Appendix L.2: Georgia Pacific Corporation - Monticello 

Appendix L.2 contents: 

L.2.1 Appendix summary 

L.2.2 BART information request letter 

L.2.3 BART eligibility letter 

L.2.4 Modeling protocol 

L.2.5 BART applicability analysis report 

L.2.6 BART exemption letter 
Appendix L.2.1 

Georgia Pacific - Monticello (1 500-00007) BART Process Summary 

As a kraft pulp mill, Georgia Pacific - Monticello (GP) meets the initial BART eligibility 

requirement of source category code. GP - Monticello is 209 krn from Breton National 

Wildlife Refuge, a Class I area, and has a possible visibility impact. Therefore, on 

February 28,2002, Mississippi Department of Environmental Quality (MDEQ) sent them 

a letter requesting information to determine BART eligibility. Based on the information 

received from GP - Monticello, several units were deemed BART eligible because they 

met the following criteria: 

operating or under construction between Aug.7, 1962 to Aug.7, 1977 

having potential emissions that exceed the limit of 250 tons per year for 

SO?, NO,, or PM10. 

The following are the BART-eligible point sources for GP - Monticello. 

As a result, GP - Monticello was required to perform CALPUFF modeling on these units. 

Using the old IMPROVE equation, the modeling analysis demonstrated a 9gth percentile 

24-hour average visibility impact of 0.33 dv for Breton. The threshold contribution for 

BART subjectivity is 0.5 dv; therefore, GP - Monticello is not BART subject. 

Existing Control Equip. 

Electrostatic Precipitator 

Electrostatic Precipitator 

Low NO, Burners 

Flue Gas Recirculation 

Scrubber 

Scrubber 

Scrubber 

. 

Emission Unit 

Recovery Boiler 1 

Recovery Boiler 2 

Combination Boiler 

Power Boiler 

Smelt Tank 1 

Smelt Tank 2 

Lime Kiln 

Heat Duty 

(MMBtulhr) 

861 

861 

1 17 

776 

Maximum Emission Rates (tons per year) 

Totals. 

PMfo 

874 

874 

404 

17 

51 

51 

141 

, 2412 

SO2 

1789 

1789 

56 

2 

57 

57 

182 

3932 

NOx 

877 

877 

804 

578 

I I 

11 

419 

, 3577 
- Appendix L.2.2 

STATE OF MISSISSIPPI 

DAVID RONALD MUSOROVIE. GOVERNOR 

MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUALI~ 

CHARLES H. (311SOUI. EXKVTM DIRKTOR 

February 28,2002 COPY 

Mr. Tim Jones 

Georgia Pacific Corporation 

P.O. Box 608 

Monticello, MS 39654 

Re: BART Information Request 

Dear Mr. Jones: 

In July 1999, The Environmental Protection Agency (EPA) issued regional haze 

regulations to improve visual air quality, or visibility, in specified national ph and 

wildemtss ateas across the country. These regulations require states to establish gods 

for improving visibility in thest areas and to submit state implementation plans (SIPS) 

that contain enfmccable measures and control strategies for reducing visibility-impairing 

pollution. 

One component of these regulations is to reduce emissions hm certain, existing, I 

emission units by installing the best available emission mntrols. This requirement, 

known as the Best Available Retrofit Technology (BART) requirement, applies to 

mission units that: 

were built between August 7,1962 and August 7,1977; 

0 have tbe potential to emit 250 tons per year or more of ammonia, nitrogen oxides, 

particulate matter less that 10 microns (PMlo), sulfur dioxide, or volatile organic 

compounds, either individually or in combination with otbcr such units; and 

D fall into one of 26 listed some categories, including steam electric plants and 

industrial boilers, and large industrial plants such as pulp mills, refineries, and 

smelters. See attached list. 

The final implementation plan should be submitted to EPA by December 31,2008, and 

must contain, among other things, the emission limits and campliance schedules for each 

BART subject source. The first step in this pmess is to identify all BART subject 

SOUTCes. 

Mississippi and other southeastern states and tribes have formed a Regional Planning 

Organization, known as VISTAS, to work on the regional haze issue and the required 
implementation plans. It is our goal to have all BART subject failities and the specific 

emission units at the facilities identified by June 2002. 

An initial file review indicates that your facility is potentially subject to the BART 

requirement becaw it falls into one of the 26 source categories, was built prior to August 

7,1977, and has potential ~nissions greater than 25 0 tons per year for at least one of the 

visibility-impairing pollutants. However, the information listed below is needed to 

make a determination. 

The initial startup date for facility. 

The initial startup date for individual emission units. 

The dates of any modification or reconstniction for individual units. 

a The BART source category of the emission units. 

A list of emission units obtained from our files is enclosed. Please enter the dates of 

initial start-up and any modification or rcconstnrction, review and make any corrections 

to the listed source category, and review and make any comtions to the potential 

emissions. This information is also available in excel spreadsheet fonnat which can be 

wmpletcd and submitted electronically. 

Please respond by April 19,2002. If this information is not received, the facility and all 

emission units at the facility will be considd subject to the BART rcquircments. 

However, the final dctenninations will not be made until the SIP development process. 

Thank you for your help with this projcct. If you have any questions, please contact me 

at (601)%1-S 176 or Deborah Boltwart at (601)961-5768, If you would like the 

electronic copy of the emission unit list, please send an e-mail to 

deborehrehboltw~dq.state.ms.us and elliott-bick~~~~q.state.ms.us. 

Lkc;;()LElliott Bickerstaff, P.E. 

Chief, Air Support Branch 
Appendix L.2.3 

STATE OF MISSlSSlPPl 

DAVlD RONALD MUSGROM. GOVERNOR 

MISS~SSIPPI DEPARTMENT OF ENVIRONMENTAL QUALITY 

CHAlurS H.CHISOLM, DIRECTOR 

October 8,2002 

Mr. Tim Jones 

Georgia Pacific Corporation 

604 Sandifer Highway 

Monticello, MS 39654 

Re: BART Information Response 

Georgia Pacific Corporation, Monticello 

Lawrence County, Mississippi 

Dear Mr. Jones: 

This letter is to acknowledge receipt of your response to our Best Available Retrofit 

Technology (BART) letter dated February 28,UMe. After reviewing the information 

you submitted, it appears your facility is BART eligible for the following reasons: 

1. The facility meets the category requirement for kraft pulp mills. 

2. All units began operation during the August 7, 1962 to August 7, 1977 date 

range. 

3. The emissions from these units exceed the 250 tons per year limit. 

On May 24,2002, the D.C. circuit court vacated the BART provisions of the Regional 

Haze Rule (RHR). At issue is the method of determining the cost and benefits of 

installing BART at a particular source. The RHR requires this detenninetion to be 

made on a group or collective basis; however, it was argued that the Clam Air Act 

requires this determination to be made on a source by source basis. In a 2-1 decision, a 

three-judge panel agreed with the petitioners and vacated the BART provisions, 

requiring EPA to revise the BART requirements to incorporate a source by source 

approach. EPA has filed a petition seeking rehearing of the case by the MI court. 

