hio 

Ohio Environmental 

Protection Agency 

JUL 2 7 2015 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. 

Chicago, Illinois 60604 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

Re: Additional Information Regarding Ohio's Apri114, 2014 Request for a Revision to Ohio's 

State Implementation Plan (SIP) for Regional Haze- BART Compliance Date for P.H. Glatfelter 

Dear Administrator Hedman: 

On March 1 1 , 201 1, Ohio EPA submitted our Regional Haze SIP to U.S. EPA. Ohio's SIP was 

subsequently approved on July 2, 2012 (77 FR 391 77). Ohio's SIP included the applicability of Best 

Available Retrofit Technology (BART) to Ohio's only BART source, P.H. Glatfelter. Ohio's submittal 

included a compliance date for BART emission reductions of December 31 , 201 4. This compliance 

date was aligned with P.H. Glatfelter's expected compliance date for the Industrial Boiler Maximum 

Achievable Control Technology (MACT) requirements promulgated by U.S. EPA in March of 2011 

and allowed for achievement of BART well before the compliance date required by U.S. EPA's BART 

regulations. Under U.S. EPA's regulations (40 CFR 51.308(3)(1 )(iv)), BART is to be implemented "as 

expeditiously as practicable, but in no event later than 5 years after approval of the implementation 

plan revision." This date is July 2, 201 7. 

On February 6, 201 4, Ohio EPA received a request from P.H. Glatfelter to extend the original BART 

compliance date to January 31, 201 7. This request is based upon the litigation, revision and new 

compliance date associated with the Industrial Boiler MACT (as extended by Ohio EPA). As noted 

above, the original compliance date was designed so that these dates aligned and allowed for P.H. 

Glatfelter to select and implement a control strategy that would address both the MACT and BART 

without unnecessarily burdening them with additional planning, design, time, recourse and money 

constraints. Because the newly requested compliance date still meets U.S. EPA's regulatory 

compliance date deadlines for BART, Ohio EPA was in agreement with this extension. 

After public comment, On April 1 4, 201 4, Ohio EPA submitted a SIP revision request that 

incorporated this change. Subsequently U.S. EPA Region 5 notified Ohio EPA that in order to 

approve the request Ohio EPA would need to explicitly revise the federally enforceable permit 

requirements to incorporate this change. This submittal addresses the request by U.S. EPA Region 

5. 

SO West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

epa.ohio.gov • {614) 644-3020 • {614) 644-3184 {fax) 
On June 6, 201 5, Ohio EPA made available for public comment the revised federally enforceable 

permit. Comments were accepted through July 7, 2015 and no hearing was requested or held. The 

Federal Land Managers were consulted and included in the public comment process. Two comments 

were received and those comments, along with Ohio EPA's responses are included in this submittal. 

We ask that U.S. EPA move forward to approve Ohio EPA's SIP revisions request to extend the 

compliance dates discussed in our April 1 4, 2014 submittal from December 31 , 2014 to January 31, 

201 7. It should be noted, as with our 2001 SIP submittal, this permit contains all requirements, 

including those unrelated to BART. Providing this permit as part of this SIP is not a request to 

incorporate all of the permit requirements into Ohio's SIP. Rather, Ohio EPA recognizes only the 

BART requirements are a part of this SIP. 

This submittal consists of one (1) hard copy of the required documentation. An exact duplicate 

electronic version of the submittal in PDF format is available at 

http://ww.epa.ohio.gov/dapc/SIP/haze.aspx. 

If you have any questions concerning this submittal, please feel free to contact Jennifer Van Vlerah of 

the Division of Air Pollution Control at 61 4-644-3696 or jennifer.vanvlerah@epa.ohio.gov. 

Sincerely, 

Craig W. Butler 

Director 

Enclosures 

cc: Bob Hodanbosi, Ohio EPA, DAPC 

John Summerhays, U.S. EPA 
Attachments 

A. Draft Federally Enforceable Permit 

B. Public Notice 

C. Comments Received 

D. Response to Comments 

E. Final Federally Enforceable Permit 
A. 

Draft Federally Enforceable 

Permit 
!!!!2 

Protection Agency 

61212015 

Kathy Wiedeman 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

P. H. Glatfelter Company - Chillicothe Facility 

232 East 8th Street 

Chillicothe, OH 45601 

RE: DRAFT AIR POLLUTION PERMIT-TO-INSTALL 

Facility ID: 067101 0028 

Permit Number: P01 1 8907 

Permit Type: Administrative Modification 

County: Ross 

Dear Permit Holder: 

Certified Mail 

No TOXIC REVIEW 

No PSD 

No 

No 

Yes 

No 

No 

No 

No 

No 

No 

No 

SYNTHETIC MINOR TO AVOID MAJOR NSR 

GEMS 

MACT/GACT 

NSPS 

NESHAPS 

NETTING 

MAJOR NON-ATTAINMENT 

MODELING SUBMITTED 

MAJOR GHG 

SYNTHETIC MINOR TO AVOID MAJOR GHG 

A draft of the Ohio Administrative Code (OAC) Chapter 3745-31 Air Pollution Permit-to-Install for the referenced facility 

has been issued for the emissions unit(s) listed in the Authorization section of the enclosed draft permit. This draft action 

is not an authorization to begin construction or modification of your emissions unit(s). The purpose of this draft is to solicit 

public comments on the permit. A public notice will appear in the Ohio Environmental Protection Agency (EPA) Weekly 

Review and the local newspaper, Chillicothe Gazette. A copy of the public notice and the draft permit are enclosed. This 

permit can be accessed electronically on the Division of Air Pollution Control (DAPC) Web page, www.epa.ohio.gov/dapc 

by clicking the "Search for Permits" link under the Permitting topic on the Programs tab. Comments will be accepted as a 

marked-up copy of the draft permit or in narrative format. Any comments must be sent to the following: 

Andrew Hall 

Permit Review/Development Section 

Ohio EPA, DAPC 

50 West Town Street, Suite 700 

P.O. Box 1 049 

Columbus, Ohio 43216-1 049 

and Ohio EPA DAPC, Southeast District Office 

2195 Front Street 

Logan, OH 43138 

Comments and/or a request for a public hearing will be accepted within 30 days of the date the notice is published in the 

newspaper. You will be notified in writing if a public hearing is scheduled. A decision on issuing a final permit-to-install 

will be made after consideration of comments received and oral testimony if a public hearing is conducted.Any permit fee 

that will be due upon issuance of a final Permit-to-Install is indicated in the Authorization section. Please do not submit 

any payment now. If you have any questions, please contact Ohio EPA DAPC, Southeast District Office at (740)385-8501. 

Sincerely, 

Michael E. Hopkins, P.E. 

Assistant Chief, Permitting Section, DAPC 

Cc: U.S. EPA Region 5 -Via E-Mail Notification 

Ohio EPA-SEDO; Kentucky 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
PUBLIC NOTICE 

The following matters are the subject of this public notice by the Ohio Environmental Protection Agency. 

The complete public notice, including any additional instructions for submitting comments, requesting 

information, a public hearing, or filing an appeal may be obtained at:http://epa.ohio.gov/actions.aspx or 

Hearing Clerk, Ohio EPA, 50 W. Town St., Columbus, Ohio 4321 5. Ph: 614-644-21 29 

emaii:HCierk@epa.ohio.gov 

Draft Air Pollution Permit-to-Install Administrative Modification 

P. H. Glatfelter Company - Chillicothe Facility 

232 East 8TH St., Chillicothe, OH 45601 

ID#: P01 1 8907 

Date of Action: 6/2/2015 

Permit Desc:Administrative modification to PTI # P01 03673 issued 3/7/201 1 to align compliance date 

for the BART requirements with the approved Boiler MACT compliance date of January 31 , 2017 to 

request to align the compliance date. The request states that this will allow Glatfelter to implement a 

strategy that meets compliance requirements as specified in Boiler MACT and the BART regulations as 

well as meet all regulatory compliance deadlines. 

The permit and complete instructions for requesting information or submitting comments may be 

obtained at: http://epa.ohio.gov/dapc/permitsonline.aspx by entering the ID # or: Christina Wieg, Ohio 

EPA DAPC, Southeast District Office, 2195 Front Street, Logan, OH 431 38. Ph: (740)385-8501 

Public Notice 

Ohio Environmental Protection Agency 

Revision to Ohio's Regional Haze State Implementation Plan 

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, (Ohio EPA) is 

requesting that the United States Environmental Protection Agency (U.S. EPA) revise the current approved 

State Implementation Plan (SIP) for Regional Haze. On March 11, 201 1, Ohio EPA submitted our Regional 

Haze SIP to U.S. EPA. Ohio's SIP was subsequently approved on July 2, 201 2 (77 FR 39177). Ohio's SIP 

included the applicability of Best Available Retrofit Technology (BART) to Ohio's only BART source, P.H. 

