 2 Power Boiler Particulate matter 1. Subject to ADEM Admin. Code R 335- 3-4-.03 (0.12 pounds per million Btu).

2. Shall not exceed 2.36 pounds per hour. Rule 335-3-4-.03 and Rule 335-3-14-.04

Z007 No. 2 Power Boiler Sulfur dioxide The fuel oil sulfur content shall not exceed 0.5 percent. Rule 335-3-14-.04

Z007 No. 2 Power Boiler Opacity Shall not exceed 20 percent with one sixminute period up to 40 percent in any one hour period Rule 335-3-4-.01

### Table of Contents

- 97 - 

### No. 2 Power Boiler Federally Enforceable Provisos Regulations

1. Applicability
1. This source is subject to the applicable requirements of ADEM Admin. Code R. 335-3-16-.03, “Major Source Operating Permits”. Rule 335-3-16-.03

2. This source is subject to the requirements of ADEM Admin. Code 335-3-4-.03 for particulate matter fr om Fuel Burning Equipment. Rule 335-3-4-.03

3. This source is subject to the requirements of ADEM Admin. Code 335-3-14-.04 (9) for particulate matter and sulfur dioxide. Rule 335-3-14-.04 (9)

4. This source is subject to the requirements of ADEM Admin. Code 335-3-4-.01 Visible Emissions. Rule 335-3-4-.01

2. Emission Standards
1. Particulate matter emissions are limited to 0.12 pounds per million Btu not to exceed 2.36 pounds per hour. Rule R 335-3-4-.03

2. The sulfur content of the fuel oil fire d shall not exceed 0.5 percent. Rule 335-3-14-.04

3. Visible emissions shall not be greater than 20% opacity, as determined by six (6) minute aver ages, except during one six (6) minute period in any sixty (60) minute period, an opacity not greater than that designated as forty percent (40%) may be discharged to the atmosphere. Rule 335-3-4-.01

4. This unit shall not fire more than 6,354,140 gallons of oil in any 12-month period. Rule 335-3-14

3. Compliance and Performance Test Methods and Procedures
1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Rule 335-3-14-.02

2. Compliance with the fuel oil sulfur content limit shall be determined by monitoring and record keeping. Rule 335-3-14-.02

3. Compliance with the Opacity limit shall be determined by 40 CFR Chapter 1 Appendix A Reference Method 9. Rule 335-3-14-.04

4. Emission Monitoring
1. A particulate matter emission test shall be performed at least once every five years. Rule 335-3-14-.02

2. For particulate matte r and opacity periodic monitoring, the steam production rate is to be checked at least once per sh ift. If it is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate. Rule 335-3-16-.05

### Table of Contents

- 98 - 3. For sulfur dioxide periodic mon itoring obtain fuel receipts from the fuel oil supplier that certify sulfur content in fuel for every load received by the mill. Rule 335-3-14-.02

5. Recordkeeping and Reporting Requirements
1. A particulate matter emission test report shall be submitted to the Department at least once every five years. Rule 335-3-14-.02

2. At least once per shift the steam producti on rate shall be reco rded. Rule 335-3-14-.02
3. Fuel receipts from the fuel oil supplier that certify sulfur content in fuel for every load received by the mill shall be maintained on site available for inspection for at least five years. Rule 335-3-14-.02

4. Records of the amount of fuel oil fired shall be maintained on site and be available for inspecti on for at least five years. Rule 335-3-14-.02

### Table of Contents

- 99 - 

# ADEM

ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT G
E M
I S S I S S



# MAJOR SOURCE OPERATING PERMIT

Permitee: Escambia Operating Company, LLC

Facility Name: Big Escambia Creek Gas Production, Treating and Processing Facility



### Facility No.: 502-0007



### Location: Sec. 4, T1N, R7E, Escambia County, Alabama

In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 20 05 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2005 Cum. Supp.), and rules and regulations adopted thereunder, and subject further to the conditions set forth in this permit, the Permittee is hereby authorized to construct, install and use the equipment, device or other article described above.

Pursuant to the Clean Air Act of 1990 , all conditions of this permit are federally enforceable by EPA, the Alabama Department of Environmental Management, and c itizens in general. Those provisions which are not required under the Clean Air Act of 1990 are considered to be state permit provisions and are not federally enforceable by EPA and citizens in general. Those provisi ons are contained in separate sections of this permit.



