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AIR DISPERSION MODELING 

PROTOCOL FOR BART 

RAYONIER PERFORMANCE FIBERS, LLC 

JESUP, GEORGIA 

Submitted For: 

RAYONIER PERFORMANCE FIBERS, LLC 

4470 Savannah Highway 

Jesup, Georgia 31545 

Submitted By: 

WESTON SOLUTIONS, INC. 

4917 Waters Edge, Suite 

Raleigh, North Carolina 27606 

April 2006 

Work Order No. 05565.009.001 
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TABLE OF CONTENTS 

SECTION 1. INTRODUCTION.......................................................................................... 1-1

SECTION 2. MILL LOCATION ........................................................................................ 2-1

SECTION 3. MODELING APROACH.............................................................................. 3-1

3.1 Model Configuration and Settings...............................................................................3-2 

3.1.1 Emissions and Stack Parameters..............................................................................3-2 

3.1.2 Receptors ................................................................................................................. 3-3 

3.1.3 Background.............................................................................................................. 3-3 

LIST OF TABLES 

TABLE 3-1 CLASS I MODELING................................................................................................... 3-2 

TABLE 3-2 ....................................................................................................................................3-3 
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1-1

SECTION 1. INTRODUCTION 

Under regional haze regulations, the Environmental Protection Agency (EPA) has issued final 

guidelines dated July 6, 2005 for Best Available Retrofit Technology (BART) determinations. 

The regional haze rule includes a requirement for BART for certain large stationary sources. 

Sources are BART-eligible if they have potential emissions of at least 250 tons per year of a 

visibility-impairing pollutant, were put in place between August 7, 1962 and August 7, 1977, and 

fall within one of the 26 listed source categories in the guidance. A BART engineering 

evaluation using five statutory factors – 1) existing controls; 2) cost; 3) energy and non-air 

environmental impacts; 4) remaining useful life of the source; 5) degree of visibility 

improvement expected from the application of controls – is required for any BART-eligible 

source that can be reasonably expected to cause or contribute to impairment of visibility in Class 

I areas. 

States must develop their implementation plans by December 2007. States will first identify the 

facilities that will have to reduce emissions under BART and then set BART emissions limits for 

those facilities. 

As part of this process, the Visible Improvement State and Tribal Association of the Southeast 

(VISTAS) members agreed to develop a common BART Modeling Protocol1 for use by the 

states and facilities subject to BART. The VISTA recommended process for evaluating the 

BART-eligible sources are: 

• Identify the BART eligible sources based on source category, when it was put in service, 

and the magnitude of emissions of one or more “visibility-impairing pollutants”. 

• Determine whether the BART eligible source can be excluded from BART controls by 

demonstrating that the source cannot be reasonably expected to cause or contribute to 

visibility impairment in a Class I area. 

• Determine BART controls for the source by considering various control options and 

selecting the “best” alternative. 

• Incorporate the BART determination into the State Implementation Plan (SIP). 

The objective of this VISTAS’ BART Modeling Protocol is to describe common procedures for 

air quality modeling to support BART determinations that are consistent with the EPA 

guidelines. The protocol will serve as the basis for establishing a common understanding among 

the organizations who will be performing the BART analyses or reviewing the BART modeling 

results, including VISTAS, State and Local air regulatory agencies, Environmental Protection 

Agency (EPA,) Federal Land Managers (FLMs), source operators, and contractors for the 

sources. 

A BART-eligible source will be required to submit a site-specific modeling protocol to the State 

for review and approval prior to performing CALPUFF modeling. States will consult with 

FLMs and the EPA when evaluating the site-specific BART protocols. The site-specific 

protocol will include the source-specific data on source location, stack parameters, and 

 

1

 “Protocol for the Application of the CALPUFF Modeling for Analyses of Best Available Retrofit Technology 

(BART)”, Visibility Improvement State and Tribal Association of the Southeast, March 2006. 
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1-2

emissions. The methods of the VISTAS common modeling protocol will be followed in the sitespecific protocol unless the source proposes to the State alternative methods or assumptions. 