Glatfelter. Ohio's submittal included a compliance date for BART emission reductions of December 31, 

2014. This compliance date was aligned with P.H. Glatfelter's expected compliance date for the Industrial 

Boiler Maximum Achievable Control Technology (MACT) requirements promulgated by U.S. EPA in March 

of 2011 and allowed for achievement of BART well before the compliance date required by U.S. EPA's 

BART regulations. Under U.S. EPA's regulations (40 CFR 51.308(3)(1)(iv)), BART is to be implemented 

"as expeditiously as practicable, but in no event later than 5 years after approval of the implementation plan 

revision." This date is July 2, 2017. 

U.S. EPA's Industrial Boiler MACT was subsequently litigated and a final revision was issued by U.S. EPA 

on January 31, 2013 which established a new compliance date for the MACT. On February 6, 2014, Ohio 

EPA received a request from P.H. Glatfelter to extend the original compliance date for BART to January 

31, 201 7 to align the BART compliance with the new compliance date associated with the Industrial Boiler 

MACT (as extended by Ohio EPA). The original compliance date was designed so that these dates 

aligned and allowed for P.H. Glatfelter to select and implement a control strategy that would address both 

the MACT and BART. 

Ohio EPA prepared a draft SIP request for U.S. EPA to revise the approved Regional Haze SIP to allow for 

a compliance date of January 31 , 2017 for BART. A public comment period and hearing were conducted in 

March of 2014. The SIP revision was finalized and submitted to U.S. EPA on Apri114, 2014. U.S. EPA is 

now requesting Ohio EPA revise P.H. Glatfelter's permit to include the compliance date extension and to 

submit the final permit BART requirements as part of Ohio's SIP. 
These actions must be noticed to allow public comment and to satisfy U.S.EPA requirements for public 

involvement in SIP related activities. This notice addresses Ohio EPA's request for U.S.EPA to approve a 

revision of the BART compliance requirements under the Regional Haze SIP. Written comments will be 

received on or before June 2, 2014 at the following: Jennifer. vanvlerah@epa.ohio.gov; or, Jennifer Van 

Vlerah, Ohio EPA, DAPC, P.O. Box 1 049, Columbus, Ohio 4321 6-1 049. Questions may be directed to (614) 

644-3696. 
hio 

Ohio Environmental 

Protection Agency 

DRAFT 

Division of Air Pollution Control 

Perm it-to-1 nstall 

for 

P. H. Glatfelter Company- Chillicothe Facility 

Facility 10: 067101 0028 

Permit Number: P01 1 8907 

Permit Type: Administrative Modification 

Issued: 6/2/2015 

Effective: To be entered upon final issuance 
!!!!2 

Protection Agency 

Division of Air Pollution Control 

Permit-to-Install 

for 

P. H. Glatfelter Company - Chillicothe Facility 

Table of Contents 

Authorization ....... ........................................... ............................................... . ..... .............................................. 1 

A. Standard Terms and Conditions ........... ............ ...................... ....... ............................... .......... ..................... 3 

1. Federally Enforceable Standard Terms and Conditions .... . ..... . ............ . .............. .. . . . ........ . ..... . ............... 4 

2. Severability Clause ............... . ............. .. . .. . . .. . ................. ............... . . . ........ . ............ ........... . . . . ............ . ..... 4 

3. General Requirements . ........................................................................................... ....... ..... . .................. 4 

4. Monitoring and Related Record Keeping and Reporting Requirements .... ............... . .............................. 5 

5. Scheduled Maintenance/Malfunction Reporting . . .............. ....................... . .......... .. ..... . .................. . ........ 6 

6. Compliance Requirements ........................... ........................... ........... . ..... . .... . ................ ........ . .......... . .... 6 

7. Best Available Technology ............................................................................................ ......... ................ 7 

8. Air Pollution Nuisance ... ....... . .... ....... .... .................... . . .......................... ................... ................ ............... 8 

9. Reporting Requirements ...... . . . ... ....................................... ............................... ..... . .............. .................. 8 

1 0. Applicability . . ............... ......................... . ........... ............................. ............ ................ .............. .. .. ..... ...... 8 

11. Construction of New Sources(s) and Authorization to Install ...... ........................ . ...... ........ .................... . 8 

1 2. Permit-To-Operate Application ................................. . . . . . ..... . ......................... . ............... ............. ............. 9 

1 3. Construction Compliance Certification .......... .................................................. .................... ................. 10 

1 4. Public Disclosure ............................................................. ... ....... .................... .......... ............................ 10 

1 5. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission 

Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations ................... 10 

1 6. Fees ... .................................................................. ........... ....... ................................................ ............. . 10 

1 7. Permit Transfers .................. ................. . ................ ... .................................. ................. ............. ......... . . 1 0 

1 8. Risk Management Plans ....................... ........ ........... ........... ............................ .................. ................... 10 

1 9. Title IV Provisions ... ...................................................................................... ..... .................................. 10 

B. Facility-Wide Terms and Conditions .............. . ................ . .......... .................... . . . .......... .......... .......... ............ 11 

C. Emissions Unit Terms and Conditions ....... ............................... ... ............... ............. ...... ..................... . ...... 19 

1. B002, No.7 Boiler ...... .............................................................. ...................................... ...... ................. 20 

2. B003, No. 8 Boiler .. ..................................... ..................................................................... .................... 32 
tlh!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date:To be entered upon final issuance 

Authorization 

Facility ID: 

Facility Description: 

Application Number(s): 

Permit Number: 

Permit Description: 

Permit Type: 

Permit Fee: 

Issue Date: 

Effective Date: 

067101 0028 

Chillicothe Paper Mill. 

M0003371 

P01 1 8907 

Administrative modification to PTI # P01 03673 issued 3/7/2011 to align compliance date for the 

BART requirements with the approved Boiler MACT compliance date of January 31, 2017 to 

request to align the compliance date. The request states that this will allow Glatfelter to 

implement a strategy that meets compliance requirements as specified in Boiler MACT and the 

BART regulations as well as meet all regulatory compliance deadlines. 

Administrative Modification 

$3,000.0000 NOT send payment at this time, subject to change before final issuance 

6/2/2015 

To be entered upon final issuance 

This document constitutes issuance to: 

P. H. Glatfelter Company - Chillicothe Facility 

232 East 8TH St. 

Chillicothe, OH 45601 

of a Permit-to-Install for the emissions unit(s) identified on the following page. 

Ohio Environmental Protection Agency (EPA) District Office or local air agency responsible for processing and 

administering your permit: 

Ohio EPA DAPC, Southeast District Office 

2195 Front Street 

Logan, OH 43138 

(7 40)385-8501 

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to 

Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied 

approval or agreement that, if constructed or modified in accordance with the plans included in the application, the 

emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and 

regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with 

those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits 

to operate (air) or NPDES permits as applicable. 

This permit is granted subject to the conditions attached hereto. 

Ohio Environmental Protection Agency 

Craig W. Butler 

Director 

Page 1 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date: To be entered upon final issuance 

Authorization (continued) 

Permit Number: P01 1 8907 

Permit Description: Administrative modification to PTI # P01 03673 issued 3/7/201 1 to align compliance date 

for the BART requirements with the approved Boiler MACT compliance date of January 

31, 2017 to request to align the compliance date. The request states that this will allow 

Glatfelter to implement a strategy that meets compliance requirements as specified in 

Boiler MACT and the BART regulations as well as meet all regulatory compliance 

deadlines. 