### Issuance Date: July 6, 2006

Modification Date December 10, 2007

Expiration Date: January 7, 2011

Alabama Department of Environmental Management- 100 - 

### Summary Page for Sulfur Recov ery Unit and Thermal Oxidizer

Permitted Operating Schedule : 24 Hours/Day x 365 Days/Year = 8760 Hours/Year

Emission limitations:

Emission Description Pollutant Emission Regulation

Point # Limit

) Sulfur Recovery Unit

Available sulfur < 575 LTons/Day SO 2 <= 0.14 Lbs/Lbs of available Sulfur Rule 335-3-5-.03(4)

Or

Available sulfur => 575 LTons/Day & <= 1,031 LTons/Day SO 2 <= 0.186 – [ {8.57 X 10 -7 } S] Lbs/ Lbs of available sulfur Rule 335-3-5-.03(4)

Or Available sulfur > 1,031 LTons/Day SO 2 <= 10,008 Lbs/Hour Rule 335-3-5-.03(4)

Beginning no later than January 1, 2013 SO 2 <= 1,818 Lbs/Hour 40 CFR 51.308(d)(3) Based on daily 24 hr. avg. 40 CFR 51.308(e)

S-1201 Thermal oxidizer Opacity No more than one 6 min Rule 335-3-4-.01(1) avg. > 20%

Opacity No 6 min avg. > 40% Rule 335-3-4-.01(1)

H 2 S Burning of gas Rule 335-3-5-.03(2)

stream

H 2 S < 20 ppbv of H 2 S off Rule 335-3-5-.03(2) site- 101 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

Applicability

1. The sulfur recovery unit and thermal oxidizer shall be subject to the requirements specified in Rule 335-3-16 of the Alabama Department of Environmental Management Administrative Code and in this subpart of this permit. Rule 335-3-16-.03

2. The thermal oxidizer shall be subject to the requirements specified in Rule 335-3-4-.01(1) and Rule 335-3-5-.03(2) of the Alabama Department of Environmental Management Administrative Code and in this subpart of this permit. Rule 335-3-4-.01(1) Rule 335-3-5-.03(2)

3. The sulfur recovery unit and thermal oxidizer shall be subject to the requirements specified in Rule 335-3-5-.03(4) of the Alabama Department of Environmental Management Administrative Code and in this subpart of this permit. Rule 335-3-5-.03(4)

4. The sulfur recovery unit with thermal oxidizer has limits in place in order to avoid a review under the 40 CFR 51.308(e). 40 CFR 51.308(d)(3) 40 CFR 51.308(e)

5. The sulfur recovery unit and thermal oxidizer shall be subject to the requirements specified in 40 CFR Part 64 as indicated in proviso 33 of the General Permit Provisos subpart of this subpart and in this subpart of this permit. 40 CFR Part 64

Emissions Standards

1. Except as limited by proviso 1(d) of this section of this subpart, sulfur dioxide emissions shall not exceed the requirements specified in either proviso 1(a)(1) or 1(b)(1) or1(c)(1) of this section of this subpart.

(a) Provided available sulfur is less than 575 LTons/Day Rule 335-3-5-.03(4)

(1) 0.140 Lbs of SO 2 per Lb of available sulfur {i.e. => 93.0% sulfur recovery efficiency} while utilizing a rol ling 3 hour average

(b) Provided available sulfur is equal to or greater than 575 LTons/Day and less than or equal to 1,031 LTons/Day Rule 335-3-5-.03(4)

(1) [0.186 – { 8.57 X 10 -7 X (Lbs of available sulfur /Hour) }] Lbs of SO 2 per Lb of available sulfur- 102 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

{i.e. sulfur recovery efficiency ranging from => 93.0% to <= 94.80%} while utilizing a rol ling 3 hour average

(c) Provided available sulfur is greater than 1,031 LTons/Day Rule 335-3-5-.03(4)

(1) 10,008 Lbs of SO 2 /Hour {i.e. sulfur recovery efficiency => 94.80%} while utilizing a rol ling 3 hour average

(d) Beginning no later than January 1, 2013, 1,818 Lbs of SO 2 /Hr while utilizing a daily 24 hour average of the data measured and calculated each calendar day. 40 CFR 51.308(d)(3) 40 CFR 51.308(e)

2. The thermal oxidizer TRS oxidation efficiency shall be equal to or greater than 95.0%.

3. Except as is provided for in proviso 3(a) of this section of this subpart, each process gas stream containing more than 0.10 of a grain of hydrogen sulfide per Scf shall not be emitted into the atmosphere unless it is properly burned to maintain the ground level concentrations of hydrogen sulfide to less than twenty (20) parts per billion beyond plant property limits, averaged over a thirty (30) minute period. Rule 335-3-5-.03(2)

(a) Provided vessels or equipment are being de-pressured and/or emptied and the reduced pressure will not allow flow of the process gas stream to the combustion device, the venting to the atmosphere of any gas stream shall be allowed, but the duration of the venting shall not exceed 15 continuous minutes.