Depending on the outcome of the appeals process, this ding may affect what controls 

a BART applicable source will be required to install, but the ruling did not address and 

therefore will not impact the methods in determining the BART applicable mtuces. We 

plan to proceed with identifying the specific emission units at the facility that are 

subject to this requirement. Please note that a BART applicable souroe is one that will 

be considered for retrofit bxhnologysontrols. It does not necessarily mean that 
Appendix L.2.3 

additional controls will be required for the source. Those defednations will be made 

over the next several years during the Regional Haze planning and our State 

Implementation Plan development process. 

Attached are the BART requirement text and the applicable definitions from the Code 

of Federal Regulations. If you have questions or corrnnents regarding the BART 

requirements or this designation, please contact me at (601) %1-5176 or Deborah 

Boleware at (601) 961-5768. 

Sincerely, 

Chief, Air Support h 
Appendix L.2.4 

August 3 1,2006 

Deborah Boleware 

Mississippi Department of Environmental Quality 

Office of Pollution Control 

Air Division 

P. 0. Box 10385 

Jackson, MS. 39289-0385 

Re: Protocol for Best Available Retrofit Technology Exemption Modeling: Monticello Mill 

Georgia-Pacific Corporation (GP) is pleased to submit this Protocol for Best Available Retrofit 

Technology (BART) Engineering air modeling for our pulp and paper facility in Monticello, 

Mississippi. BART is required for any eligible source that "emits any air pollutant which may 

reasonably be anticipated to cause or contribute to any impairment of visibility" in any 

mandatory Class I federal area. 40 CFR Part 5 1 Appendix Y states, "You can use dispersion 

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

contribute to visibility impairment in a Class I area and thus is not subject to BART." The 

enclosed protocol describes our proposal for this dispersion modeling. Should the facility not 

qualify for the exemption level, the protocol describes the additional post-processing steps for 

quantifying the visibility improvement to engineering control scenarios with a VISTASsponsored refined dataset. The analyses will be completed by Georgia-Pacific. While many of 

the components of a protocol for this analysis are thoroughly documented in the VISTAS 

common protocol, this document provides source-specific information. 

We look forward to addressing any questions or concerns you have with this protocol. Please 

contact me at (404) 652-4293; FAX (404) 654-4706; miaguila~ipapac.com. 

Sincerely, 

Mark J. Aguilar P.E. 

Senior Environmental Engineer 

Georgia-Pacific Corporation 

Cc: Tim Jones, Monticello Mill 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1. 2006 

1.0 INTRODUCTION ............................................................................................................ 1 

1.1. Overview of the Regional Haze BART Process ............................................................... 1 

1.2. Organization of the Protocol ............................................................................................. 2 

SITE DESCRIPTION ....................................................................................................... 3 

VISTAS CONTRIBUTION TO CALPUFF MODELING ........................................... 7 

MODEL DISCUSSION .................................................................................................. 7 

Exemption Procedures .................................................................................................. 7 

CALPUFF Configuration ............................................................................................. 8 

RESULTS AND DETERMINATION OF IMPAIRMENT .......................................... 9 

Impact Threshold .......................................................................................................... 9 

Presentation of Modeling Results ................................................................................ 9 

QUALITY ASSURANCE PLAN .................................................................................. 12 

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1.0 INTRODUCTION 

1.1. Overview of the Regional Haze BART Process 

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

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

(70 FR 39 104-39 172). The regional haze rule includes a requirement for BART for certain large 

stationary sources, such as our pulp & paper facility in Monticello, MS. Sources are BARTeligible if they meet three criteria on potential emissions of visibility-impairing pollutants, the 

date when the source was put in place and fall within one of the source categories listed in the 

guidance. The guidance requires a BART engineering evaluation using five statutory factors for 

any BART-eligible source that can be reasonably expected to cause or contribute to impairment 

of visibility in any Class I areas protected under the regional haze rule. (Note that, depending on 

the five factors, the evaluation may result in no control.) Air quality modeling is an important 

tool available to the States to determine whether a source can be reasonably expected to 

contribute to visibility impairment in a Class I area. 

The process of establishing BART determination consists of four steps: 

I) Identify whether a source is "BART-eligible" based on its source category, when it was 

put in service, and the magnitude of its emissions of one or more "visibility-impairing" air 

pollutants. The BART guidelines list 26 source categories of stationary sources that are 

BART-eligible. Sources must have been put in service between August 7, 1962 and 

August 7, 1977 in order to be BART-eligible. Finally, a source is eligible for BART if 

potential emissions of visibility-impairing air pollutants are greater than 250 tons per year. 

Qualifying pollutants include primary particulate matter (PMlo) and gaseous precursors to 

secondary fine particulate matter, such as SO2 and NO,. VISTAS has determined that 

neither ammonia nor volatile organic compounds (VOCs) should be included as visibilityimpairing pollutants for BART eligibility. 

2) Determine whether a 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. The preferred approach is an assessment with an air 

quality model such as CALPUFF or other appropriate model followed by comparison of 

the estimated 24-hr visibility impacts against a threshold above estimated natural 

conditions to be determined by the ~tates.1 The threshold to determine whether a single 

source "causes" visibility impairment is set at 1.0 deciview (dv) change from natural 

conditions over a 24-hour averaging period in the final BART rule (70 FR 391 18). The 

guidance also states that the proposed threshold at which a source may "contribute" to 

visibility impairment should not be higher than 0.5 dv although, depending on factors 

affecting a specific Class I area, it may be set lower than 0.5 dv. The test against the 

Guidance to determine the level of the natural conditions baseline for BART modeling purposes is still under 

development by VlSTAS members states and EPA Region 1V. 

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August 3 1,2006 

threshold is "driven" by the contribution level, since if a source "causes", by definition it 

"contributes". 

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

selecting the "best" alternative, taking into consideration: 

a) Any pollution control equipment in use at the source (which affects the 

availability of options and their impacts), 

b) The costs of compliance with control options, 

c) The remaining useful life of the facility, 

d) The energy and non air-quality environmental impacts of compliance, 

and 

e) The degree of improvement in visibility that may reasonably be 

anticipated to result from the use of such technology. 

Note that if a source agrees to apply the most stringent controls available to BART-eligible 

units, the BART analysis is essentially complete and no further analysis is necessary (70 

FR 39165). 

4) Incorporate the BART determination into the State Implementation Plan for Regional 

Haze, which is due by December 2007. 

Step 2 described above reflects 40 CFR Part 5 1 Appendix Y which states that, "You can use 

dispersion modeling to determine that an individual source cannot reasonably be anticipated to 

cause or contribute to visibility impairment in a Class I area and thus is not subject to BART." 

(70 FR 391 62) This "individual source attribution approach" determines if a BART-eligible 

source (i.e., collection of eligible emission units at a source) is predicted to cause or contribute to 

visibility impairment in a Class I area. As mentioned above, a predicted impact of I .O dv change 

or more is considered to "cause" visibility impairment, and a predicted impact of 0.5 dv change 

or more is considered to "contribute". Any source determined to cause or contribute to visibility 

impairment in any Class I area is subject to BART. 