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated 

below: 

Emissions Unit ID: 

Company Equipment ID: 

Superseded Permit Number: 

General Permit Category and Type: 

Emissions Unit ID: 

Company Equipment ID: 

Superseded Permit Number: 

General Permit Category and Type: 

8002 

No.7 Boiler 

P0103673 

Not Applicable 

8003 

No.8 Boiler 

P0103673 

Not Applicable 

Page 2 of 43 
�!!!2 

Protection Agency 

A. 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

Standard Terms and Conditions 

Page 3 of43 
rl!!!� 

Protection Agency 

1. Federally Enforceable Standard Terms and Conditions 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

a) All Standard Terms and Conditions are federally enforceable, with the exception of those listed 

below which are enforceable under State law only: 

(1) Standard Term and Condition A.2.a), Severability Clause 

(2) Standard Term and Condition A.3.c) through A. 3.e)General Requirements 

(3) Standard Term and Condition A.6.c) and A. 6.d), Compliance Requirements 

(4) Standard Term and Condition A.9. , Reporting Requirements 

(5) Standard Term and Condition A.1 0., Applicability 

(6) Standard Term and Condition A.1 1 .b) through A.1 1 .e), Construction of New Source(s) 

and Authorization to Install 

(7) Standard Term and Condition A.1 4., Public Disclosure 

(8) Standard Term and Condition A.15., Additional Reporting Requirements When There 

Are No Deviations of Federally Enforceable Emission Limitations, Operational 

Restrictions, or Control Device Operating Parameter Limitations 

(9) Standard Term and Condition A.1 6., Fees 

(10) Standard Term and Condition A.17., Permit Transfers 

2. Severability Clause 

a) A determination that any term or condition of this permit is invalid shall not invalidate the force or 

effect of any other term or condition thereof, except to the extent that any other term or condition 

depends in whole or in part for its operation or implementation upon the term or condition 

declared invalid. 

b) All terms and conditions designated in parts 8 and C of this permit are federally enforceable as 

a practical matter, if they are required under the Act, or any of its applicable requirements, 

including relevant provisions designed to limit the potential to emit of a source, are enforceable 

by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by 

section 304 of the Act) under the Act. Terms and conditions in parts 8 and C of this permit shall 

not be federally enforceable and shall be enforceable under State law only, only if specifically 

identified in this permit as such. 

3. General Requirements 

a) Any noncompliance with the federally enforceable terms and conditions of this permit 

constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, 

revocation and re-issuance, or modification. 

Page 4 of 43 
!!!!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company- Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

b) It shall not be a defense for the permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

federally enforceable terms and conditions of this permit. 

c) This permit may be modified, revoked, or revoked and reissued, for cause. The filing of a 

request by the permittee for a permit modification, revocation and reissuance, or revocation, or 

of a notification of planned changes or anticipated n oncompliance does not stay any term and 

condition of this permit. 

d) This permit does not convey any property rights of any sort, or any exclusive privilege. 

e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of 

the Director, upon receipt of a written request and within a reasonable time, any information that 

may be requested to determine whether cause exists for modifying or revoking this permit or to 

determine compliance with this permit. Upon request, the permittee shall also furnish to the 

Director or an authorized representative of the Director, copies of records required to be kept by 

this permit. For information claimed to be confidential in the submittal to the Director, if the 

Administrator of the U.S. EPA requests such information, the permittee may furnish such 

records directly to the Administrator along with a claim of confidentiality. 

4. Monitoring and Related Record Keeping and Reporting Requirements 

a) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, 

the permittee shall maintain records that include the following, where applicable, for any 

required monitoring under this permit: 

(1) The date, place (as defined in the permit), and time of sampling or measurements. 

(2) The date(s) analyses were performed. 

(3) The company or entity that performed the analyses. 

(4) The analytical techniques or methods used. 

(5) The results of such analyses. 

(6) The operating conditions existing at the time of sampling or measurement. 

b) Each record of any monitoring data, testing data, and support information required pursuant to 

this permit shall be retained for a period of five years from the date the record was created. 

Support information shall include, but not be limited to all calibration and maintenance records 

and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by this permit. Such records may be maintained in computerized form. 

c) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, 

the permittee shall submit required reports in the following manner: 

(1) Reports of any required monitoring and/or recordkeeping of federally enforceable 

information shall be submitted to the Ohio EPA DAPC, Southeast District Office. 

Page 5 of 43 
!!!!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

(2) Quarterly written reports of (i) any deviations from federally enforceable 

emissionlimitations, operationalrestrictions, 

andcontroldeviceoperatingparameterlimitations, excluding deviations resulting from 

malfunctions reported in accordance with OAC rule 3745-15-06, that have been detected 

by the testing, monitoring and recordkeeping requirements specified in this permit, (ii) 

the probable cause of such deviations, and (iii) any corrective actions or preventive 

measures taken, shall be made to the Ohio EPA DAPC, Southeast District Office. The 

written reports shall be submitted quarterly, by January 31, April 30, July 31 , and 

October 31 of each year and shall cover the previous calendar quarters. See A.15. 

below if no deviations occurred during the quarter. 

(3) Written reports, which identify any deviations from the federally enforceable monitoring, 

recordkeeping, andreportinqrequirements contained in this permit shall be submitted to 

the Ohio EPA DAPC, Southeast District Office every six months, by January 31 and July 

31 of each year for the previous six calendar months. If no deviations occurred during a 

six-month period, the permittee shall submit a semi-annual report, which states that no 

deviations occurred during that period. 

(4) This permit is for an emissions unit located at a Title V facility. Each written report shall 

be signed by a responsible official certifying that, based on information and belief formed 

after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

d) The permittee shall report actual emissions pursuant to OAC Chapter 3745-78 for the purpose 

of collecting Air Pollution Control Fees. 

5. Scheduled Maintenance/Malfunction Reporting 

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with 

paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units or any 

associated air pollution control system(s) shall be reported to theOhio EPA DAPC, Southeast District 

Office in accordance with paragraph (B) of OAC rule 37 45-1 5-06. (The definition of an upset condition 

shall be the same as that used in OAC rule 3745-1 5-06(8)(1) for a malfunction.) The verbal and written 

reports shall be submitted pursuant to OAC rule 37 45-1 5-06. 

Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown 

or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the 

emission unit(s) that is (are) served by such control system(s). 

6. Compliance Requirements 

a) All applications, notifications or reports required by terms and conditions in this permit to be 

submitted or "reported in writing" are to be submitted to Ohio EPA through the Ohio EPA's 

eBusiness Center: Air Services web service ("Air Services"). Ohio EPA will accept hard copy 

submittals on an as-needed basis if the permittee cannot submit the required documents 

through the Ohio EPA eBusiness Center. In the event of an alternative hard copy submission in 

lieu of the eBusiness Center, the post-marked date or the date the document is delivered in 

person will be recognized as the date submitted. Electronic submission of applications, 

notifications or reports required to be submitted to Ohio EPA fulfills the requirement to submit 

the required information to the Director, the appropriate Ohio EPA District Office or contracted 

Page 6 of 43 
!!!!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

local air agency, and/or any other individual or organization specifically identified as an 

additional recipient identified in this permit unless otherwise specified. Consistent with OAC rule 

3745-15-03, the electronic signature date shall constitute the date that the required application, 

notification or report is considered to be "submitted". Any document requiring signature may be 

represented by entry of the personal identification number (PIN) by responsible official as part of 

the electronic submission process or by the scanned attestation document signed by the 

Authorized Representative that is attached to the electronically submitted written report. 

Any document (including reports) required to be submitted and required by a federally 

applicable requirement in this permit shall include a certification by a Responsible Official that, 

based on information and belief formed after reasonable inquiry, the statements in the 

document are true, accurate, and complete 

b) Upon presentation of credentials and other documents as may be required by law, the permittee 

shall allow the Director of the Ohio EPA or an authorized representative of the Director to: 

(1) At reasonable times, enter upon the permittee's premises where a source is located or 

the emissions-related activity is conducted, or where records must be kept under the 

conditions of this permit. 

(2) Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of this permit, subject to the protection from disclosure to the public of 

confidential information consistent with ORC section 3704.08. 

(3) Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under this 

permit. 

(4) As authorized by the Act, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the permit and applicable 

requirements. 

c) The permittee shall submit progress reports to the Ohio EPA DAPC, Southeast District Office 

concerning any schedule of compliance for meeting an applicable requirement. Progress 

reports shall be submitted semiannually or more frequently if specified in the applicable 

requirement or by the Director of the Ohio EPA. Progress reports shall contain the following: 

(1) Dates for achieving the activities, milestones, or compliance required in any schedule of 

compliance, and dates when such activities, milestones, or compliance were achieved. 

(2) An explanation of why any dates in any schedule of compliance were not or will not be 

met, and any preventive or corrective measures adopted. 

7. Best Available Technology 

As specified in OAC Rule 3745-31-05, new sources that must employ Best Available Technology (BAT) 

shall comply with the Applicable Emission Limitations/Control Measures identified as BAT for each 

subject emissions unit. 