4. Visible emissions from the thermal oxidizer shall meet the requirements specified in prov iso 4(a) through (c) of this section of this subpart.

(a) Except for one 6-minute period during any 60- consecutive minute period, the thermal oxidizer shall not discharge into the atmosphere particulate that results in opacity greater than 20%, as determined by a 6-minute average. Rule 335-3-4-.01(1)(a)- 103 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

(b) At no time shall the thermal oxidizer discharge into the atmosphere particulate th at results in an opacity greater than 40%, as determined by a 6-minute
average. Rule 335-3-4-.01(1)(b)

Compliance and Performance Test Methods and Procedures

1. A performance test shall be conducted in accordance to the requirements specified in prov isions 1(a) and (b) of this section of this subpart. Rule 335-3-16-.05(c)(1)(i) Rule 335-3-1-.05

(a) At lease once every twelve (12) months

(b) Consist of three runs of at least 1-hour in duration each.

(1) Each run shall test for the emissions of SO 2 and TRS.

(2) Each run shall be conducted in accordance to the appropriate reference methods and procedures specified in proviso 1(b)(2)(i) through (vii) of this section of this subpart.

(i) 40 CFR Part 60 Appendix A, Method 1
or 1A

(ii) 40 CFR Part 60 Appendix A, Method 2 or 2A or 2B or 2C or 2D or 2E

(iii) 40 CFR Part 60 Appendix A, Method 3 or 3A or 3B or 3C

(iv) 40 CFR Part 60 Appendix A, Method 4

(v) 40 CFR Part 60 Appendix A, Method 6 or 6A or 6B or 6C

(vi) 40 CFR Part 60 Appendix A, Method 15 or 15A

(vii) 40 CFR Part 60 Appendix A, Method 16 or 16A or 16B

(3) TRS oxidation efficiency % =- 104 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

[ Total SO 2 (Lbs/Hour) ] – [ TRS (Lbs/Hour) ] Total SO 2 (Lbs/Hour)

(4) The pollutants tested for and the methods and procedures that are utilized may be modified upon receiving Departmental approval.

Emission Monitoring

1. A monitoring system that meets the requirements specified in the Sulfur Recovery System and Thermal Oxidizer table of Appendix A of this permit shall be utilized. §64.6(b) & (c) of 40 CFR Part 64 Rule 335-3-16-.05(c)(1)

Recordkeeping and Reporting Requirements

1. A record of the information specified in provisos 1(a) through (h) of this section of this subpart shall be maintained and made av ailable for inspection. Rule 335-3-16-.05(c)(2)

(a) The date, starting time and duration of each deviation from the requirements specified in this subpart along with the cause and corrective actions taken.

(b) The date, time and results of each performance tests along with any other tests conducted on the thermal oxidizer that provides additional stack pollutant content data.

(c) The date and time of each shut down and start up of either the gas sweetening unit or the 3 stage Claus sulfur recovery unit or the thermal oxidizer.

(d) Date and type of maintenance that affects air emissions

(e) Results of each visual emission observation

(f) The three hour rolling average CMS calculations and analysis of the sulfur r ecovery and/or the sulfur dioxide emissions.

(g) The three hour rolling average of the thermal oxidizer firebox temperature.- 105 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

(h) The information required by the recordkeeping section of Subparts A and §60.647 of 40 CFR Part 60

. 40 CFR §60.7 §60.647 of 40 CFR Part 60

2. Monitoring reports meeting the requirements specified in proviso 2(a) through (c) of this section of this subpart shall be submitted to the Department. Rule 335-3-16-.05(c)(2) Rule 335-3-16-.05(c)(3)(i)

(a) Each report shall identify each incidence of deviation from a permit term or condition including those that occur during startups, shutdowns, and malfunctions.

(1) A deviation shall mean any condition determined by observation, by data derived from any monitoring or testing or recordkeeping which is required by the permit that can be used to determine or indicate compliance, that identifies an affected source has failed to meet an applicable emission limit or standard or that a work practice was not complied with or completed.