1.2. Organization of the Protocol 

Section 2 presents facility-specific information. Section 3 presents the contribution by VISTAS 

for the BART exemption analyses. Section 4 summarizes the exemption process, modeling 

approach, and model configuration. Section 5 presents the criteria and processing of model 

results to demonstrate what impairment, if any, the facility is predicted to create in the Class I 

areas. Section 6 presents the Quality Assurance Plan. 

The exemption modeling is completed in two phases: screening and refined. The sections below 

also identify how values in model input, exemption criteria, and model approach are different in 

these two phases. 

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2.0 SITE DESCRIPTION 

The Mill is located approximately 5 miles north of the town of Monticello, in Lincoln County. 

The UTM coordinate for the project area is 776.9 E, 3502.7 N kilometers (km), Zone 15. 

The area surrounding the Mill is largely rural or undeveloped and generally flat in all directions. 

Figure 1 presents an aerial map of the Monticello Mill vicinity. The facility manufactures 

corrugated containerboard. 

The Mill construction began in 1966 and most existing emission units of PM10, sulfur dioxide, 

and nitrogen oxides were constructed and began operations in the 1962-1977 window for BART 

eligibility. An exception is the thermal oxidizer installed after 1980. Table 1 presents the source 

parameters for point sources and reflects recent dispersion modeling reviewed by MDEQ for air 

permit applications. Table 2 presents emission rate information reflecting permit conditions. 

Table 1. Source Modeling Parameters. GP Monticello Mill 

Stack Parameters 

Source Location Stack Exit Stack Exit Stack 

Model UTM Stack Height Temp Velocity Diameter 

ID Description East (m) North (m) (fi) (m) K F (fils) (ds) (ft) (m) 

RE31 UT-1 Recovery Boiler 1 776961 3502671 232 70.71 435.9 325.0 55.57 16.94 8.0 2.44 

RB2 UT-I Recovery Boiler 1 776953 3502664 233 71.02 435.9 325.0 43.91 13.38 9.0 2.74 

RE33 UT-2 Recovery Boiler 2 776945 3502656 233 71.02 435.9 325.0 43.91 13.38 9.0 2.74 

RE34 UT-2 Recovery Boiler 2 776937 3502649 232 70.71 435.9 325.0 55.57 16.94 8.0 2.44 

UT3 UT-3 Comb. Boiler 776881 3502758 213 64.92 438.7 330.0 50.19 15.30 11.0 3.35 

UT4 UT-4 Power Boiler 776880 3502735 232 70.71 435.9 325.0 82.32 25.09 8.0 2.44 

UT5 UT-5 Smelt Tank 1 776891 3502709 233 71.02 349.0 168.5 24 7.32 4.0 1.22 

UT6 UT-6 Smelt Tank2 776868 3502688 233 71.02 349.0 168.5 24 7.32 4.0 1.22 

CRI CR-1 Lime Kiln 777020 3502615 95 28.96 352.0 174.0 24.01 7.32 8.0 2.44 ~~~~~ - 

Notes: 

1. GP proposes to exclude fugitive-only and woodyard chip/bark/wood transfer cyclones 

from the BART modeling inventory. Combined, these sources described in the air 

permit collectively emit a maximum of 3.8 Ibslhr of PM. 

2. Recovery Boilers 1 and 2 are modeled with 2 stacks each. Smelt Tanks 1 and 2 have 

two identical stacks each, and are modeled with one representative stack for each tank. 

P iA!r & Waler\A~r\BARnMonoceIIoiBART E\empllon Protocol Montdlo doc 3 
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Figure 1. Aerial Photo Of Vicinity of GP Monticello Mill 

UTM East [m) NAD27 Zone 15 

P \Ar 8: W~er\Alr\BARnMontlcello~BART E\ern~son Protocol Montlcello doe 4 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1,2006 

Table 2. Maximum 24-hour Permitted Emissions, Monticello Mill BART Point Sources. 

Existing Maximum Emission Rates (Ibslhr) 

Control 

Source Equipment SO2 H2S04 NOx PM 1 0 Speciated? 

RBI ESP 204.2 1.55 100.1 35.9 Yes 

ESP 

ESP 

ESP 

LNB 

LNBIFGR 

Scrubber 

Scrubber 

Scrubber 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

Yes 

ESP = Electrostatic Precipitator; LNB = Low NOx Burners; FGR = Flue Gas Recirculation 

Notes: 

1. Permit does not limit H2S04 emissions. 

2. Permit contains multiple limits, most restrictive PM 10 limit for RB 1 -RB4 is 0.44 grldscf 

08%. 

3. UT5 reflects emissions of both UT5L and UT5R 

Speciated emissions will be developed using industry-estimated guidance by National Council 

for Air & Stream Improvement. 

Figure 2 presents a regional map showing the Monticello Mill and all PSD Class I Areas within 

300 km. Breton NWR is located approximately 202 km from the Mill. The next nearest PSD 

Class I area is over 385 km from the Mill. Only Breton NWR will be evaluated in the impact 

analyses. 

P \kr & Waler\Atr\BARnMont~celldsART E~ernpflon Prolocal Manlmllo doc 5 
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Figure 2. GP Monticello Mill Location and PSD Class I Areas Within 300 km 

-GP Monticello Mill 

i~reton NWR 

UTM East (m) NAD27 Zone 15 

P \Air 8: Wnler\AiriBAR~anIicello!BART Enemphon Protocol Man~icello.doc 6 
Monticello Mill BART Exemption Modeling Protocol 

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3.0 VISTAS CONTRIBUTION TO CALPUFF MODELING 

For this application of BART Exemption Modeling, VISTAS is providing the technical data 

through its contractor, Earth Tech. 

VISTAS will provide updates and supporting information concerning the VISTAS Common 

Modeling Protocol on the VISTAS website. In addition, VISTAS will make publicly available 

the following data bases developed by Earth Tech: 

VISTAS version of the CALPUFF modeling system, maintained on the Earth Tech 

website. And will not be updated further unless errors are found in the code. 

12-km CALMET output files for 200 1,2002, and 2003 produced as described in 

previous sections. Further detail on model configuration and settings will be 

provided with the output files and will be made available on the CALPUFF website. 

CALMET will include a software modification to allow the meteorological data 

inputs into CALMET to be used to generate finer grid CALMET files without having 

to go back to the original MM5 output files 

Five 4-km CALMET subdomains for 2001,2002, and 2003, produced as described in 

previous sections. Further detail on model configuration and settings will be 

provided with the output files and will be made available on the website. 

File with CALPUFF model configuration and settings sufficient to replicate 

CALPUFF modeling done for VISTAS using 12 km CALMET, including 

o Ozone data used to run CALPUFF 

o Ammonia data used to run CALPUFF and to partition NO3 in POSTUTIL. 

o Background concentrations files for use in POSTUTIL 

o All other set up files used in VISTAS 12-km CALPUFF run 

4.0 MODEL DISCUSSION 

4.1 Exemption Procedures 

For determining if a BART-eligible source is subject to a full BART engineering analysis, GP is 

proposing a single refined-level approach. For all visibility modeling use CALPUFF with 4-km 

grid CALMET. 