Page 7 of 43 
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Protection Agency 

8. Air Pollution Nuisance 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

The air contaminants emitted by the emissions units covered by this permit shall not cause a public 

nuisance, in violation of OAC rule 3745-15-07. 

9. Reporting Requirements 

The permittee shall submit required reports in the following manner: 

a) Reports of any required monitoring and/or recordkeeping of state-only enforceable information 

shall be submitted to the Ohio EPA DAPC, Southeast District Office. 

b) Except as otherwise may be provided in the terms and conditions for a specific emissions unit, 

quarterly written reports of (a) any deviations (excursions) from state-only required emission 

limitations, operational restrictions, and control device operating parameter limitations that have 

been detected by the testing, monitoring, and recordkeeping requirements specified in this 

permit, (b) the probable cause of such deviations, and (c) any corrective actions or preventive 

measures which have been or will be taken, shall be submitted to theOhio EPA DAPC, 

Southeast District Office. If no deviations occurred during a calendar quarter, the permittee 

shall submit a quarterly report, which states that no deviations occurred during that quarter. The 

reports shall be submitted quarterly, by January 31 , April 30, July 31, and October 31 of each 

year and shall cover the previous calendar quarters. (These quarterly reports shall exclude 

deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.) 

10. Applicability 

This Permit-to-Install is applicable only to the em1ss1ons unit(s) identified in the Permit-to-Install. 

Separate application must be made to the Director for the installation or modification of any other 

emissions unit(s)not exempt from the requirement to obtain a Permit-to-Install. 

11. Construction of New Sources(s) and Authorization to Install 

a) This permit does not constitute an assurance that the proposed source will operate in 

compliance with all Ohio laws and regulations. This permit does not constitute expressed or 

implied assurance that the proposed facility has been constructed in accordance with the 

application and terms and conditions of this permit. The action of beginning and/or completing 

construction prior to obtaining the Director's approval constitutes a violation of OAC rule 3745-

31-02. Furthermore, issuance of this permit does not constitute an assurance that the proposed 

source will operate in compliance with all Ohio laws and regulations. Issuance of this permit is 

not to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (or 

other persons) may have against the applicant for starting construction prior to the effective date 

of the permit. Additional facilities shall be installed upon orders of the Ohio Environmental 

Protection Agency if the proposed facilities cannot meet the requirements of this permit or 

cannot meet applicable standards. 

b) If applicable, authorization to install any new emissions unit included in this permit shall 

terminate within eighteen months of the effective date of the permit if the owner or operator has 

not undertaken a continuing program of installation or has not entered into a binding contractual 

Page 8 of 43 
!h!� 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

obligation to undertake and complete within a reasonable time a continuing program of 

installation. This deadline may be extended by up to 12 months if application is made to the 

Director within a reasonable time before the termination date and the permittee shows good 

cause for any such extension. 

c) The permittee may notify Ohio EPA of any emissions unit that is permanently shut down (i.e. , 

the emissions unit has been physically removed from service or has been altered in such a way 

that it can no longer operate without a subsequent "modification" or "installation" as defined in 

OAC Chapter 3745-31) by submitting a certification from the authorized official that identifies the 

date on which the emissions unit was permanently shut down. Authorization to operate the 

affected emissions unit shall cease upon the date certified by the authorized official that the 

emissions unit was permanently shut down. At a minimum, notification of permanent shut down 

shall be made or confirmed by marking the affected emissions unit(s) as "permanently shut 

down" in "Air Services" along with the date the emissions unit(s) was permanently removed 

and/or disabled. Submitting the facility profile update electronically will constitute notifying the 

Director of the permanent shutdown of the affected emissions unit(s). 

d) The provisions of this permit shall cease to be enforceable for each affected emissions unit after 

the date on which an emissions unit is permanently shut down (i.e., emissions unit has been 

physically removed from service or has been altered in such a way that it can no longer operate 

without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31 ) . All 

records relating to any permanently shutdown emissions unit, generated while the emissions 

unit was in operation, must be maintained in accordance with law. All reports required by this 

permit must be submitted for any period an affected emissions unit operated prior to permanent 

shut down. At a minimum, the permit requirements must be evaluated as part of the reporting 

requirements identified in this permit covering the last period the emissions unit operated. 

Unless otherwise exempted,no emissions unit certified by the responsible official as being 

permanently shut down may resume operation without first applying for and obtaining a permit 

pursuant to OAC Chapter 3745-31 and OAC Chapter 3745-77 if the restarted operation is 

subject to one or more applicable requirements. 

e) The permittee shall comply with any residual requirements related to this permit, such as the 

requirement to submit a deviation report, air fee emission report, or other any reporting required 

by this permit for the period the operating provisions of this permit were enforceable, or as 

required by regulation or law. All reports shall be submitted in a form and manner prescribed by 

the Director. All records relating to this permit must be maintained in accordance with law. 

12. Permit-To-Operate Application 

The permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77. The 

permittee shall submit a complete Title V permit application or a complete Title V permit modification 

application within twelve (12) months after commencing operation of the emissions units covered by 

this permit. However, if operation of the proposed new or modified source(s) as authorized by this 

permit would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit 

modification of such new or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 

3745-77-08(C)(3)(d)must be obtained beforeoperating the source in a manner that would violate the 

existing Title V permit requirements. 

Page 9 of 43 
?a!h!2 

Protection Agency 

13. Construction Compliance Certification 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

The applicant shall identify the following dates in the "Air Services"facility profile for each new 

emissions unit identified in this permit. 

a) Completion of initial installation date shall be enteredupon completion of construction and prior 

to start-up. 

b) Commence operation after installation or latest modification date shall be entered within 90 days 

after commencing operation of the applicable emissions unit. 

14. Public Disclosure 

The facility is hereby notified that this permit, and all agency records concerning the operation of this 

permitted source, are subject to public disclosure in accordance with OAC rule 37 45-49-03. 

1 5. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable 

Emission Limitations, Operational Restrictions, or Control Device Operating Parameter 

Limitations 

If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which 

states that no deviations occurred during that quarter. The reports shall be submitted quarterly by 

January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar 

quarters. 

16. Fees 

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 37 45.1 1 

and OAC Chapter 3745-78. The permittee shall pay all applicable permit-to-install fees within 30 days 

after the issuance of any permit-to-install. The permittee shall pay all applicable permit-to-operate fees 

within thirty days of the issuance of the invoice. 

17. Permit Transfers 

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The new 

owner must update and submit the ownership information via the "Owner/Contact Change" functionality 

in "Air Services" once the transfer is legally completed.The change must be submitted through "Air 

Services" within thirty days of the ownership transfer date. 

18. Risk Management Plans 

If the permittee is required to develop and register a risk management plan pursuant to section 112(r) of 

the Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall comply with the 

requirement to register such a plan. 

19. Title IV Provisions 

Page 10 of 43 
�h!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date: To be entered upon final issuance 

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee 

shall ensure that any affected emissions unit complies with those requirements. Emissions exceeding 

any allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder, 

are prohibited. 

B. Facility-Wide Terms and Conditions 

Page 11 of 43 
�h!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

1. All the following facility-wide terms and conditions are federally enforceable with the exception of those 

listed below which are enforceable under state law only: 

a) None. 

2. Nitrogen Oxides (NOx) Budget Trading Program 

OAC Chapter 3745-1 4 

a) Office of Regulatory Information System Facility Code· 067101 0028 

b) The following regulated non-electrical generating unit is subject to the applicable requirements 

specified in OAC Chapter 3745-14 and the annual NOx allowance allocations listed below: 

. Annual Allowance for 

. Calendar Years 

Emissions Unit 2004 through 2007 

B002 - Boiler #7 

B003 - Boiler #8 

205 

248 

Each emissions unit identified in Section 2.b) above is a NOx budget unit under OAC rule 3745-

1 4-01(C)(1). 

[OAC rule 3745-14-01(C)(1)(a)(i)] 

c) The NOx authorized account representative shall submit a complete NOx budget permit 

application inaccordance with the deadlines specified in paragraphs {B){2) and (B)(3) of OAC 

rule 3745-14-03. The NOxauthorized account representative shall also submit, in a timely 

manner, any supplemental information that theDirector determines is necessary in order to 

review a NOx budget permit application and issue or deny a NOxbudget permit. 

