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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
PERMIT NO. 712-0010-008 

Coker No. 2 Provisos 

- 3 - 

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. 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 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 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 the 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 operated 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation of this permit. 

10. Emission test are to be conducted for the following pollutants at intervals not to exceed 

twelve (12) months following the date of initial compliance testing. 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 regulations. 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 control rules and regulations are not violated. 

13. 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. 

14. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 
PERMIT NO. 712-0010-008 

Coker No. 2 Provisos 

- 5 - 

emissions shall be taken upon a determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

21. The issuance of this permit does not convey any property rights of any sort, or any 

exclusive privilege. 

22. 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 
PERMIT NO. 712-0010-008 

Coker No. 2 Provisos 

- 6 - 

inspection and will be retained for at least 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 period of opacity monitoring system breakdowns, repairs, 

calibration checks and zero and span adjustments shall not be included in the data 

averages). 

• The date and time of commencement and completion of each time period of 

excess emissions. 

• The nature and cause of the excess emissions (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 and 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. 

26. Sulfur dioxide emissions from this source 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 SO2 emission limits on Coker 2, the SO2

emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and 

BTU ratings of the coal burned in these sources. A guaranteed analysis of each shipment 

of coal shall be obtained from the supplier. 

30. Records of the calculated SO2 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 
PERMIT NO. 712-0010-008 

Coker No. 2 Provisos 

- 7 - 

records shall include the supporting calculations, 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 Coker 2 shall be indicated 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 source shall not exceed 0.12 lbs/MMBTU. 

3. Sulfur dioxide emissions from this source 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
Solutia, 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 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. 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 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 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 the 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 operated 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation of this permit. 
PERMIT NO. 712-0010-007 

Coker No. 1 Provisos 

- 11 - 

10. Emission test are to be conducted for the following pollutants at intervals not to exceed 

twelve (12) months following the date of initial compliance testing. 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 regulations. 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 control rules and regulations are not violated. 

13. 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. 

14. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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 
PERMIT 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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

21. The issuance of this permit does not convey 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 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. 

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 period of opacity monitoring system breakdowns, repairs, 

calibration checks and zero and span adjustments shall not be included in the data 

averages). 

• The date and time of commencement and completion of each time period of 

excess emissions. 

• The nature and cause of the excess emissions (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 and 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. 

26. Sulfur dioxide emissions from this source 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 SO2 emission limits on Coker 2, the SO2

emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and 

BTU ratings of the coal burned in these sources. 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 SO2 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 calculations, 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 Coker 2 shall be indicated 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 source shall not exceed 0.12 lbs/MMBTU. 

3. Sulfur dioxide emissions from this source 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
Solutia, 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 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. 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 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 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 the 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 operated 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation of this permit. 
PERMIT NO. 712-0010-005 

Boiler No. 5 Provisos 

- 18 - 

10. Emission test are to be conducted for the following pollutants at intervals not to exceed 

twelve (12) months following the date of initial compliance testing. 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 regulations. 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 control rules and regulations are not violated. 

13. 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. 

14. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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 
PERMIT 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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

21. The issuance of this permit does not convey 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 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. 

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 period of opacity monitoring system breakdowns, repairs, 

calibration checks and zero and span adjustments shall not be included in the data 

averages). 

• The date and time of commencement and completion of each time period of 

excess emissions. 

• The nature and cause of the excess emissions (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 and 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 source 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 subject 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 SO2 emission limits on Boiler No. 5, the SO2

emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and 
PERMIT NO. 712-0010-005 

Boiler No. 5 Provisos 

- 21 - 

BTU ratings of the coal burned in these sources. A guaranteed analysis of each shipment 

of coal shall be obtained from the supplier. 

30. Records of the calculated SO2 emissions in lb/MMBTU for Boiler No. 5 shall be 

maintained in a permanent form suitable for inspection for a period of at least five years. 

These records shall include the supporting calculations, including the sulfur content and 

BTU ratings of the coal fired in these units (i.e., fuel certifications).
- 22 - 

1. Effective January 1, 2013, the sulfur dioxide (SO2) emission rate from this boiler shall 

not exceed 1.4 lb/MMBTU and 406 lb/hr as measured in accordance with 40 CFR Part 

60, Method 6. Continuous monitoring for indication 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
Solutia, Inc. 

Decatur, ALABAMA 

(PERMIT NO. 712-0010-006) 

PROVISOS 

Page 24 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. 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 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 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 the 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 operated 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation of this permit. 
PERMIT NO. 712-0010-006 

Boiler No. 6 Provisos 

- 25 - 

10. Emission test are to be conducted for the following pollutants at intervals not to exceed 

twelve (12) months following the date of initial compliance testing. 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 regulations. 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 control rules and regulations are not violated. 