P \kr & WSer\A~rlBARnMont~cello\BART Exsrnplmn Prolocol Monncello doc 7 
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August 3 1,2006 

For finer grid (4 km or less) analyses, use the 98th percentile impact value for the 24-hr average. 

Use either the 8th highest day in each year or the 22nd highest day in the 3-year period, 

whichever is more conservative, for comparison to the exemption threshold. 

The analysis uses the same model assumptions for pre-BART visibility impact and for BART 

control options modeling: establish baseline visibility from the pre-BART run; change one 

control at a time; and evaluate the change in visibility impact, i.e. the delta-deciview. Note that 

"no control'' may constitute BART. 

The VISTAS Common Modeling Protocol consistently recommends conservative assumptions. 

Individual States ultimately have responsibility to determine which, if any, BART controls are 

recommended in their State Implementation Plans (SIPS). The VISTAS protocol presents 

additional detailed information on the meteorological fields, and specific settings for CALPUFF 

and CALPOST (see section 4.33 of the VISTAS Common Modeling Protocol). 

4.2 CALPUFF Configuration 

Source emissions should be defined using the maximum 24-hour actual emission rate during 

normal operation for the most recent 3 or 5 years. If maximum 24-hr actual emissions are not 

available, continuous emissions data, permit allowable emissions, potential emissions, and 

emissions factors from AP-42 source profiles may be used as available. Specific configuration 

settings presented in the VISTAS Common Modeling Protocol are listed below: 

Use a default value for NH3 provided by VISTAS. 

Use ozone data from non-urban monitors as the background ozone input (VISTAS 

Standard ozone files). 

Use the Pasquill-Gifford dispersion method 

In CALPOST, use Method 6 with monthly average RH for calculating extinction, as 

recommended by the EPA. 

Use EPA default calculations of light extinction under current and natural background 

conditions. 

The major features and options of the meteorological and dispersion model are summarized and 

discussed in the VISTAS Common Modeling Protocol. 

As also discussed in the VISTAS Common Modeling Protocol, CALPUFF is currently not 

recommended for addressing visibility impacts from VOC because its capability to simulate 

secondary organic aerosol formation from VOC emissions is not adequately tested, especially for 

anthropogenic emissions. (Separately, condensable organic carbon can be calculated from 

PM10.) 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1,2006 

EPA has given states the option to address ammonia (NH3) emissions from BART-eligible 

sources. VISTAS has also contracted with Georgia Tech to perform emissions sensitivities using 

CMAQ v 4.4 with a refined SOA module and the Jun-Jul and Nov-Dec periods in 2002. At the 

time of this protocol, MDEQ is not requesting the objective treatment of ammonia emissions 

from the source. 

5.0 RESULTS AND DETERMINATION OF IMPAIRMENT 

5.1 Impact Threshold 

The final BART guidance recommends that the threshold value to define whether a source 

"contributes" to visibility impairment is 0.5 dv change from natural conditions (although states 

may set a lower threshold). The 9sth percentile (sth highest annual) 24-hr average predicted 

impact at the Class I area, as calculated using CALPOST Method 6 (monthly average relative 

humidity values), is to be compared to this contribution threshold value. For this comparison, the 

predicted impact at the Class I area on any day is taken to be the highest 24-hr average impact at 

any receptor in the Class I area on that day. (Note that the receptor where the highest impact 

occurs can change from day to day.) According to clarification of.the BART guidance received 

from EPA, for a three-year simulation the modeling values to be compared with the threshold are 

the greatest of the three annual sth highest values or the 22"* highest value over all three years 

combined, whichever is greater. 

5.2 Presentation of Modeling Results 

The CALPOST processing computes the daily maximum change in deciviews. A sample of the 

summary table produced by CALPOST is shown in Table 4. For evaluating compliance with the 

VISTAS screening threshold, the 98% change in extinction value, located at the bottom of the 

CALPOST list file is compared to the threshold value (e.g., 0.5 dv). For example, in the sample 

shown in Table 3, the summary at the bottom shows that the highest visibility impact is 1.219 dv, 

with 9 days over the year showing values greater than 0.5 dv. Therefore this source would not 

pass the initial analysis, and finer grid modeling would be required. 

In addition to the highest change in deciview value on each day over all the receptors in a 

particular Class I area, the CALPOST summary table in Table 3 contains the coordinates of the 

receptor, receptor type (D indicates discrete receptors), the total haze level (background + source, 

in dv), the background haze in deciviews, the change in haziness (delta dv), the humidity term 

applied to hygroscopic aerosols (F(RH)), and the contribution of each species to light extinction 

(in percent of the total source contribution) for S04, N03, organics, elemental carbon, coarse 

and fine particulate matter. 

If the maximum predicted impact is above 0.5 dv, then these results will also be presented: 

Number of receptors within a single Class I area with impact > 0.5 dv 

Number of days at all receptors in the Class I area with impact > 0.5 dv 

P \Air & Water\A~r\BARnManlleelldsART Exemption Protacol Manldlu doc 9 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1,2006 

Number of Class I areas with impacts > 0.5 dv 

Section 4 of the VISTAS Common Modeling Protocol present sample tables for these results. 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1,2006 

Table 3. Example of CALPOST Output, Showing Maximum Daily Impacts of Source and Locations of Those Impacts. 

YEAR DAY HR RECEPTOR COORDINATES (km) TYPE DV(Tota1) DV(BKG) DELTA DV F(RH) %-SO4 %No3 %-OC %-EC %-PMC %-PMF 

2001 2 0 3 20.540 79.782 D 5.397 5.358 0.039 4.314 44.33 47.22 3.07 1.07 0.00 4.30 

2001 3 0 9 31.680 79.822 D 4.566 4.421 0.145 1.767 40.75 33.89 9.19 3.24 0.00 12.94 

2001 4 0 1 24.723 77.951 D 4.540 4.540 0.000 2.076 0.00 0.00 0.00 0.00 0.00 0.00 

2001 5 0 77 30.228 94.571 D 4.950 4.939 0.011 3.144 43.13 44.74 4.64 1.45 0.00 6.05 

2001 6 0 1 24.723 77.951 D 5.181 5.166 0.015 3.772 38.58 56.05 1.90 0.70 0.00 2.76 

2001 7 0 3 20.540 79.782 D 6.366 5.745 0.620 5.439 44.98 44.99 3.69 1.26 0.00 5.08 

--- Number Of days with Delta-Deciview => 0.50: 9 

--- Number of days with Delta-Deciview -> 1.00: 2 

--- Largest Delta-Deciview = 1.219 
Monticello Mill BART Exemption Modeling Protocol 

August 3 1,2006 

6.0 QUALITY ASSURANCE PLAN 

Air quality modeling covered under this protocol is an important tool for use in 

determining whether a BART-eligible source can be reasonable expected to cause or 

contribute to visibility impairment in a Class I area. and therefore whether this source 

should be subject to BART controls, and if so, to determine the relative benefits of 

various BART controls. The purpose of the quality assurance (QA) program is to 

establish procedures for ensuring that products produced by the application of the 

modeling techniques for BART studies satisfy the regulatory objectives of the BART 

program. Section 6 of the VISTAS Common Modeling Protocol presents additional 

detailed information on the QA plan. 