[OAC rules 3745-14-01 (E)(1)(a)(i), 3745-1 4-01(E)(1)(a){ii), and 3745-14-03(B)(1)] 

d) Beginning May 31, 2004, the owners and operators of each NOx budget source and each NOx 

budget unit at thesource shall hold NOx allowances available for compliance deductions under 

paragraph (E) of OAC rule3745-1 4-06, as of the NOx allowance transfer deadline, in the unit's 

compliance account and the source'soverdraft account in an amount not less than the total NOx 

emissions for the control period from the unit, asdetermined in accordance with OAC rule 37 45-

1 4-08, plus any amount necessary to account for actual utilizationunder paragraph (C)(5) of 

OAC rule 3745-14-05 for the control period. 

[OAC rules 3745-14-01 (E)(3)(a) and 3745-14-01 (E)(3){c)] 

e) NOx allowances shall be held in, deducted from, or transferred among NOx allowance tracking 

system accountsin accordance with OAC rules 3745-14-05, 3745-14-06, 3745-14-07, and 3745-

1 4-09. 

Page 12 of 43 
�!!!2 

Protection Agency 

[OAC rule 3745-14-01(E)(3)(d)] 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

f) A NOx allowance shall not be deducted, in order to comply with the requirement under 

paragraph (E)(3)(a) ofOAC rule 3745-14-01, for a control period in a year prior to the year for 

which the NOx allowance was allocated. 

[OAC rule 3745-14-01(E)(3)(e)] 

g) Each ton of NOx emitted in excess of the NOx budget emission limitation, as defined in OAC 

rule3745-1 4-01 (B)(2)(yy), shall constitute a separate violation of OAC Chapter 3745-14, the 

Clean Air Act, andapplicable Ohio law. The owners and operators of a NOx budget unit that has 

excess emissions in any controlperiod shall surrender the NOx allowances required for 

deduction under paragraph (E)(4)(a) of OAC rule3745-14-06 and pay any fine, penalty, or 

assessment or comply with any other remedy imposed under paragraph(E)(4)(c) of OAC rule 

3745-14-06. 

[OAC rules 3745-14-01(E)(3)(b), 3745-14-01(E)(4)(a) and 3745-14-01(E)(4)(b)] 

h) When recorded by the Administrator pursuant to OAC rules 3745-14-06 and 3745-14-07, every 

allocation,transfer, or deduction of a NOx allowance to or from a NOx budget unit's compliance 

account or the overdraftaccount of the source where the unit is located is deemed to amend 

automatically, and become a part of, anyNOx budget permit of the NOx budget unit by operation 

of law without any further review. 

[OAC rule 3745-14-01(E)(3)(h )] 

i) Except as provided below, the Director shall revise the NOx budget permit, as necessary, in 

accordance withOAC rule 3745-77-0S.Each NOx budget permit is deemed to incorporate 

automatically the definitions of terms under paragraph (B) ofOAC rule 3745-1 4-01 and, when 

recorded by the Administrator, in accordance with OAC rules 3745-14-06 and3745-1 4-07, every 

allocation, transfer, or deduction of a NOx allowance to or from the compliance accounts ofthe 

NOx budget units covered by the permit or the overdraft account of the NOx budget source 

covered by thepermit. 

[OAC rules 3745-14-03(D)(2) and 3745-14-03(E)(1 )] 

j) The owner or operator of a NOx budget unit shall comply with the prohibitions under OAC rule 

3745-14-08(A)(5). 

[OAC rule 3745·14-08(A)(5)] 

k) The owners and operators of the NOx budget unit shall keep on site at the source each of the 

followingdocuments for a period of five years from the date the document is created: (This 

period may be extended forcause, at any time prior to the end of five years, in writing by the 

Director or Administrator.) 

(1) the account certificate of representation for the NOx authorized account representative 

for the NOx budgetunit and all documents that demonstrate the truth of the statements in 

the account certificate of representation,in accordance with paragraph (D) of OAC rule 

3745-14-02, provided that the certificate and documents shall beretained on site at the 

Page 13 of 43 
!h!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date: To be entered upon final issuance 

source beyond such five-year period until such documents are superseded because of 

thesubmission of a new account certificate or representation changing the NOx 

authorized account representative; 

(2) all emission monitoring information, in accordance with OAC rule 3745-14-08; 

(3) copies of all reports, compliance certifications, and other submissions and all records 

made or required underthe NOx budget trading program; and 

(4) copies of all documents used to complete a NOx budget permit application and any 

other submission underthe NOx budget trading program or to demonstrate compliance 

with the requirements of the NOx budget tradingprogram. 

[OAC rule 37 45-14-01 (E)(5)(a)(i) through (iv)] 

I) The permittee shall operate and maintain equipment to continuously monitor and record 

nitrogen oxidesemissions from these emissions units in units of the applicable standard(s). Such 

continuous monitoring andrecording equipment shall comply with the requirements specified in 

40 CFR Part 75. 

Each continuous monitoring system consists of all the equipment used to acquire data and 

includes the sampleextraction and transport hardware, sample conditioning hardware, 

analyzers, and data recording/processinghardware and software. This includes all systems 

required to monitor the NOx emission rate, NOx concentration, heat input rate, and stack flow 

rate, in accordance with 40 CFR Parts 75.71 and 75.72. 

The permittee shall comply with the initial and re-certification procedures of 40 CFR Part 75. 

The permittee shallmaintain on-site documentation from the USEPA or the Ohio EPA that the 

continuous nitrogen oxidesmonitoring system has been certified in accordance with 40 CFR 

Part 75. The letter of certification shall bemade available to the Director upon request. 

The permittee shall maintain records of the following data obtained by the continuous nitrogen 

oxides monitoringsystem: emissions of nitrogen oxides in lb/millionBtu actual heat input on an 

hourly average basis, emissions ofnitrogen oxides in lbs/hr, results of daily zero/span calibration 

checks, and magnitude of manual calibrationadjustments. 

Whenever the monitoring system fails to meet the quality assurance or data validation 

requirements of 40 CFRPart 75, data shall be substituted using the applicable procedures in 

Subpart D, Appendix D, or Appendix E of40 CFR Part 75. 

[OAC rules 3745-14-01 (E)(2)(a), 37 45-14-01 (E)(5)(a)(ii), 37 45-14-08(A)(2)(a) through (A)(2)(d), 

37 45-14-08(8)(1 ),and 37 45-1 4-08(C)(1 )] 

m) The permittee shall comply with the monitoring plan requirements of 40 CFR Part 75.62, except 

that themonitoring plan shall also include all of the information required by Subpart H of 40 CFR 

Part 75. 

[OAC rule 3745-14-08(E)(2)(a)] 

Page 14 of 43 
fh!� 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

n) The NOx authorized account representative of the N Ox budget unit shall submit the reports and 

compliancecertifications required under the NOx budget trading program, including those under 

OAC rules 3745-14-04 and3745-1 4-08, to the Director and Administrator. 

[OAC rule 3745-14-01(E)(5)(b)] 

o) Each submission under the NOx budget trading program shall be submitted, signed, and 

certified by the NOxauthorized account representative for each NOx budget source on behalf of 

which the submission is made. Eachsuch submission shall include the following certification 

statement by the NOx authorized account representative: 

"I am authorized to make this submission on behalf of the owners and operators of the NOx 

budget sources orNOx budget units for which the submission is made. I certify under penalty of 

law that I have personallyexamined, and am familiar with, the statements and information 

submitted in this document and all itsattachments. Based on my inquiry of those individuals with 

primary responsibility for obtaining the information, !certify that the statements and information 

are to the best of my knowledge and belief true, accurate, andcomplete. I am aware that there 

are significant penalties for submitting false statements and information oromitting required 

statements and information, including the possibility of fine or imprisonment." 

If the NOx authorized account representative for a NOx budget unit subject to an acid rain 

emission limitationwho signed and certified any submission that is made under Subpart F or G 

of 40 CFR Part 75 and whichincludes data and information required under OAC rule 3745-14-08 

or Subpart H of 40 CFR Part 75 is not thesame person as the designated representative or the 

alternate designated representative for the unit under 40CFR Part 72, then the submission shall 

also be signed by the designated representative or the alternatedesignated representative. 

[OAC rules 3745-14-02(A)(5) and 3745-14-08(E)(1)(b)] 

p) The NOx authorized account representative shall submit quarterly reports that include all of the 

data andinformation required in Subpart H of 40 CFR Part 75 for each NOx budget unit (or 

group of units using a commonstack) and the data and information in Subpart G of 40 CFR Part 

75. These quarterly excess emission reportsshall be submitted by January 30, April 30, July 30 

and October 30 of each year and shall be submitted in themanner specified in Subpart H of 40 

CFR Part 75 and 40 CFR Part 75.64. 