13. 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. 

14. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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 
PERMIT 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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

21. The issuance of this permit does not convey 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 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. 

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 period of opacity monitoring system breakdowns, repairs, 

calibration checks and zero and span adjustments shall not be included in the data 

averages). 

• The date and time of commencement and completion of each time period of 

excess emissions. 

• The nature and cause of the excess emissions (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 and 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 source 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 subject 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 SO2 emission limits on Boilers No. 6, the SO2

emissions (lb/MMBTU) from each source shall be calculated from the sulfur content and 
PERMIT NO. 712-0010-006 

Boiler No. 6 Provisos 

- 28 - 

BTU ratings of the coal burned in these sources. A guaranteed analysis of each shipment 

of coal shall be obtained from the supplier. 

30. Records of the calculated SO2 emissions in lb/MMBTU for Boiler No. 6 shall be 

maintained in a permanent form suitable for inspection for a period of at least five years. 

These records shall include the supporting calculations, including the sulfur content and 

BTU ratings of the coal fired in these units (i.e., fuel certifications). 
- 29 - 

1. Effective January 1, 2013, the sulfur dioxide (SO2) emission rate from this boiler shall 

not exceed 1.4 lb/MMBTU and 448 lb/hr as measured in accordance with 40 CFR Part 

60, Method 6. Continuous monitoring for indication 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
Solutia, Inc. 

Decatur, ALABAMA 

(PERMIT NO. 712-0010-X015) 

PROVISOS 

Page 31 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. 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 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 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 the 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 operated 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation of this permit. 
PERMIT NO. 712-0010-X015 

Boiler No. 7 Provisos 

- 32 - 

10. Emission test are to be conducted for the following pollutants at intervals not to exceed 

twelve (12) months following the date of initial compliance testing. 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 regulations. 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 control rules and regulations are not violated. 

13. 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. 

14. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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 
PERMIT 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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

21. The issuance of this permit does not convey 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 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. 

23. A written report of the excess opacity emissions, SO2, and NOx emissions as defined 

below, will be submitted to the Department for each six month period 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 and completion of each time period of 

excess emissions. 

• The nature and cause of the excess emissions (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 and span checks) and the nature of the 

system repairs or adjustments. 

• Equations used to convert SO2 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 shall 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 source 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/MMBTU 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 shall 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 provisions 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 (SO2) 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 meet the required limit in Proviso No. 32 by 

installing a sorbent injection system (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 meet the required limit in Proviso No. 34 by 

installing a rotating opposed fired air system (ROFA) or comparable technology. 

5. Effective January 1, 2013, this boiler shall be equipped with a SO2 continuous emissions 

monitoring system for determination of compliance with the SO2 emission rate. This 

monitor shall meet the requirements of 40 CFR Part 60, Appendix F. 

6. Effective January 1, 2013, the continuous NOx monitoring system shall be used for 

determination of compliance with 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 source 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey any property rights of any sort, or any 

exclusive privilege. 

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

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

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

24. Particulate matter emissions shall not exceed the limits found the Department’s Air 

Division Rules and Regulations Chapter 335-3-4-. 08. 
PERMIT NO. 707-0001-X006 

No. 1 Combination Boiler Provisos 

- 41 - 

25. This unit shall not emit greater than 0.17 gr/sdcf corrected 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 discharge into the 

atmosphere from any source of emission, particulate 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. 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 

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 may 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 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 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 and sulfur dioxide periodic 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 taken 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 shall 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 available 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 the applicable requirements of 40 CFR Part 51, Subpart P and 

Appendix Y. 

2. Effective January 1, 2013, this unit shall 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 regulatory emissions testing without taking 

another unit off-line. 

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

i) The unit reduces NOx emissions to 93.15 lb/hr. 

ii) Emissions testing has been conducted which demonstrates compliance with the 

emission limit; after which yearly compliance testing will be performed for NOx and 

submitted to the Department. 

3. This unit shall not emit greater than 0.17 gr/sdcf corrected 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, 2013, 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 ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey any property rights of any sort, or any 

exclusive privilege. 

21. This source is subject to the requirements of ADEM Admin. Code 335-3-4-. 07 (2) (c) 

particulate matter from kraft pulp mill lime kilns. 

22. This source is subject to the requirements of ADEM Admin. Code 335-3-4-. 01 for 

opacity. 

23. This source is subject to the 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 request and the initial 
PERMIT 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 discharge into the 

atmosphere from any source of emission, particulate of an opacity not greater than that 

designated as forty percent. 

26. 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. 

27. 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. 

28. Compliance with the nitrogen oxide emission limit shall be determined in accordance 

with the 40 CFR Part 60 Method 7 or 7e. Alternate 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 may 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 block average lime mud 

flow rate is greater than 110 percent of its 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 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 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 taken within twenty-four hours. 