(2) If no deviation event occurred during the reporting period, a statement that indicates there were no deviations from the permit requirements shall be included in the report.

(b) An Excessive Emission and CMS Performance Report and Summary Report meeting the requirements specified in provisos 2(b)(1) through (3) to this section of this subpart shall be submitted to the Department.

(1) A deviation shall consist of any period of time during which the following occurs:

(i) There was a failure to maintain the three hour rolling average sulfur recovery efficiency or sulfur dioxide emission rate and the daily 24 hour average sulfur dioxide emission rate at a value that is equal to or greater than the sulfur recovery efficiency or equal to or less than the sulfur dioxide emission rate that is required by proviso 1 of the Emissions Standards section of this subpart.- 106 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

(ii) There was a failure to maintain the hourly average thermal oxidizer stack at temperature that is equal to or greater than that required by the Periodic Monitoring column of the Sulfur Recovery System and Thermal Oxidizer table of Appendix A of this subpart.

(iii) There was a failure of the continuous emission monitoring system to meet the requirements specified in Appendix F 40 CFR Part 60 while the sulfur recovery unit or the thermal oxidizer remained in operation.

(2) Each report shall cover a calendar quarter period and shall be submitted within thirty days of the end of each reporting period.

(3) Except as provided for in proviso 2(d) of this section, each report shall meet the requirements specified in either §60.7(c) of 40 CFR Part 60, Subpart A.

(c) A Periodic Monitoring Report meeting the requirements specified in provisos 2(c)(1) through (3) of this section of this subpart shall be submitted to the Department.

(1) A deviation shall consist of any period of time during which the following occurs:

(i) There was a failure to meet the daily, quarterly and annual requirements specified in Appendix F of 40 CFR Part 60.

(ii) There was a failure to maintain the 6- minute average opacity at a value less than or equal to 20% for no more than one 6-minute period when utilizing Method 9.- 107 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

(iii) There was a failure to maintain the 6- minute averaging opacity at a value less than or equal to 40% during any 6- minute period when utilizing Method 9.

(iv) There was a failure to maintain the accumulated minutes in which visible emissions were observed at a value less than or equal to 12 minutes when utilizing Method 22.

(v) There was a failure to meet the requirements specified in proviso 1 of the Compliance and Performance Test Methods and Procedures section of this subpart.

(vi) There was a failure to meet the requirements specified in proviso 1 of the Emission Monitoring section of this subpart.

(vii) There was a failure to meet the requirements specified in proviso 1 of the Recordkeeping and Reporting Requirements section of this subpart.

(viii) There was a failure to take immediate corrective actions when a deviation occurred.

(2) Except as provided for in proviso 2(d) of this section, the report shall meet the requirements specified in proviso 2(c)(2)(i).

(i) For each deviation event, the following information shall be submitted.

(I) Emission source description

(II) Permit requirement

(III) Date

(IV) Starting time- 108 - 

### Provisos for Sulfur Recovery Unit and Thermal Oxidizer

Federally Enforceable Provisos Regulations

(V) Duration

(VI) Actual quantity of pollutant or parameter

(VII) Cause

(VIII) Actions taken to return to normal operating conditions

(IX) Total operating hours of the affected source during the reporting period

(X) Total hours of deviation events during the reporting period

(XI) Total hours of deviation events that occurred during start ups, shut downs, and malfunctions during the reporting period

(3) Each report shall cover no more that a calendar semi-annual period and shall be submitted within thirty days of the end reporting period.

(d) The report content and format in proviso 2(c) of this section may be modified upon receipt of Departmental approval.

3. Each deviation from the requirements specified in this subpart, including those that occur during startups, shutdowns, and malfunctions, shall be reported to the Department in a manner that complies with proviso 15(b) and 21(b) of the general proviso subpart of this permit. Rule 335-3-16-.05(c)(2) Rule 335-3-16-.05(c)(3)(ii)- 109 - 

## Appendix A

Monitoring- 110 - 

### Sulfur Recovery Unit and Thermal Oxidizer

Monitoring approach: Compliance assurance monitoring Compliance assurance monitoring

I. Indicator Sulfur recovery efficiency & Thermal Oxidizer Sulfur dioxide emission rate firebox temperature

A. Measurement approach Inlet feed volume and sulfur content Firebox temperature shall be shall be monitored with a system monitored with a thermocouple or capable of continuously measuring equivalent device. and recording the flow rate and/or the parameters utilized for flow rate calculation along with its sulfur
content.