[OAC rules 3745-14-08(E)(4)(a) and 3745-14-08(E)(4)(c)(i)] 

q) The NOx authorized account representative shall submit to the Administrator a compliance 

certification insupport of each quarterly report based on a reasonable inquiry of those persons 

with primary responsibility forensuring that all of the unit's emissions are correctly and fully 

monitored. The compliance certification shall statethat: 

(1) the monitoring data submitted were recorded in accordance with the applicable 

requirements of OAC rule3745-14-08 and 40 CFR Part 75, including the quality 

assurance procedures and specifications; and 

(2) for a unit with add-on NOx emission controls and for all hours where data are substituted 

in accordance with40 CFR Part 75.34(a)(1), the add-on emission control were operating 

within the range of parameters listed in thequality assurance program under Appendix B 

Page 15 of 43 
!!!!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

of 40 CFR Part 75 and the substitute values do not systematicallyunderestimate the NOx 

emissions. 

[OAC rule 3745-14-08(E)(4)(d)(i) and (ii)] 

r) The NOx authorized account representative for a N Ox budget unit shall submit written notice of 

monitoringsystem certification and re-certification test dates to the Director and the 

Administrator in accordance with 40CFR Part 75.61. The NOx authorized account 

representative shall submit a certification application to theAdministrator, U.S. EPA, Region V 

Office, and the Director within forty-five days after completing all initial orre-certification tests 

required under paragraph (B) of OAC rule 3745-14-08, including the information requiredunder 

Subpart H of 40 CFR Part 75. 

[OAC rules 3745-14-08(D) and 3745-1 4-08(E)(3)] 

s) For each control period in which one or more NOx budget units at a source are subject to the 

NOx budgetemission limitation, the NOx authorized account representative of the source shall 

submit to the Director and theAdministrator, by November 30 of that year, a compliance 

certification report for each source covering all such units. 

The NOx authorized account representative shall include the following elements in the 

compliance certification report, in a format prescribed by the Administrator, concerning each unit 

at the source and subject to the NOxbudget emission limitation for the control period covered by 

the report: 

(1) identification of each NOx budget unit; 

(2) at the NOx authorized account representative's option, the serial numbers of the NOx 

allowances that are tobe deducted from each unit's compliance account under 

paragraph (E) of OAC rule 37 45-14-06 for the controlperiod; 

(3) at the NOx authorized account representative's option, for units sharing a common stack 

and having NOxemissions that are not monitored separately or apportioned in 

accordance with OAC rule 3745-14-08, thepercentage of allowances that is to be 

deducted from each unit's compliance account under paragraph (E)(5) ofOAC rule 37 45-

1 4-06; and 

(4) the compliance certification under paragraph (A)(3) of OAC rule 3745-14-04. 

[OAC rules 3745-14-04(A)(1) and 3745-14-04(A)(2)] 

t) In the compliance certification report under Section 2.s)(4) above, the NOx authorized account 

representativeshall certify, based upon reasonable inquiry of those persons with the primary 

responsibility for operating thesource and the NOx budget units at the source in compliance with 

the NOx budget trading program, whethereach NOx budget unit for which the compliance 

certification is submitted was operated during the calendar yearcovered by the report in 

compliance with the requirements of the NOx budget trading program applicable to theunit, 

including all the following: 

(1) whether the unit was operated in compliance with the NOx budget emission limitation; 

Page 16 of 43 
!!!!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date:To be entered upon final issuance 

(2) whether the monitoring plan that governs the unit has been maintained to reflect the 

actual operation and monitoring of the unit, and contains all information necessary to 

attribute NOx emissions to the unit, in accordance with OAC rule 3745-14-08; 

(3) whether all the NOx emissions from the unit, or group of units (including the unit) using a 

common stack, were monitored or accounted for through the missing data procedures 

and reported in the quarterly monitoring reports, including whether conditional data were 

reported in the quarterly reports in accordance with OAC rule 3745-14-08, and if 

conditional data were reported, the permittee shall indicate whether the status of all 

conditional data has been resolved and all necessary quarterly report submissions have 

been made; and 

(4) whether the facts that form the basis for certification under OAC rule 3745-1 4-08 of each 

monitor at the unitor group of units (including the unit) using a common stack, or for 

using an excepted monitoring method oralternative monitoring method approved under 

OAC rule 3745-14-08, if any, have changed. lf a change is required to be reported under 

Section 2.s)(4) above, specify the nature of the change, the reasonfor the change, when 

the change occurred, and how the unit's compliance status was determined subsequent 

tothe change, including what method was used to determine emissions when a change 

mandated the need formonitor re-certification. 

[OAC rule 3745-14-04(A)(3)] 

u) The NOx authorized account representative shall submit a complete NOx budget permit renewal 

application forthe NOx budget source covering the NOx budget units at the source in 

accordance with paragraph (E) of OACrule 3745-77-08. 

[OAC rule 3745-14-03(B)(3)(a)] 

v) The emission measurements recorded and reported in accordance with OAC rule 3745-1 4-08 

shall be used todetermine compliance by the unit with the NOx budget emission limitation under 

paragraph (E)(3) of OAC rule3745-14-01. 

[OAC rule 3745-14-01(E)(2)(b)] 

w) The permittee shall develop and maintain a written quality assurance/quality control plan for 

each continuousNOx monitoring system designed to ensure continuous valid and representative 

readings of NOx emissions inunits of the applicable standard. The plan shall follow the 

requirements of 40 CFR Part 75, Appendix B. Thequality assurance/quality control plan and a 

logbook dedicated to the continuous NOx monitoring system mustbe kept on-site and available 

for inspection during regular office hours. 

[OAC rules 3745-14-08(A)(2)(c) and 3745-1 4-08(A)(2)(d)] 

Note: Ohio EPA DAPC has completed rule amendments for OAC Chapter 3745-14, specifically OAC rule 

3745-14-01 and OAC rule 3745-1 4-06, to facilitate the transition of the affected units from OAC Chapter 

3745-14 into the federal Clean Air Interstate Rule (CAIR) program and to begin the process of "sunsetting" 

the parts of OAC Chapter 3745-14 which will no longer be needed as a result of Ohio's CAIR rules (OAC 

Chapter 3745-1 09). The revised applicability section of OAC Chapter 3745-14 allows the rules to remain 

available as a backup until court required revisions to the federal CAIR program have been completed. The 

Page 17 of 43 
tlh!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

revision to OAC rule 3745-14-01 (C)(2)(a) requires all affected units to be subject to and meet the 

requirements of Ohio's CAIR program beginning in 2009. Should U.S. EPA eliminate or suspend the CAIR 

program, this revision would require these units to revert back and meet the requirements of OAC Chapter 

3745-14, provided a NOx allowance tracking system is maintained by U.S. EPA. 

Clean Air Interstate Rule - OAC Chapter 3745-109 

The permittee shall ensure that any CAIR NOx, S02, or NOx ozone season units complies with the 

requirements of OAC Chapter 37 45-1 09, which includes submitting timely permit applications. The 

requirements of this rule will be specified in the Title V permit issued to this facility. 

Page 18 of 43 
�!!!� 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date:To be entered upon final issuance 

C. Emissions Unit Terms and Conditions 

Page 19 of 43 
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Protection Agency 

1. 8002, No.7 Boiler 

Operations, Property and/or Equipment Description: 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date:To be entered upon final issuance 

Emissions unitB002 (Boiler No. 7) is a wet bottom, pulverized coal-fired boiler (Combustion 

Engineering model VU-405) having a maximum heat input capacity of 422 million Btu per hour, 

capable of firingnumber 2 fuel oil as backup fuel, and is a backup control device for noncondensable gases (NCG) generated by other facility emissions units. The unit is controlled with 

a cyclone/multi-clone, an electrostatic precipitator(ESP), a low nitrogen oxides concentric firing 

system and a vane close-coupled overfire air compartment (Aistom Power)(Administrative 

modification to PTI # P01 03673 issued 3/7/201 1 to align compliance date for the BART 

requirements with the approved Boiler MACT compliance date of January 31 , 201 7). 

a) The following emissions unit terms and conditions are federally enforceable with the exception 

of those listed below which are enforceable under state law only. 