The Rayonier Performance Fibers, LLC (Rayonier) Mill located in Jesup, Georgia has several 

BART eligible sources. These are the No. 5 Recovery Furnace, the No. 5 Smelt Dissolving Tank, 

wastewater treatment system, C-mill (digesters, brownstock washers and bleach plant), Devaporators and the No. 3 Power Boiler. However, only the No. 5 Recovery Furnace, the No. 5 

Smelt Tank and the No. 3 Power Boiler emit visibility impairing pollutants. This protocol 

outlines the approach to be taken to conduct the CALPUFF modeling for Rayonier. 
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2-1

SECTION 2. MILL LOCATION 

The Rayonier mill is located northeast of downtown Jesup in Wayne County at approximate 

Universal Transverse Mercator (UTM) coordinates 420,019 meters Easting and 3,502,929 

meters Northing, NAD83, Zone 17. Modeling for BART–eligible sources must be evaluated for 

Class I areas located within 300 km of the facility. Table 2-1 lists the Class I areas within 300 

km of the Jesup mill. The distances given in Table 2-1 are the approximate distance from the 

mill to the nearest boundary of the Class I Area. 

Table 2-1 

Class I Areas within 300 Kilometers 

Rayonier, Jesup, Georgia

Class I Area State 

Distance 

(kilometers) 

Direction From 

Plant 

Okefenokee Wilderness Area Georgia 76 Southwest 

Wolf Island Wilderness Area Georgia 58 Southeast 

Cape Romain South 

Carolina 246 Northeast 

St. Marks Florida 264 Southwest 

Bradwell Bay Florida 302 Southwest 
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SECTION 3. MODELING APROACH 

According to 40 CFR Part 51, Appendix Y, dispersion modeling can be used to determine that an 

individual BART-eligible source can reasonably be anticipated to cause or contribute to 

visibility impairment in a Class I area and thus not be subject to BART requirements. A BARTeligible source that is responsible for a 1.0 deciview (dv) change or more at a Class I area is 

considered to “cause” visibility impairment. A BART-eligible source that is responsible for a 

0.5 dv change or more at a Class I area is considered to “contribute” to visibility impairment in a 

Class I area. Sources determined to cause or contribute to visibility impairment in a Class I area 

are subject to BART requirements. 

Since the distance to each of these Class I areas is greater than 50 km, the use of CALPUFF to 

determine visibility impacts is acceptable. The CALMET/CALPUFF (as provided by VISTAS) 

modeling system will be used. The analysis will follow guidance provided in the VISTAS 

guidance document. Features of the CALPUFF modeling system include: 

• A Gaussian puff dispersion formulation: Plumes are treated as a series of Gaussian puffs 

that move and disperse according to local meteorological conditions that vary in time 

and space. 

• Three-dimensional meteorology: Wind and other meteorological variables are allowed to 

vary three-dimensionally. 

• Wet and dry deposition: Deposition processes are included for both particles and 

gaseous pollutants that depend on the characteristics of the pollutant, local surface 

roughness and meteorology. The model accounts for the mass removed from the plume 

when deposition occurs. Post-processing will be performed using CALPOST (Version 

5.4) to predict annual deposition of nitrogen (N) and sulfur (S). 

• Aerosol chemistry: Secondary aerosol formation is treated according to a first-order 

mechanism that depends on the time of day, relative humidity, meteorology, background 

ozone concentration, and background ammonia concentration. 

• Post-processing by CALPOST specifically to assess regional haze: Visibility is 

characterized using extinction coefficients that vary with the concentrations of the 

aerosol species present, extinction characteristics of each aerosol species, and relative 

humidity. 

Based on the VISTAS guidance, if the BART eligible potential emissions of SO2 in tons per year 

(Q, based on the actual emissions for 2002) divided by the distance to each Class I boundary (d, 

in kilometers) is greater than 10, the source is subject to BART and no further exemption 

modeling will be performed by VISTAS. The source either can proceed with using CALPUFF 

to evaluate BART control options or the source can conduct its own modeling to determine 

impacts on the Class I area. If Q/d is less than 10, then VISTAS will conduct further modeling 

of the facility. 

For Rayonier the 2002 actual emissions of SO2 from the BART-eligible sources is 1,715 tons per 

year (based on information received from EPD). Table 3-1 shows the calculation for the five 

Class I areas located within 300 km of Rayonier. Based on this calculation, modeling will be 

conducted for Okefenokee and Wolf Island Class I. 
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Table 3-1 

Class I Modeling 

Class I Area Distance from 

Rayonier (km) 

Q/d BART Modeling 

Required? 