33. A particulate matter emission test report shall 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 the 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 result of properly performed startups, 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 monitor, 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 installed, 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 the 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 dioxide emissions shall not exceed 0.10 lb/hr. 

4. Effective January 1, 2013, nitrogen oxide 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 emission test shall be performed at least once 

per calendar year. 

7. Effective January 1, 2013, a nitrogen oxide emission test shall be performed at least once 

per calendar year. 

8. Effective January 1, 2013, a sulfur dioxide emission 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 ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey 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 solid fossil fuel and wood 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 the continuous emission monitoring system. 

30. Compliance with the sulfur dioxide pound per hour limit shall be determined in 

accordance with 40 CFR Part 60 Method 6. Alternate 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 may 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 complying 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 corrective action is to be taken. 

36. A continuous emission monitoring system for the measurement of sulfur dioxide shall be 

installed, calibrated, operated and maintained. 

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

38. The fossil fuel to bark ratio shall be monitored 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 shall 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 recorded 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 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 emissions (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 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. 

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 calendar year shall be recorded and maintained on 

file available for inspection for at least five years. 

46. Records of the emission unit’s running twelve-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 month that completes any twelvemonth period). The records shall be maintained on file available for review for a period 

of at least two years 
PERMIT 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 recorded during periods 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 emissions (if known) and the corrective 

action taken or preventative measures adopted. 

(d) The date and time identifying each period 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 the 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 solid fossil fuel and wood 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 emissions 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 ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey any property rights of any sort, or any 

exclusive privilege. 

21. This source is subject to federal New Source Performance Standards 40 CFR 60 Subpart 

A and Subpart BB. 

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

23. This source is subject to the requirements of ADEM Admin. Code 335-3-4-. 01 for 

opacity. 
PERMIT NO. 707-0001-X013 

No. 2 Lime Kiln Provisos 

- 66 - 

24. This source is subject to the 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 request 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 exceed 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 discharge into the 

atmosphere from any source of emission, particulate 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. 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 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 or 7e. 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 may 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 block average lime mud 

flow 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 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 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 taken within twenty-four hours. 

35. A total reduced sulfur continuous emission monitor shall be installed, 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 shall 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 within the month following the end of the 

quarter. The reports will include 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 monitoring system 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 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 inoperative 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 scrubber 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 the applicable requirements of 40 CFR Part 51, Subpart P and 

Appendix Y. 

2. Particulate emissions shall not exceed 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 dioxide 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 emission test shall be performed at least once 

per calendar year. 

8. Effective January 1, 2013, a nitrogen oxide emission test shall be performed at least once 

per calendar year. 

9. Effective January 1, 2013, a sulfur dioxide emission 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 ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey 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 (28) 

New Source Performance Standards Subpart BB for kraft pulp mills and Rule 335-3-14. 

22. This source is subject to the 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 request 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 shall 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 test 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. Alternate test methods may be used provided 

prior approval by the Department is granted. 

34. Compliance with the volatile organic compound 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 approval by the Department is granted. 

35. Compliance with the carbon monoxide emission limit shall be determined in accordance 

with the 40 CFR Part 60 Method 10. Alternate test methods may be used provided prior 

approval by the Department is granted. 

36. Compliance with the opacity limit shall be determined in accordance with 40 CFR Part 

60 Appendix A Method 9. Alternate test methods 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 corrective action is to be taken. 

39. For particulate matter, sulfur dioxide, nitrogen 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 Department, 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 performed at least once every five years. 

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

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

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

years. 

46. A particulate matter emission test report shall 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-hour block average liquor-firing rates shall be made and maintained 

on file available for inspection 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 within the month following the end of the 

quarter. The reports will include 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 emission monitoring system 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. 
PERMIT NO. 707-0001-X010 

No. 2 Recovery Furnace Provisos 

- 76 - 

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 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 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 emissions (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 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 the 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 shall 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 emission test shall be performed at least once 

per calendar year. 

10. Effective January 1, 2013, a nitrogen oxide emission test shall be performed at least once 

per calendar year. 

11. Effective January 1, 2013, a carbon monoxide emission 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 FINAL BART NO 2 RECOVERY FURNACE X010 
- 78 - 

CHECKLIST FOR ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey 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 (28) 

New Source Performance Standards Subpart BB for kraft pulp mills and Rule 335-3-14. 

22. This source is subject to the requirements of ADEM Admin. Code 335-3-4-. 01 for 

opacity. 

23. This source is subject to the 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 request and the initial 
PERMIT 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 exceed 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 discharge into the 

atmosphere from any source of emission, particulate of an opacity not greater than that 

designated as forty percent. 

27. 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. 

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 may 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 and set periodic monitoring parameters. 