(1) None. 

b) Applicable Emissions Limitations and/or Control Requirements 

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit 

along with the applicable rules and/or requirements and with the applicable emissions 

limitations and/or control measures are identified below. Emissions from each unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures 

a. OAC rule 3745-31-05(A)(3) See section c)(2) below. 

b. OAC rule 3745-1 7-07(A) Visible particulate emissions from the 

exhaust stack serving emissions units 

B002 and B003 shall not exceed 20% 

opacity as a 6-minute average, except as 

. provided by the rule. 

c. OAC rule 3745-1 7-1 0(C)(1) Particulate emissions shall not exceed 

0.1 0 pound per million Btu of actual heat 

input, when firing coal. The particulate 

emission limitation specified in 40 CFR 

Part 63, Subpart DDDDD for this 

emissions unit, when firing coal, is 

currently more stringent than this 

particulate emission limitation. Unless the 

applicable 40 CFR Part 63, Subpart 

DDDDD emission limitation is revised 

under "reconsideration", after the 

specified compliance date for this 

emissions unit, this particulate emission 

limitation will be less stringent than the 

particulate emission limitation established 

pursuant to Subpart DDDDD. 

Page 20 of 43 
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Protection Agency 

d. 

e. 

f. 

g. 

h. 

i. 

Applicable Rules/Requirements 

OAC rule 3745-1 7-1 0(B)(1) 

OAC rule 3745-18-77(B)(1) 

OAC Chapters 3745-14and 

1 09 

40 CFR Part51 .308(e) 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

Applicable Emissions Limitations/Control 

Measures 

Particulate emissions shall not exceed 

0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel 

oil. The particulate emission limitation 

specified in 40 CFR Part 63, Subpart 

DDDDD for this emissions unit, when 

firing only number 2 fuel oil, is currently 

more stringent than this particulate 

emission limitation. Unless the applicable 

40 CFR Part 63, Subpart DDDDD 

emission limitation is revised under 

"reconsideration", after the specified 

compliance date for this emissions unit, 

this particulate emission limitation will be 

less stringent than the particulate 

emission limitation established pursuant 

to Subpart DDDDD. 

Sulfur dioxide emissions shall not exceed 

9.9 pounds per million Btu actual 

heatinput. After the compliance date 

listed under b)(2)b. below, this emission 

limitation will be less stringent than the 

emission limitation established pursuant 

to 40 CFR Part 51.308(e) (see b)(1 )g. 

below). 

3745- See section b)(2)a. below. 

After the compliance date listed under 

Federally enforceable limitation to b)(2)b. below, sulfur dioxide emissions 

comply with the BART requirements from emissions units B002 and B003, 

of u.s. EPA's Regional Haze combined, shall not exceed 24,930 

Regulations. pounds per calendar dav. 

40 CFR Part 63, Subpart DDDDD See b)(2)c. below. 

Also see 40 CFR Part 63.7500 and Table 

2 to Subpart DDDDD. 

40 CFR Part 63, Subpart A See 40 CFR Part 63.7565 and Table 10 

to Subpart DDDDD for the Applicability of 

General Provisions to this Subpart. 

(2) Additional Terms and Conditions 

a. Refer to Part B. - Facility-Wide Terms and Conditions of the permit for the 

requirements of OAC Chapter 3745-14 "NOx Budget Trading Program in 

Ohio"and OAC Chapter 3745-1 09 "Clean Air Interstate Rule." 

Page 21 of 43 
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Protection Agency 

b. 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

Emissions units B002 and B003 (Boilers No. 7 and No. 8, respectively) are 

subject to the Best Available Retrofit Technology (BART) requirements of the 

U.S. EPA's Regional Haze Regulations (40 CFR Part 51, Subpart P). The 

permittee shall operate and maintain control measures constituting an 

"alternative to BART" that will achieve greater reasonable progress than would 

be achieved through installation and operation of BART, as allowed under 40 

CFR Part 51 .308(e)(2). 

In addition to using a cyclone/multi-clone and an ESP to control the particulate 

emissions, emissions unit B002 (Boiler No. 7) is equipped with an Alstom Power 

low nitrogen oxides (low-NOx) concentric firing systemand a vane close-coupled 

over fire air compartment, which, based upon Ohio EPA's analysis, satisfy the 

BART nitrogen oxides technology requirement. 

The permittee shall achieve the required nitrogen oxides emission reduction by 

not later than January 31, 201 7by routinely employing the Alstom Power lowNOx concentric firing systemand vane close-coupled over fire air compartment, 

on a year-round basis, rather than limiting low-NOx operation to the control 

period (May 1 through September 30) specified in OAC Chapter 3745-1 4. 

The permittee shall achieve the required sulfur dioxide emission reduction, on a 

year-round basis, by not later than January 31, 2017. As part of this "alternative 

to BART," the permittee shall install, operate, and maintain control technology 

sufficient to meet the emissions limitation in section b)(1 )g. This may include an 

add-on control device, use of an alternative fuel, use of low sulfur fuel, 

permanent shutdown of emissions unit B002, or a combination of these 

measures. By no later than January 31, 2017, the permittee shall submit to Ohio 

EPA an application for modification of this federally enforceable permit. The 

application shall include a compliance plan outlining, at a minimum, the specific, 

selected control technologies and methods of compliance; and these 

requirements, along with any appropriate monitoring, recordkeeping, and 

reporting requirements, shall be incorporated into the federally enforceable 

permit by no later than January 31 , 201 7. A continuous emission monitoring 

system (GEMS) shall be installed for this emissions unit by no later than January 

31 , 201 7 to measure and record the daily sulfur dioxide emissions. 

c. This emissions unit will be subject to the applicable requirements specified in 40 

CFR Part 63, Subpart DDDDD when the regulations become effective on 

January 31, 2017. 

c) Operational Restrictions 

(1) The quality of the oil burned in this emissions unit shall meet a sulfur content that is 

sufficient to comply with the allowable sulfur dioxide emission limitation specified in 

section b)(1 )e. above. 

(2) This emissions unit shall not be taken out of service at the same time as both emissions 

units B003 (Boiler No. 8) and B01 3 0JVood Waste Boiler), except during emergency 

outages. Emissions unit B01 3 shall serve as the primary incineration point for highvolume low concentration NCG. Either emissions unit B002 or B003 shall serve as a 

Page 22 of 43 
�h!2 

Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

backup control device for high-volume low concentration NCG combustion. If emissions 

unit 8002 is permanently shutdown, emissions unit 8003 shall serve as the backup 

control device for high-volume low concentration NCG combustion and shall not be 

taken out of service at the same time as emissions unit 8013, except during emergency 

outages. 

d) Monitoring and/or Record keeping Requirements 

(1) The permittee shall operate and maintain equipment to continuously monitor and record 

the opacity of the visible particulate emissions of the combined emissions from 

emissions units 8002 and 8003. Such continuous monitoring and recording equipment 

shall comply with the requirements specified in 40 CFR Part 60.1 3. 

The continuous monitoring system consists of all the equipment used to acquire data 

and includes the data recording/processing hardware and software. 

The permittee shall maintain a letter of certification from the Ohio EPA, Central Office 

documenting that the continuous opacity monitoring system has been certified in 

accordance with the requirements of 40 CFR Part 60, Appendix 8, Performance 

Specification 1. The letter of certification shall be made available to the Ohio EPA, 

Southeast District Office upon request. 

The permittee shall maintain records of the following data obtained by the continuous 

opacity monitoring system: percent opacity on a 6-minute block average basis, results of 

daily zero/span calibration checks, and magnitudes of manual calibration adjustments. 

(2) The permittee shall maintain a written quality assurance/quality control plan for the 

continuous opacity monitoring system designed to ensure continuous valid and 

representative readings of opacity. The plan shall include, as a minimum, conducting 

and recording daily automatic zero/span checks, provisions for conducting a quarterly 

audit of the continuous opacity monitoring system, and a description of preventive 

maintenance activities. The quality assurance/quality control plan must be kept on site 

and available for inspection during regular office hours. 

(3) To obtain an exemption pursuant to OAC rule 3745-1 7-07(A)(3)(a)(i) or (A)(3)(b)(i), the 

permittee shall operate and maintain a temperature monitor and recorder that measures 

and records the temperature of the boiler exhaust gases entering the ESP during (a) all 

periods of start-up until the ESP is operational or until the inlet temperature of the ESP 

achieves the temperature level specified in OAC rule 3745-1 7-07(A)(3)(a)(i) and (b) all 

periods of shutdown until the inlet temperature of the ESP drops below the temperature 

level specified in OAC rule 3745-1 7-07(A)(3)(b)(i). An electronic or hardcopy record of 

the temperatures during periods of start-up and shutdown shall be maintained. 