Effluent volume and sulfur content shall be monitored with a system capable of continuously measuring and recording the flow rate and/or the parameters utilized for flow rate calculation along with its sulfur dioxide content.

A continuous emissions monitoring A continuous emissions monitoring system that is capable of assimilating system that is capable of assimilating the above information, analyzing that the above information, analyzing that information and making appropriate information and making appropriate calculations for each monitoring cycle calculations for each monitoring cycle and each rolling three hour period and each rolling three hour period while recording relevant information while recording relevant information and calculation results shall be and calculation results shall be utilized. utilized.

II. Indicator range If available sulfur < 575 LTons/Day Firebox temperature of shall be maintained at => 1,300 °F
SO 2 emission shall be <=
0.140 Lbs of SO 2 per Lb. of available Sulfur
Or sulfur recovery e fficiency => 93.0%

If available sulfur => 575 LTons/Day & =< 1,031 LTons/Day

SO 2 emission shall be <= [0.186 – {8.57 X 10 -7 X (Lbs of available Sulfur/Hour)}]
Lbs. of SO 2 per Lb. of available
sulfur
Or sulfur recovery effici ency => 93.0% to
<= 94.8%- 111 - If available sulfur > 1,031 LTons/Day

SO 2 emission shall be <= 10,008 Lbs/Hour
Or sulfur recovery e fficiency => 94.8%



### Sulfur Recovery Unit and Thermal Oxidizer

Monitoring approach: Compliance assurance monitoring Compliance assurance monitoring

Sulfur recovery efficiency & Thermal Oxidizer Sulfur dioxide emission rate firebox temperature

By no later than January 1, 2013
SO 2 emission shall be <= 1,818 Lbs/Hour

A deviation is defined as anytime the A deviation is defined as anytime the three hour rolling average SO 2 rate the three hour rolling average greater than the value calculated firebox temperature is < 1,300 °F. while utilizing the above equations or the three hour rolling average sulfur recovery efficiency is less than the value calculated while utilizing the above equations.

A deviation triggers an immediate A deviation triggers an immediate inspection and corrective actions that inspection, corrective action, and meet the requirements of 40 CFR Part reporting within 48 hours or two work 64.7(d) and reporting within 48 hours days. or two work days.

The minimum firebox temperature may be modified upon receipt of Departmental approval.

A QIP threshold If the accumulated hours of deviation If the accumulated hours of deviation events occurring exceeds 5% of the events occurring exceeds 5% of the sulfur recovery system operating time sulfur recovery system operating time during any quarterly reporting during any quarterly reporting period, a Quality Improvement Plan period, a Quality Improvement Plan shall be developed and implemented. shall be developed and implemented.

III. Performance criteria

A. Data representiveness The location of each inlet sensor shall Each temperature sensor shall be located be upstream of the sulfur located within the combustion recovery unit and shall consist of chamber or immediately downstream- 112 - 

### Sulfur Recovery Unit and Thermal Oxidizer

Monitoring approach: Compliance assurance monitoring Compliance assurance monitoring

Sulfur recovery efficiency & Thermal Oxidizer Sulfur dioxide emission rate firebox temperature

a single device that monitors all of the combustion chamber. streams or multiple sensors that monitors individual or multiple
streams.

The location of the effluent sensor shall be within the thermal oxidizer stack and shall consist of a multiple device that monitors all appropriate parameters.

The volume sensor shall be accurate The temperature sensor shall be to within ±2.0%. accurate to within ±1.0%.

The content sensor shall be accurate to within ±5.0%.

B. Verification of operational Not applicable Not applicable
status

C. QA/QC practices & criteria A program for the continuous Each temperature sensor shall be emission monitoring system shall be calibrated at a frequency in developed and implemented that accordance with the manufacturer’s meets the requirements specified in specifications, other written the following regulations: procedures that provide adequate assurance that the device is §60.13 of 40 CFR Part 60, Sub. A calibrated accurately. 40 CFR Part 60, App F 40 CFR Part 60, App B, PS 2 40 CFR Part 60, App B, PS 6

If a sensor fails its calibration If the sensor fails its calibration test, the sensor shall be taken out test, the sensor shall be taken out of service until repairs and/or of service until repairs and/or replacements are made and a new replacements are made and a new calibration test is undertaken and calibration test is undertaken and passed. passed.

D. Monitoring frequency Inlet volume or inlet volume Temperature shall be measured parameters and inlet content shall be continuously. measured continuously.