P \Au & WatdAzr\B4RnMon!!ceIIo\BART E\empuon Protocol Monllcella doc 12 
Appendix L.2.5 

Georgia-Pacific LLC 

133 Peachtree Street NE 

Atlanta, GA 30303 

(404) 652-4000 

www.gp.com 

September 7,2007 

Ms. Deborah Boleware 

Mississippi Department of Environmental Quality 

Office of Pollution Control, Air Division 

P. 0. Box 10385 

Jackson, MS 39289-0385 

Re: Georgia-Pacific Monticello, LLC - Monticello, Mississippi Mill 

Best Available Retrofit Technology Applicability Analysis 

Dear Ms. Boleware: 

Georgia-Pacific Monticello, LLC (GP) is pleased to submit this Best Available Retrofit 

Technology (BART) Applicability Analysis Report for our pulp and paper mill in Monticello, 

Mississippi. BART is required for any eligible source that "emits any air pollutant which may 

reasonably be anticipated to cause or contribute to any impairment of visibility" in any 

mandatory Class I federal area. EPA's guidelines for assessing applicability of BART (40 CFR 

Part 5 1, Appendix Y) state that a BART-eligible source "can use dispersion modeling to 

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

visibility impairment in a Class I area and thus is not subject to BART." 

The enclosed report describes our BART applicability modeling analyses, which demonstrate 

that the modeled visibility impacts are below the applicability criteria. These results indicate that 

GP's Monticello Mill is exempt from BART requirements because visibility-affecting emissions 

from BART-eligible emission units neither cause nor contribute to visibility impairment at any 

Class I area. 

While many of the components of a protocol for this analysis are thoroughly documented in the 

VISTAS common protocol, this document also provides source-specific information used to 

conduct our analyses. We look forward to addressing any questions or concerns you have about 

this report. Please contact me at (404) 652-4293; FAX (404) 654-4706; minguilaQ gapac.com. 

Sincerely, 

Mark J. Aguilar P.E. 

Senior Environmental Consultant 

Georgia-Pacific LLC 

cc: Tim Jones, Georgia-Pacific Monticello, LLC 
1.0 INTRODUCTION ............................................................................................................ 2 

1.1. Overview of the Regional Haze BART Process .............................................................. 2 

1.2. Organization of the Report ............................................................................................... 3 

2.0 SITE DESCRIPTION ....................................................................................................... 4 

3.0 VISTAS CONTRIBUTION TO CALPUFF MODELING ........................................... 8 

4.0 MODEL DISCUSSION .................................................................................................... 8 

4.1 Exemption Procedures .............................................................................................. 8 

4.2 CALPUFF Configuration ............................................................................................. 9 

5.0 RESULTS AND DETERMINATION OF IMPAIRMENT ........................................ 1 1 

5.1 Impact Threshold ........................................................................................................ 1 1 

5.2 Presentation of Modeling Results .............................................................................. 1 1 

P \Air & Water\A~BAR~Monlii.clIo\CALPUFRGP Monticello MS BART Appllwh~ltty Analys~s Report (2007.09.07 . Uplate).doc i 
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September 7,2007 

1.0 INTRODUCTION 

1.1. Overview of the Regional Haze BART Process 

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

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

determinations (70 FR 39104-39172). The regional haze rule includes a requirement for 

BART for certain large stationary sources, such as Georgia-Pacific's pulp & paper 

facility in Monticello, Mississippi. Sources are BART-eligible if they meet three criteria 

on potential emissions of visibility-impairing pollutants. the date when the source was put 

in place, and fall within one of the major source categories listed in the guidance. The 

guidance requires a BART engineering evaluation using five statutory factors for any 

BART-eligible source that can be reasonably expected to cause or contribute to 

impairment of visibility in any Class I areas protected under the regional haze rule. (Note 

that, depending on the five factors, the evaluation may result in no control.) Air quality 

modeling is an important tool available to the States to determine whether a source can be 

reasonably expected to contribute to visibility impairment in a Class I area. 

The process of establishing BART determination consists of four steps: 

1) Identify whether a source is "BART-eligible" based on its source category, when 

it was put in service, and the magnitude of its emissions of one or more "visibilityimpairing" air pollutants. The BART guidelines list 26 source categories of 

stationary sources that are BART-eligible. Sources must have been put in service 

between August 7, 1962 and August 7, 1977 in order to be BART-eligible. 

Finally, a source is eligible for BART if potential emissions of visibility-impairing 

air pollutants are greater than 250 tons per year. Qualifying pollutants include 

primary particulate matter (PMlo) and gaseous precursors to secondary fine 

particulate matter, such as SO2 and NO,. VISTAS has determined that neither 

ammonia nor volatile organic compounds (VOCs) should be included as visibilityimpairing pollutants for BART eligibility. 

2) Determine whether a BART-eligble 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. The preferred approach is an 

assessment with an air quality model such as CALPUFF or other appropriate model 

followed by comparison of the estimated 24-hr visibility impacts against a threshold 

above estimated natural conditions to be determined by the ~tates.~ The threshold 

to determine whether a single source "causes" visibility impairment is set at 

1.0 deciview (dv) change from natural conditions over a 24-hour averaging period 

in the final BART rule (70 FR 391 18). The guidance also states that the proposed 

threshold at which a source may "contribute" to visibility impairment should not be 

Guidance to determine the level of the natural conditions baseline for BART modeling purposes is still 

under development by VISTAS members states and EPA Region IV. 

P:iAr & Water\AoiBARTiMonticcIbiCALPUFF!GP Monlacllo MS BART Appliwhslily Annlysis Repn (2007-09-07. Update) doc 2 
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September 7, 2007 

higher than 0.5 dv although, depending on factors affecting a specific Class I area, 

it may be set lower than 0.5 dv. The test against the threshold is "driven" by the 

contribution level, since if a source "causes", by definition it "contributes". 

3) Determine BART controls for the source by considering various control options 

and selecting the "best" alternative, taking into consideration: 

a) Any pollution control equipment in use at the source (which affects the 

availability of options and their impacts), 

b) The costs of compliance with control options, 

c) The remaining useful life of the facility, 

d) The energy and non air-quality environmental impacts of compliance, 

and 

e) The degree of improvement in visibility that may reasonably be 

anticipated to result from the use of such technology. 

Note that if a source agrees to apply the most stringent controls available to BARTeligible units, the BART analysis is essentially complete and no further analysis is 

necessary (70 FR 39165). 

4) Incorporate the BART determination into the State Implementation Plan for 

Regional Haze, which is due by December 2007. 