33. For particulate matter and total reduced sulfur periodic monitoring, 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 than 90 percent of its respective average value set by the 

required complying periodic test or a complying test approved by the Department or if 

fan ampere readings indicate the fan is not operating, 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 shall 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 shall be submitted to the Department at least 

once every five years. 

37. Records of all three-hour block average liquor firing 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 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 the applicable requirements of 40 CFR Part 51, Subpart P and 

Appendix Y. 

2. Particulate matter emissions shall not exceed 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 dioxide 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 emission test shall be performed at least once 

per calendar year 

7. Effective January 1, 2013, a sulfur dioxide emission 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 ISSUANCE 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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: February 5, 2008
International 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 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. 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 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 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 the 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 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 application is cancelled if construction 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. Authorization 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 operation without authorization 

could result in revocation 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 regulations. 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 control rules and regulations are not violated. 

12. 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. 

13. 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: 

(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 company that will conduct the tests. 

(b) 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). 

(c) 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. 

(d) 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. The 

necessity 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. 

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 determination by the Alabama Department of 

Environmental Management that these measures are technically 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 surface 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 traffic 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 methods fail to adequately reduce airborne 

dust from plant or haul roads and grounds, alternative 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 methods 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 and 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 would have required halting or reducing the 

permitted activity. 

20. The issuance of this permit does not convey 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 requirements 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 initial 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 shall 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 discharge into the 

atmosphere from any source of emission, particulate 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 test 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 Method 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 may 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, operated and maintained per the requirements of Rule 335-3-8- 

.12 for the ozone season each year (May first 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 taken 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 fired in any rolling twelve-month period shall 

be recorded and maintained on file available for inspection for at least five years. 
PERMIT NO. 707-0001-X007 

Package Boiler Provisos 

- 92 - 

38. The nitrogen oxide budget program 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 the 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 ISSUANCE 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 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 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 from 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 fired 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 averages, 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 matter and opacity periodic monitoring, the steam 

production rate is to be checked at least once per shift. 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 monitoring 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 production rate shall be recorded. 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 inspection 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 2005 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 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: July 6, 2006 

Modification Date December 10, 2007 

Expiration Date: January 7, 2011 

Alabama Department of Environmental Management 
- 100 - 

Summary Page for Sulfur Recovery 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 SO2 <= 0.14 Lbs/Lbs of available 

Sulfur Rule 335-3-5-.03(4) 

 Or 

 Available sulfur => 575 LTons/Day & <= 1,031 LTons/Day SO2 <= 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 SO2 <= 10,008 Lbs/Hour Rule 335-3-5-.03(4) 

 

 Beginning no later than January 1, 2013 SO2 <= 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) 

 

 H2S Burning of gas Rule 335-3-5-.03(2) 

 stream 

 

 H2S < 20 ppbv of H2S 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 SO2 per Lb of available sulfur 

{i.e. => 93.0% sulfur recovery efficiency} 

while utilizing a rolling 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 SO2 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 rolling 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 SO2/Hour 

{i.e. sulfur recovery efficiency => 94.80%} 

while utilizing a rolling 3 hour average 

(d) Beginning no later than January 1, 2013, 1,818 Lbs 

of SO2/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 proviso 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 that 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 provisions 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 SO2

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 SO2 (Lbs/Hour) ] – [ TRS (Lbs/Hour) ]

 Total SO2 (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 available 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 recovery 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 

SO2 emission shall be <=

0.140 Lbs of SO2 per

Lb. of available Sulfur

Or 

sulfur recovery efficiency => 93.0% 

If available sulfur => 575 LTons/Day 

& =< 1,031 LTons/Day 

SO2 emission shall be <=

[0.186 – {8.57 X 10-7 X

(Lbs of available Sulfur/Hour)}] 

Lbs. of SO2 per Lb. of available

sulfur 

Or 

sulfur recovery efficiency => 93.0% to 

<= 94.8%
- 111 - 

If available sulfur > 1,031 LTons/Day 

SO2 emission shall be <=

10,008 Lbs/Hour 

Or 

sulfur recovery efficiency => 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 

SO2 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 SO2 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 H2S 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 
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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 2nd 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 2nd time when 

utilizing Method 9. 

 

A deviation is defined as anytime the 

observed 6-minute average opacity 

exceeds 40% for the 1st 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 
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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 
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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 2nd 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 2nd 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 1st 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. 

 
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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 
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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 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 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 conditions set forth in this permit, the Permittee 

is hereby authorized to construct, install and use the equipment, device or other article described 

above. 

ISSUANCE DATE: November 16, 2006
Page 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 systems 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 inspectors, measures to abate the odorous emissions 
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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. The 

necessity 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. 
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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 average 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 complying 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 performed 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 
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