Effluent volume or effluent volume Temperature shall be measured parameters and effluent content shall continuously. be measured continuously.- 113 - 

### Sulfur Recovery Unit and Thermal Oxidizer

Monitoring approach: Compliance assurance monitoring Compliance assurance monitoring

Sulfur recovery efficiency & Thermal Oxidizer Sulfur dioxide emission rate firebox temperature

Data collection Calculate and record hourly and Record hourly and rolling three hour procedure rolling three hour averages of the average firebox temperature. following items:

Volumes & sulfur mass rates of: Inlet streams Thermal oxidizer effluent Actual sulfur dioxide emission rate Allowed sulfur recovery efficiency Actual sulfur recovery efficiency

Record each H 2 S concentration analysis.

Record calibration results. Record calibration results.

Record inspection results and Record inspection results and corrective actions taken. corrective actions taken.

Averaging period Rolling three hours Rolling three hours Daily 24 hour average- 114 - 

### Sulfur Recovery Unit and Thermal Oxidizer - Continued

Monitoring approach: Periodic Monitoring

I. Indicator Opacity

A. Measurement approach Provided the thermal oxidizer is being operated and facility operating personnel notice visible emissions being emitted from the thermal oxidizer, a daily visual emission observation on the thermal oxidizer shall be undertaken.

Duration of each observation shall be:

>= 15 minutes and <= 120 minutes

Each observation shall be conducted in accordance to either:

Test Method 9 of 40 CFR Part 60 Or Test Method22 of 40 CFR Part 60

II. Indicator range No 2 nd 6-min. opacity average > 20% No 6-min. opacity average > 40% Or Accumulated time that opacity is > 0%
shall not exceed 12 minutes.

A deviation is defined as anytime the observed 6-minute average opacity exceeds 20% for the 2 nd time when utilizing Method 9.

A deviation is defined as anytime the observed 6-minute average opacity exceeds 40% for the 1 st time when utilizing Method 9.

A deviation is defined as anytime the accumulated time in which visible emissions were observed exceeds 12 minutes per observation when utilizing Method 22.

A deviation triggers continued visible emissions observations at a frequency suitable to defining the duration of- 115 - The visible emission deviation event. One observation shall be undertaken to establish the end of the visible emission deviation event.



### Sulfur Recovery Unit and Thermal Oxidizer - Continued

Monitoring approach: Periodic Monitoring

Opacity

A deviation triggers an immediate inspection, corrective action, and reporting within 48 hours or two work days.

III. Performance criteria

A. Monitoring frequency Daily

Data collection Record: Daily procedure Each 15 second observation reading

Record: Each occurrence

Time, date and results of corrective actions taken

Averaging period Six minute- 116 - Flares - Continued

Monitoring approach: Periodic Monitoring Periodic Monitoring

I. Indicator Opacity Opacity

A. Measurement approach Provided a flaring event occurs at Provided a flaring event occurs at flare either flare No. Fl02 or Fl03, a daily No. Fl04 , a daily visual emission visual emission observation on the observation on the flare shall be flare shall be undertaken. undertaken.

Duration of each observation shall be: Duration of each observation shall be:

>= 15 minutes >= 15 minutes and and <= 120 minutes <= 60 minutes

Each observation shall be conducted Each observation shall be conducted in accordance to either: in accordance to either:

Test Method 9 of 40 CFR Part 60 Test Method 9 of 40 CFR Part 60 Or Or Test Method 22 of 40 CFR Part 60 Test Method 22 of 40 CFR Part 60

II. Indicator range Accumulated time that opacity is > 0% No 2 nd 6-min. opacity average > 20%
shall not exceed 5 minutes. No 6-min. opacity average > 40% Or Accumulated time that opacity is > 0%
shall not exceed 12 minutes.

A deviation is defined as anytime the A deviation is defined as anytime the Accumulated time exceeds 5 minutes observed 6-minute average opacity during any observation while utilizing exceeds 20% for the 2 nd time when either Method 9 or 22. utilizing Method 9.

A deviation is defined as anytime the observed 6-minute average opacity exceeds 40% for the 1 st time when utilizing Method 9.

A deviation is defined as anytime the accumulated time in which visible emissions were observed exceeds 12 minutes per observation when utilizing Method 22.