Step 2 described above reflects 40 CFR Part 51 Appendix Y which states that, "You can 

use dispersion modeling to determine that an individual source cannot reasonably be 

anticipated to cause or contribute to visibility impairment in a Class I area and thus is 

not subject to BART." (70 FR 39162) This "individual source attribution approach 

determines if a BART-eligible source (i.e., collection of eligible emission units at a 

source) is predicted to cause or contribute to visibility impairment in a Class I area. As 

mentioned above, a predicted impact of 1 .O dv change or more is considered to "cause" 

visibility impairment, and a predicted impact of 0.5 dv change or more is considered to 

"contribute". Any source determined to cause or contribute to visibility impairment in 

any Class I area is subject to BART. 

1.2. Organization of the Report 

Section 2 presents facility-specific information. Section 3 presents the contribution by 

VISTAS for the BART exemption analyses. Section 4 summarizes the exemption 

process, modeling approach, and model configuration. Section 5 presents the criteria and 

processing of model results to demonstrate what impairment, if any, the facility is 

estimated to create in the Class I areas. 

The exemption modeling is completed in two phases: screening and refined. The sections 

below also identify how values in model input, exemption criteria, and model approach 

are different in these two phases. 

- 

P \Au & Wole~lr\BAR~MnntceIlo\CALPUFnGP Montlcello MS BART Appll~abht~ Analyans Replrl(2007-IW-07. Upda~e) doe 3 
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September 7,2007 

2.0 SITE DESCRIPTION 

The Mill is located approximately 5 miles north of the town of Monticello, in Lawrence 

County. The UTM coordinate for the project area is 776.9 E, 3502.7 N kilometers (km), 

Zone 15. The area surrounding the Mill is largely rural or undeveloped and generally flat 

in all directions. Figure 1 presents an aerial map of the Monticello Mill vicinity. The 

facility manufactures corrugated containerboard. 

The Mill construction began in 1966 and most existing emission units of PMlo, sulfur 

dioxide, and nitrogen oxides were constructed and began operations in the 1962 to 1977 

window for BART eligibility. An exception is the thermal oxidizer installed after 1980. 

Table 1 presents the source parameters for point sources and reflects recent dispersion 

modeling reviewed by MDEQ for air permit applications. Table 2 presents emission rate 

information reflecting permit conditions. 

Table 1. Source Modeling Parameters, GP Monticello Mill 

Stack Parameters 

Source Location Stack Stack Exit Stack Exit Stack 

Model LCC (km) Height Temp Velocity Diameter 

ID Description East North (ft) (m) (K) (OF) (ftls) (mls) (ft) (m) 

RB1 UT-1 Recovery Boiler 1 656.2265 -903.199 232 70.71 435.9 325.0 55.57 16.94 8.0 2.44 

RB2 UT-1 Recovery Boiler 2 656.2189 -903.206 233 71.02 435.9 325.0 55.57 13.38 8.0 2.74 

RB3 UT-2 Recovery Boiler 1 656.21 1 -903.214 233 71.02 435.9 325.0 55.57 13.38 8.0 2.74 

UT3 UT-3 Comb. Boiler 656.142 -903.1 15 213 64.92 438.7 330.0 50.19 15.30 11.0 3.35 

UT4 UT-4 Power Boiler 656.1424 -903.138 232 70.71 435.9 325.0 82.32 25.09 8.0 2.44 

UT5 UT-5 Smelt Tank 1 656.1547 -903.164 233 71.02 349.0 168.5 24 7.32 4.0 1.22 

UT6 UT-6 Smelt Tank 2 656.1328 -903.186 233 71.02 349.0 168.5 24 7.32 4.0 1.22 

Notes: 

1. As discussed with MDEQ, GP excluded fugitive-only and woodyard chip/bark/wood transfer 

cyclones from the BART modeling inventory. Combined, these sources described in the air 

permit collectively emit a maximum of 3.8 lbslhr of PM. 

2. Recovery Boilers 1 and 2 are modeled with 2 stacks each. Smelt Tanks 1 and 2 have two 

identical stacks each, and'are modeled with one representative stack for each tank. 

P:M& & W~~~~\A~\BAR~M~~~ICCIIO\CALPUF~CP Monhicella MS BART Applicnhlltty Analysts Repon (2007-09-07, Update) doc 4 
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September 7,2007 

Figure 1. Aerial Photo Of Vicinity of GP Monticello Mill 

ijoo 776'000 77Sjoo 777000 777500 77aooo 

UTM East (rn) NA027 Zone 15 

P-\AN & Waar\Anr\BARnMont~uellD\CALPuFnGP Monucellu MS BART Appl~cability Analysis Repln (2007-09-07, Updale) doc 5 
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Table 2. Maximum 24-hour Permitted Emissions, Monticello Mill BART Emission Units 

Emissions Existing Maximum Emission Rates (lbhr) 

Unit 

RB 1 

RB2 

RB3 

RB4 

UT3 (CB) 

UT4 (PB) 

UT5 (e) 

UT6 

LK 

Control 

Equipment SOz HzSOdb) NO, PMlo Speciated? 

ESP 

ESP 

ESP 

ESP 

LNB 

FGR 

Scrubber 

Scrubber 

Scrubber 

204.2 2.55 

204.2 2.55 

204.2 2.55 

204.2 2.55 

12.8 (a) 0.6 

0.46 0.0 

13 0 

13 0 

41.6 2.5 

97.24(d) Yes 

97.24(d) Yes 

97.24(d) Yes 

97.24(d) Yes 

91.7 Yes 

3.8 Yes 

11.6 No 

11.6 No 

29.8 Yes 

ESP = Electrostatic Precipitator; LNB = Low NOx Burners; FGR = Flue Gas Recirculation 

CB = Combination Boiler; PB = Power Boiler 

Emission rates are permit limits except where noted. 

Notes: 

(a) SOr emission rates reflect 2005 source testing. UT3 no longer has the capability of burning 

residual oil, the emission rate of 12.8 lbshr reflect the highest emission rate of fuels in actual 

use. 

(b) Permit does not limit H2SO4 emissions. 

(c) Stack test for actual NOx emissions report values of approximately 0.15-0.18 lbsA4MBtu. he 

analysis applied the AP-42 emission factor of 0.2 1bslMMBtu to compute a worst-case value of 

183.5 lbsh. 

(d) Permit contains multiple limits, most restrictive PMlo limit for RBI-RB4 is 0.044 grldscf @8% 

which is less than the modeled emission rate. 

(e) UT5 reflects emissions of both UTSL and UTSR 

Speciated emissions were developed using industry-estimated guidance by National 

Council for Air & Stream Improvement. 

Figure 2 presents a regional map showing the Monticello Mill and all PSD Class I Areas 

within 300 km. Breton NWR is located approximately 202 km from the Mill. The next 

nearest PSD Class I area is over 385 km from the Mill. Only Breton NWR was evaluated 

in the impact analyses. 