Okefenokee 76 23 Yes 

Wolf Island 58 30 Yes 

Cape Romain 246 7.0 No 

St. Marks 264 6.5 No 

Bradwell Bay 302 5.7 No 

To further determine if a BART-eligible source is subject to BART, a two tier approach is 

recommended by VISTAS. The first step is to model the facility (sources) with CALPUFF using 

a 12-km grid CALMET file (this is available from EPD). If the facility modeling shows twentyfour hour impacts less than 0.5 dv, then no further modeling is required. If the facility modeling 

impacts are greater than 0.5 dv, then further modeling can be conducted using a more refined 4 

km CALMET input file. If the impacts using the 4 km CALMET input file are less than 0.5 dv, 

then the source is exempted from further BART evaluation. If the impacts exceed 0.5 dv, then 

the Rayonier sources are required to implement BART. This would require further modeling. 

For the 12-km initial modeling exemption test, the highest single 24-hour average value across 

the receptors in the Class I area will be compared to the threshold value of 0.5 dv. If using the 

single highest 24-hr average value proves to be too conservative f a screening level, VISTAS 

may allow some exceedances of the threshold value for exemption purposes, up to no more than 

the 98th percentile value. The 12-km modeling results can be used to focus finer grid modeling 

for exemption purposes on only those Class I areas where impacts greater than 0.5 dv were 

projected in the 12-km modeling. For the grid (4 km or less) analyses, the 98th percentile impact 

value for the 24-hr average will be used. Either the 8th highest day in each year or the 22nd

highest day in the 3-year period, whichever is more conservative, will be used for comparison to 

the exemption threshold. 

3.1 MODEL CONFIGURATION AND SETTINGS 

The 12 km and/or 4 km CALPUFF modeling will be conducted using the settings specified in 

Section 4 of the VISTAS protocol document. 

3.1.1 EMISSIONS AND STACK PARAMETERS 

Currently, Rayonier is developing the emission rate information to be used in the modeling. 

Once this is complete, Rayonier will supply EPD with this information. This will include the 

maximum 24-hour actual emissions of SO2, H2SO4, NOx, and PM10. PM10 emissions will be 

broken down further into the appropriate filterable and condensable portions and further into 

elemental carbon (soot), soil, coarse particulate and organics. The VISTAS Protocol specifies a 

priority ranking of how to obtain the emission rates for use with the BART exclusion modeling 

as follows: 

• 24-hour maximum value emissions for the period 2001-2003 based on continuous 

emission monitoring data. 
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• 24-hour maximum value from continuous emission monitoring data. 

• Facility stack tests. 

• Potential to emit. 

• Permit allowable rates. 

• Emission factors from AP-42. 

PM speciation will be obtained from AP-42, stack testing and the VISTAS website 

http://www.vistas-sesarm.org/BART/calpuff.asp

Table 3-2 shows the stack parameters to be used for the BART-eligible Rayonier sources. As 

specified in the VISTAS protocol, building downwash will not be considered. 

Table 3-2 

Stack Parametersa 

Source 

UTM 

East 

(m) 

UTM 

North 

(m) 

Height 

(m) 

Diameter 

(m) 

Temperature 

(

o

K) 

Exit 

Velocity 

(m/s) 

No. 3 Power 

Boilerb 

C c 57 2.58 521 27.69 

No. 5 

Recovery 

Furnace 

420,163 3,502,648 78.8 3.81 475 15.5 

No. 5 Smelt 

Dissolving 

Tank 

420,156 3,502,671 78.8 1.38 339 19.2 

a Visibility impairing pollutants (PM, SO2, NOx and H2SO4) are not emitted from the BARTeligible wastewater treatment plant, C-mill, and D-evaporators and will not be included in the 

BART modeling analysis. 

b A new scrubber is currently be installed on the No. 3 Boiler. The initial modeling will be 

conducted based on the configuration of the stack when it was originally installed. However, 

subsequent modeling may incorporate the emission reductions associated with the installation oft 

his scrubber. 

c To be determined. 

3.1.2 RECEPTORS 

Receptor location and elevations information for each of the five Class I areas to be modeled will 

be obtained from the Federal Land Manager (FLM) website 

http://www2.nature.nps.gov/air/Maps/Receptors/index.cfm . 

3.1.3 BACKGROUND 

Background information for ammonia will be set to 0.5 ppb. For ozone, background will be 

developed from the existing CASNET and AIRS station data. The data to be used will be 
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submitted to EPD for review prior to modeling. Background concentrations of TNO3 and SO4

will be obtained from the CMAQ modeling currently being conducted.