A deviation triggers continued visible A deviation triggers continued visible emissions observations at a frequency emissions observations at a frequency suitable to defining the duration of suitable to defining the duration of the visible emission deviation event. the visible emission deviation event. One observation shall be undertaken One observation shall be undertaken to establish the end of the visible to establish the end of the visible emission deviation event. emission deviation event.- 117 - Flares - Continued

Monitoring approach: Periodic Monitoring Periodic Monitoring

Opacity Opacity

A deviation triggers an immediate A deviation triggers an immediate inspection, corrective action, and inspection, corrective action, and reporting within 48 hours or two work reporting within 48 hours or two work days. days.

III. Performance criteria

A. Monitoring frequency Daily Daily

Data collection Record: Daily Record: Daily procedure Each 15 second observation Each 15 second observation reading reading

Record: Each occurrence Record: Each occurrence

Time, date and results of Time, date and results of corrective actions taken corrective actions taken

Averaging period 15 seconds Six minute- 118 - 

# AIR PERMIT

PERMITTEE: MOBILE ENERGY SERVICES COMPANY, LLC

FACILITY NAME: MOBILE ENERGY SERVICES COMPANY, LLC

LOCATION: MOBILE, MOBILE COUNTY, ALABAMA

PERMIT NUMBER DESCRIPTION OF EQUIPMENT, ARTICLE OR DEVICE

503-2021-X002 Power Boiler No. 6

In accordance with and s ubject to the provisions of the Alabama Air Po llution Control Act of 1971, as amended, Ala. Code §§22-28-1 to 22-28-23 (1997 Rplc. Vol. and 2006 Cum. Supp.) (the "AAPCA") and the Alabama Environmental Management Act, as amended, Ala. Code §§22-22A-1 to 22-22A-15 (1997 Rplc. Vol. and 2006 Cum. Supp.), and rules and regulations adopted there under, and subject further to the cond itions set forth in this permit, the Permittee is hereby authorized to construc t, install and use the equipment, device or other article described above.

ISSUANCE DATE: November 16, 2006Page 119 of 122 1. This permit is issued on the basis of Rules and Regulations existing on the date of issuance. In the event additional Rules and Regulations are adopted, it shall be the permit holder's responsibility to comply with such rules.

2. This permit is not transferable, whether by operation of law or otherwise, either from one location to another, from one piece of equipment to another, or from one person to another, except as provided in Rule 335-3-16-.13(1)(a)(5).

3. A new permit application must be made for new sources, replacements, alterations or design changes which may result in the issuance of, or an increase in the issuance of, air contaminants, or the use of which may eliminate or reduce or control the issuance of air contaminants.

4. Each point of emission will be provided with sampling ports, ladders, platforms, and other safety equipment to facilitate testing performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal Regulations, as the same may be amended or revised.

5. In case of shutdown of air pollution control equipment for scheduled maintenance for a period greater than 1 hour, the intent to shut down shall be reported to the Air Division at least 24 hours prior to the planned shutdown, unless accompanied by the immediate shutdown of the emission source.

6. In the event there is a breakdown of equipment or upset of process for a period exceeding one (1) hour in such a manner as to cause, or is expected to cause, increased emissions of air contaminants which are above an applicable standard, the person responsible for such equipment shall notify the Air Division within 24 hours or the next working day and provide a statement giving all pertinent facts, including the estimated duration of the breakdown. The Air Division shall be notified when the breakdown has been corrected.

7. All air pollution control devices and capture syst ems for which this permit is issued shall be maintained and operated at all times in a manner so as to minimize the emissions of air contaminants for purposes of meeting applicable requirements. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established.

8. Submittal of reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and regulations. The Department may require stack emission testing at any time.

9. Additions and revisions to the conditions of this Permit will be made, if necessary, to ensure that the Department's air pollution control rules and regulations are not violated.

10. Nothing in this permit or conditions thereto shall negate any authority granted to the Air Division pursuant to the Alabama Environmental Management Act or regulations issued thereunder.

11. This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspecto rs, measures to abate the odorous emissions- 120 - shall be taken upon a determination by the Alabama Department of Environmental Management that these measures are technically and economically feasible.

12. The Air Division must be notified in writing at least 10 working days in advance of all emission tests to be conducted and submitted as proof of compliance with the Department's air pollution control rules and regulations.

To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter:

(1) The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing company that will conduct the tests.

(2) A complete description of each sampling train to be used, including type of media used in determining gas stream components, type of probe lining, type of filter media, and probe cleaning method and solvent to be used (if test procedure requires probe cleaning).

(3) A description of the process(es) to be tested, including the feed rate, any operating parameter used to control or influence the operations, and the rated capacity.

(4) A sketch or sketches showing sampling point locations and their relative positions to the nearest upstream and downstream gas flow disturbances.