P:Ms & W~IerMlr\BAR'I\Monlicello\CALPUFF\GP Moniicrlla MS BART Applicability Adysls Rrporl(2007-09-07. Updaleldoc 6 
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September 7, 2007 

Figure 2. GP Monticello Mill Location and PSD Class I Areas Within 300 km 

-~GP Monticello Mill 

+Breton NWR 

I I I I I 

500000 600000 700000 800000 900000 

UTM East (m) NAD27 Zone 15 

P \Ax & Waler\Au\BAR~Manr~ceUo\CALPUFRGP Monttcellu MS BART Appl~cahd!ly Anrlyau Repan (2W7-09-Ui UpdaLe) doc 7 
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3.0 VISTAS CONTRIBUTION TO CALPUFF MODELING 

For this application of BART Exemption Modeling, VISTAS is providing the technical 

data through the support of a Technical Contractor. 

VISTAS provided updates and supporting information concerning the VISTAS BART 

Modeling Protocol on the VISTAS website. In addition, VISTAS made the following 

data bases developed by VISTAS Technical Contractor publicly available: 

VISTAS version of the CALPUFF modeling system, maintained on the Earth 

VISTAS Technical Contractor website, 

Regional 12-km CALMET output files for 2001, 2002, and 2003 for screening 

analyses. 

Five subregional 4-km CALMET output files for 2001,2002, and 2003 for 

refined analyses. 

File with CALPUFF model configuration and settings sufficient to replicate 

CALPUFF modeling done for VISTAS using 12 km CALMET, including 

o Ozone data used to run CALPUFF 

o Ammonia data used to run CALPUFF and to partition NO3 in 

POSTUTIL. 

o Background concentrations files for use in POSTUTIL 

o All other set up files used in VISTAS 12-km CALPUFF run 

4.0 MODEL DISCUSSION 

4.1 Exemption Procedures 

For determining if a BART-eligible source is subject to a full BART engineering 

analysis, GP utilized a single refined-level approach. For all visibility modeling, 

CALPUFF was used with 4-km grid CALMET. 

For finer grid (4 km or less) analyses, the 98th percentile impact value for the 24-hour 

average is used, represented as either the 8th-highest day in each year or the 22nd-highest 

day in the 3-year period, whichever is more conservative, for comparison to the 

exemption threshold. 

The analysis uses the same model assumptions for pre-BART visibility impact and for 

BART control options modeling: establish baseline visibility from the pre-BART run; 

change one control at a time; and evaluate the change in visibility impact, i.e. the deltadeciview. Note that "no control" may constitute BART. 

P:\Air & Walrr\A"WARnMunrlcrllo\CALPUFhGP Monlicrlla MS BART Appl~cahdry Analysis Reporl(2007-09-CV. Up&~e).duc 8 
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September 7,2007 

The VtSTAS BART Modeling Protocol consistently recommends conservative 

assumptions. Individual States ultimately have responsibility to determine which, if any, 

BART controls are recommended in their State Implementation Plans (SIPS). The 

VISTAS protocol presents additional detailed information on the meteorological fields, 

and specific settings for CALPUFF and CALPOST (see section 4.33 of the VtSTAS 

BART Modeling Protocol). 

4.2 CALPUFF Configuration 

Source emissions should be defined using the maximum 24-hour actual emission rate 

during normal operation for the most recent 3 or 5 years. If maximum 24-hour actual 

emissions are not available, continuous emissions data, permit allowable emissions, 

potential emissions, and emissions factors from AP-42 source profiles may be used as 

available. Specific configuration settings presented in the VISTAS Common Modeling 

Protocol are listed below: 

Use default data provided by VISTAS for background concentrations of SO4 and 

total NO3 (HN03 + NO3). 

Use hourly ozone data as the background ozone input as prepared by VISTAS. 

Use the Pasquill-Gifford dispersion method. 

In CALPOST, use Method 6 with monthly average RH for calculating extinction, 

as recommended by the EPA. 

Use EPA default calculations of light extinction under average background 

conditions. 

The major features and options of the meteorological and dispersion model are 

summarized and discussed in the VISTAS BART Modeling Protocol. 

As also discussed in the VISTAS BART Modeling Protocol, CALPUFF is currently not 

recommended for addressing visibility impacts from VOC because its capability to 

simulate secondary organic aerosol formation from VOC emissions is not adequately 

tested, especially for anthropogenic emissions. (Separately, condensable organic carbon 

can be calculated from PMlo.) 

Georgia-Pacific completed the refined analysis with the Domain #1 4-krn meteorological 

datasets provided by VISTAS. Figure 3 presents the modeling domain, the Class I Area 

model receptors and Monticello Mill. 

P:Mr & W~~~~MI~\BAR~M~~~~~~II~\CALPUF~GP Monticrllo MS BART Applicdbhty Analysis Repn (2007-09-07, Updace).dnc 9 
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September 7,2007 

LCC Origin: 40N, 97W 

Figure 3. Modeling Domain for Monticello Mill BART Exem~tion An 

500 600 700 800 900 

LCC East (km) 

False Easting: 0 

False Northing: 0 

Datum: NWS-84 

Terra~n (rn) 

- 

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September 7, 2007 

5.0 RESULTS AND DETERMINATION OF IMPAIRMENT 

5.1 Impact Threshold 

The final BART guidance recommends a threshold value of 0.5 dv change from natural 

conditions to define whether a source "contributes" to visibility impairment (although 

states may set a lower threshold). The 98th percentile (8th-highest annual) 24-hour 

average predicted impact at the Class I area, as calculated using CALPOST Method 6 

(monthly average relative humidity values), is to be compared to this contribution 

threshold value. For this comparison, the predicted impact at the Class I area on any day 

is taken to be the highest 24-hour average impact at any receptor in the Class I area on 

that day. (Note that the receptor where the highest impact occurs can change from day to 

day.) According to clarification of the BART guidance received from EPA, for a threeyear simulation the modeling values to be compared with the threshold are the greatest of 

the three annual 8'-highest values or the 22"*-highest value over all three years 

combined, whichever is greater. CALPUFF presents the visibility change in both a 

percent change and a "delta-dv" form. 

5.2 Presentation of Modeling Results 

Table 3 summarizes the CALPOST result for the 98th percentile predicted visibility 

change (dv) for each year at Breton. In addition to the highest change in deciview value 

on each day over all the receptors in a particular Class I area, the CALPOST summary 

table in the CALPOST list files contain the coordinates of the receptor, receptor type (D 

indicates discrete receptors), the total haze level (background + source, in dv), the 

background haze in deciviews, the change in haziness (delta dv), the humidity term 

applied to hygroscopic aerosols (KRH)), and the contribution of each species to light 

extinction (in percent of the total source contribution) for SO4, NOs, organics, elemental 

carbon, coarse and fine particulate matter. 

As shown, the 98th-percentile predicted impact for each meteorological data year is below 

the 0.5 dv change criteria. This result confirms GP's determination that the Monticello 

Mill is not subject to BART because it does not contribute to visibility impairment at 

Breton. 