A pretest meeting may be held at the request of the source owner or the Department. Thenecessity for such a meeting and the required attendees will be determined on a case-bycase basis.

All test reports must be submitted to the Air Division within 30 days of the actual completion of the test, unless an extension of time is specifically approved by the Air Division.

13. Records will be maintained of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the process equipment and any malfunction of the air pollution control equipment. These records will be kept in a permanent form suitable for inspection and will be retained for at least two years following the date of each occurrence.

14. This unit shall be subject to the particulate emission limitations in ADEM Admin. Code r. 335-3-4-.03 while firing less than thirty percent wood waste, based upon heat input.

15. This unit shall be subject to the particulate emission limitations in ADEM Admin. Code r. 335-4-.08 while firing greater than or equal to thirty percent wood waste, based upon heat input.

16. The particulate emission rate from this unit shall not exceed the more stringent of 0.1 grains per standard dry cubic foot at 50 percent excess air and 101.56 pounds per hour, measured in accordance with 40 CFR Part 60, Method 5. Alternate test methods may be utilized if prior approval is granted by the Department.- 121 - 17. This unit shall not emit sulfur oxides, measured as sulfur dioxide, in excess of 1.8 pounds per million BTU heat input.

18. The sulfur dioxide emission rate from this unit shall not exceed 236.6 pounds per hour, as measured in accordance with 40 CFR Part 60, Method 6. Alternate test methods may be utilized if prior approval is granted by the Department.

19. The nitrogen oxide emission rate from this unit shall not exceed the more stringent of 0.33 pounds per million Btu heat input and 166.7 pounds per hour, as measured in accordance with 40 CFR Part 60, Method 7. Alternate test methods may be utilized if prior approval is granted by the Department.

20. The carbon monoxide emission rate from this unit shall not exceed the more stringent of 1.10 pounds per million Btu heat input and 548.6 pounds per hour, as measured in accordance with 40 CFR Part 60, Method 10. Alternate test methods may be utilized if prior approval is granted by the Department.

21. Opacity from this unit shall not be greater than 20 percent, except for one six-minute period during any 60-minute period of not greater than 40 percent. The opacity shall be determined in accordance with 40 CFR Part 60, Method 9.

22. A particulate matter emission test shall be performed at least once per year that the unit operates. A report of the test results shall be submitted to the Department if a test is conducted.

23. For particulate matter, sulfur dioxide, nitrogen oxide and carbon monoxide periodic monitoring, if any three-hour rolling block av erage steam production rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the steam production rate is to be lowered until compliance is successfully demonstrated at the higher rate.

24. For particulate matter periodic monitoring, if any three-hour block average wet scrubber pressure drop or liquid flow rate is less than 90 percent of its respective lowest value set by the required complying periodic test or a co mplying test approved by the Department, the facility shall investigate the cause and take corrective action within twenty-four hours.

25. A sulfur dioxide emission test shall be perform ed at least once every 5 years if the unit is operated. A report of the test results shall be submitted to the Department if a test is conducted.

26. A nitrogen oxide emission test shall be performed at least once every five years if the unit is operated. A report of the test results shall be submitted to the Department if a test is conducted.

27. A carbon monoxide emission test shall be performed at least once every five years if the unit is operated. A report of the test results shall be submitted to the Department if a test is conducted.

28. Records of all three-hour block average steam production rates shall be maintained on file and shall be available for inspection for at least five years.- 122 - 29. The wet scrubber pressure drops and liquid flow rates shall be measured continuously and recorded. These records should be available for inspection for a period of at least five
years.

30. The furnace oxygen percentage shall be measured continuously and recorded.

31. This unit shall be limited to firing natural gas and/or wood wastes.

32. The natural gas (fossil-fuel) heat input to this unit shall be limited to no greater than 240 MMBTU/hr. The natural gas usage during each hour, the natural gas heat content, and the hourly heat input from natural gas during each hour of operation shall be maintained and shall be available for inspection for a period of five years. A permit modification which increases the heat input of fossil-fuels into this unit to 250 MMBTU/hr or greater shall subject the unit to a best available retrofit technology (BART) review.

33. Should this facility, at any time, exceed the natural gas heat input limitation listed in Proviso 32, this Department must be notified within ten (10) days of the exceedance.

34. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit would have required halting or reducing the permitted activity.

35. The issuance of this permit does not convey any property rights of any sort, or any exclusive privilege.

November 16, 2006 Date