P \As & W~L~AALC~BAR~M~~~~~~IO\CALPUFF\GP Monticrllo MS BART Appllcab~hty Analysis Repun (2007-09-07, UpdaLe).doc 1 1 
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Table 3. Maximum Estimated Visibility Impacts at Breton for 2001-2003 

attributable to Georgia-Pacific's Monticello Mill using the default IMPROVE 

light extinction algorithm 

Delta deciview 

2001 2002 2003 

1" High 0.803 0.770 0.688 

2nd High 0.429 0.528 0.655 

31d High 0.386 0.358 0.507 

4th High 0.373 0.342 0.388 

5th High 0.363 0.341 0.376 

6th High 0.357 0.339 0.364 

7th High 0.354 0.300 0.312 

sth High (9sth percentile) 0.329 0.284 0.300 

Since the inception of the BART implementation process, the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) workgroup has proposed a more robust 

equation for calculating background visibility, as described in a report entitled "Revised 

IMPROVE Algorithm for Estimating Light Extinction from Particle Speciation Data" 

(http://vista.cira.colostate.edu/IMPROVE/Publications/GrayLi~gray~literature.htm.) The 

updated algorithm, which has been approved by the IMPROVE Steering Committee and 

is currently undergoing peer review, provides a more refined calculation by including 

visibility impairment due to the following processes: 

Visibility impairment due to different sizes of sulfates, nitrates, and organic 

carbon 

Visibility impairment due to sea salt particles 

Distinct water growth curves (i.e.,fiRH)) for small sulfates and nitrates, large 

sulfates and nitrates, and sea salt 

Elevation-dependent (hence Class I area dependent) Rayleigh scattering 

coefficient 

Visibility impairment due to gaseous nitrogen dioxide (NO2) 

The revised IMPROVE light extinction algorithm takes the following form: 

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September 7, 2007 

For the purposes of calculating current, future, and natural background visibility at 

Class I areas as part of its reasonable progress analyses, VISTAS intends to present 

regional air quality modeling results using both the default and the newly revised 

IMPROVE light extinction formula. Values for the parameters listed above specific to 

the natural background conditions at the Class I areas considered in this analysis are 

provided on an annual average basis in the U.S. EPA's Guidance for Estimating Natural 

Visibility Conditions under the Regional Haze Rule. 

To facilitate the use of the revised IMPROVE algorithm for assessing BART 

applicability, the VISTAS Technical Advisor developed and distributed a spreadsheet 

processing tool to implement the revised IMPROVE light extinction algorithm, 

designated as the CALPOST-IMPROVE Processor Version 2 (December 9, 2006). This 

processor calculates the reconstructed light extinction using the revised IMPROVE 

algorithm and output from the current version of the CALPOST postprocessor. To 

implement the CALPOST-IMPROVE Processor, three additional data points are 

required: background concentration of gaseous NO2, Rayleigh scattering parameter 

corrected for site-specific elevation, and an estimate of the average background sea salt 

aerosol concentration. The following specific inputs to the tool were used to estimate 

visibility impacts at Breton: 

Elevation-dependent Rayleigh scattering coefficient of I I ~m-' as tabulated 

in the VISTAS spreadsheet 

Conservative representation of background sea salt concentration as 0 pg/m3 

to represent an unknown quantity 

24-hour average NO2 concentration at each receptor attributable to BARTeligible sources at Georgia-Pacific's Monticello Mill as calculated by 

additional CALPOST analyses 

Although other anthropogenic (stationary and mobile) sources contribute to background 

levels of NO2 at Class I areas, for the purposes of this analysis, the background NO2 

concentration is assumed to be attributable only to BART-eligible sources at GeorgiaPacific's Monticello Mill. The 24-hour average NO2 concentration for each day and 

receptor was calculated by separate CALPOST processing analyses, and converted from 

units of pg/m3 (default model output) to parts per billion as required by the tool. The 

NO2 concentration entered into the CALPOST-IMPROVE Processor for each 24-hour 

average visibility impacts corresponds to the specific day and receptor at which the 

modeled visibility impact occurs. The N02/NOx ratio was conservatively entered as 1.0 

in the CALPOST-IMPROVE Processor. Copies of the CALPOST-IMPROVE 

spreadsheets used in this analysis are included on the electronic media enclosed with this 

report. Table 4 summarizes the estimated impacts attributable to Georgia-Pacific's 

Monticello Mill as calculated using the revised IMPROVE light extinction algorithm. 

P.\Aa & Waler\AHBARnMontiaello\CALPUFnGP Monticelk, MS BART Applicabilily Analysis Repon (2007-09-07. Updnte1.d~ I3 
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Table 4. Maximum Estimated Visibility Impacts at Breton for 2001-2003 

attributable to Georgia-Pacific's Monticello Mill using the revised IMPROVE light - 

extinction algorithm 

Delta deciview 

2001 2002 2003 

lqt High 0.679 0.680 0.616 

2nd HG~ 0.379 0.437 0.573 

3'd High 0.333 0.308 0.425 

4Ih High 0.312 0.291 0.325 

5th High 0.311 0.292 0.318 

fjth High 0.302 0.292 0.307 

7'h High 0.293 0.260 0.268 

gth High (9gth percentile) 0.290 0.239 0.266 

The results of the visibility analysis using the CALPOST-IMPROVE processor and 

revised IMPROVE light extinction algorithm affirm Georgia-Pacific's conclusion that the 

Monticello Mill is exempt from BART because the BART-eligible emission units at the 

mill neither cause nor contribute to visibility impairment at any Class I area. 

P.\Ak & WalerVlirWARnhtonLiceIIo\CALPUFnGP Mnticello MS BART Appiicabrlity Analysis Repon (2007-09-07, U+te).doc 14 
Appendix L.2.6 

STATE OF MISSISSIPPI 

tturrBAulom 

ChmNOR 

MISSISSIPPI DEPARTMENT OF ENVIRONMENTAL QUMSrY 

'IhnnD.Ptam,EwamnDmJcluR 

October 2,2007 

Tim Jones 

Georgia Pacific Corporation 

604 N.A. Sandifer Highway 

Monticello, MS 39654 

Subject: Exemption fiom Best Available Retrofit Technology (BART) Determination Requirements 

Monticello, (1 500)077-00007 

Lawrence, Mississippi 

Dear Mr. Jones: 

Due to the Georgia Pacific - Monticello facility being BART eligible, you were required to 

perform and submit exemption modeling analysis for your eligible units. We have received the 

exemption modeling performed by Mark Aguilar of your company. The modeling finds a 

visibility impact of 0.33 deciviews (dv) which is below the 0.5 dv subjectivity threshold. Based 

on these results, we are proposing that the BART eligible units be exempt from further 

determination requirements. Mississippi Department of Environmental Quality (MDEQ) will 

include documentation of the proposed exemptions in our Regional Haze State Implementation 

Plan (SIP) submittal. The SIP is reviewed and commented on by the Environmental Protection 

Agency (EPA) and other parties with Georgia Pacific - Monticello's exemption contingent on 

EPA's approval. 

If you have any questions regarding this matter, please feel free to contact Elliott Bickerstaff 

(601 -96 1-5 176) or Deborah Boleware (601 -961 -5768) of my staff. 

Sincerely. 

Maya ~az P.E., BCEE 

Chief, Air Division 

OFFICE OF POLLLJTION CONTROL 

POS~O- Box 10385 JMXSON, Mlssm 39U190385 TU (601) %1-5171 Fa (601) 3-12 -dsq-~#