The temperature monitor and recorder shall be installed, calibrated, operated, and 

maintained in accordance with manufacturer's recommendations, with any modifications 

deemed necessary by the permittee, and shall be capable of accurately measuring the 

temperature of the boiler exhaust gases in units of degrees Fahrenheit. 

(4) The permittee shall maintain monthly records of the total quantity of coal burned, and the 

results of the analyses for ash content, sulfur content, heat content, and the average 

Page 23 of 43 
�!!!� 

Protection Agency 

Draft Permit-to-install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

sulfur dioxide em1ss1on rate (in lbs/million Btu). The coal collection and sampling 

procedures and analyses for ash content, sulfur content, and heat content shall be 

performed in accordance with the following: 

The permittee shall collect monthly composite samples of the coal burned in this 

emissions unit. A sufficient number of individual samples shall be collected so that each 

composite sample is representative of the average quality of coal burned in this 

emissions unit during each calendar month. The coal sampling shall be performed in 

accordance with the most recent version of ASTM method 02234, Collection of a Gross 

Sample of Coal. 

Each monthly composite sample of coal shall be analyzed for ash content (in percent), 

sulfur content (in percent), and heat content (in Btu/pound). The analytical methods for 

ash content, sulfur content, and heat content shall be the most recent version of: ASTM 

method 031 74, Ash in the Analysis of Coal and Coke; ASTM method 03177, Total 

Sulfur in the Analysis Sample of Coal and Coke or ASTM method 04239, Sulfur in the 

Analysis Sample of Coal and Coke Using High Temperature Tube Furnace Combustion 

Methods; and ASTM method 05865, Gross Calorific Value of Coal and Coke, 

respectively. Alternative, equivalent methods may be used upon written approval from 

the Ohio EPA, Southeast District Office. 

The requirements to analyze the sulfur content of the composite coal sample and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this term 

and condition shall terminate on January 31, 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(5) The permittee shall comply with the requirements of one of the following alternatives 

pertaining to the use of number 2 fuel oil: 

a. Alternative 1 : 

For each shipment of oil received for burning in this emissions unit, the permittee 

shall collect or require the oil supplier to collect a representative grab sample of 

oil and maintain records of the total quantity of oil received, the permittee's or oil 

supplier's analyses for sulfur content and heat content, and the calculated sulfur 

dioxide emission rate (in lbs/million Btu). The sulfur dioxide emission rate shall be 

calculated in accordance with the formula specified in OAC rule 3745-1 8-04(F). A 

shipment may be comprised of multiple tank truck loads from the same supplier's 

batch, and the quality of the oil for those loads may be represented by a single 

batch analysis from the supplier. 

b. Alternative 2: 

The permittee shall collect a representative grab sample of oil that is burned in 

this emissions unit for each day when the emissions unit is in operation. If 

additional fuel oil is added to the tank serving this emissions unit on a day when 

the emissions unit is in operation, the permittee shall collect a sufficient number 

of grab samples to develop a composite sample representative of the fuel oil 

Page 24 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

burned in this emissions unit. A representative grab sample of oil does not need 

to be collected on days when this emissions unit is only operated for the purpose 

of "test-firing." The permittee shall maintain records of the total quantity of oil 

burned each day, except for the purpose of test-firing, the permittee's analyses 

for sulfur content and heat content, and the calculated sulfur dioxide emission 

rate (in lbs/million Btu). The sulfur dioxide emission rate shall be calculated in 

accordance with the formula specified in OAG rule 3745-1 8-04(F). 

c. The permittee shall perform or require the supplier to perform the analyses for 

sulfur content and heat content in accordance with 40 GFR Part 60, Appendix A, 

Method 19, or the appropriate ASTM methods (such as, ASTM methods 0240 

and 04294), or equivalent methods as approved by the Director. 

The requirements to analyze the sulfur content of the number 2 fuel oil and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this 

term and condition shall terminate on January 31, 201 7 because the sulfur 

dioxide continuous monitoring system required under section d)(6) and the 

monitoring and recordkeeping provisions for the pounds per million Btu and 

pounds per calendar day emission limitations under section d)(B) become 

effective on that date. 

(6) By not later than January 31 , 2017, the permittee shall install, operate, and maintain 

equipment to continuously monitor and record sulfur dioxide and exhaust gas flow data 

for this emissions unit in units of the applicable standards (pounds per million Btu and 

pounds per calendar day). Such continuous monitoring and recording equipment shall 

comply with the requirements specified in 40 GFR Part 60, Appendix B, Performance 

Specification 6, and be operated in accordance with 40 GFR Part 60.13 unless otherwise 

specified in d)(?) below. 

The permittee shall maintain records of all data obtained by the continuous sulfur dioxide 

and exhaust gas flow monitoring system including, but not limited to, minute-by-minute 

concentration data for sulfur dioxide; minute-by-minute flow data in AGFM; sulfur dioxide 

data in pounds per day; the results of all daily, weekly, and quarterly calibration checks; 

and the magnitude of any calibration adjustments. 

Each continuous emissions monitoring system (GEMS) consists of all the equipment 

used to acquire and record data and includes any sample extraction and transport 

hardware, sample conditioning hardware, analyzers, and data recording/processing 

hardware and software. 

The data recorded by the GEMS shall be used to determine compliance with the 

applicable emission limitations on an ongoing basis. 

(7) By not later than April 31 , 201 6, the permittee shall develop a written quality 

assurance/quality control plan for the continuous sulfur dioxide and exhaust gas flow 

monitoring system designed to meet all requirements as listed in 40 GFR Part 60, 

Appendix F and ensure continuous valid and representative readings of sulfur dioxide 

and flow. The plan shall describe in detail, complete, step-by-step procedures and 

operations for each of the following activities: 

Page 25 of 43 
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Protection Agency 

a. 

b. 

c. 

d. 

e. 

f. 

calibration of CEMS; 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

calibration drift determination and adjustment of GEMS; 

preventive maintenance of GEMS (including spare parts inventory); 

data recording, calculations, and reporting; 

accuracy audit procedures including sampling and analysis methods; and 

program of corrective action for malfunctioning GEMS. 

The permittee shall be required to complete a GEMS certification relative accuracy test 

audit (RATA), in accordance with the procedures specified in 40 CFR Part 60, Appendix 

F, by not later thanJanuary 31, 201 7 . From the date of GEMS certification forward, the 

permittee may forego annual RATA requirements as listed in 40 CFR Part 60, Appendix 

F, by completing a quarterly cylinder gas or relative accuracy audit, in accordance with 

40 CFR Part 60, Appendix F, for each quarter of the year. Should any GEMS not pass a 

cylinder gas or relative accuracy audit on the first attempt for two consecutive quarters 

(even though a recalibration or repair allows the second attempted cylinder gas or 

relative accuracy audit to pass), the permittee shall complete a RATA within 60 days of 

the second quarter's failed cylinder gas or relative accuracy audit. The permittee shall 

also complete a RATA for the GEMS within six months prior to the expiration of this 

permit. RATA testing may also be required if the GEMS as listed on the GEMS 

certification letter from the Ohio EPA, Central Office, or any GEMS associated 

equipment, is changed or modified. 

Beginning on January 31, 201 7, the permittee shall perform daily zero/span calibration 

drift checks on each sulfur dioxide and flow GEMS for 60 consecutive operating days in 

accordance with the requirements specified in 40 CFR Part 60, Appendix F, section 4. 

If, on the first attempt, the results of each daily zero/span calibration drift check are less 

than the criteria for excessive calibration drift specified in 40 CFR Part 60, Appendix F, 

section 4.3 (as determined by the Ohio EPA, Southeast District Office), the permittee 

shall begin performing zero/span calibration drift checks on a weekly basis. If any 

GEMS should fail a weekly zero/span calibration drift check for two consecutive weeks 

(based on the criteria of being two times over the limit as stated in Appendix F, section 

4.3), the permittee shall perform daily zero/span calibration drift checks until such time 

as 60 consecutive daily zero/span calibration drift checks have been successfully 

completed within the criteria specified in Appendix F, section 4.3. 

The quality assurance/quality control plan and a logbook dedicated to the sulfur dioxide 

and flow GEMS must be kept on site and available for inspection during regular office 

hours. 

(8) By not later than January 31, 2017, the permittee shall maintain daily records of the 

following information: 

a. the total sulfur dioxide emissions from this emissions unit based upon the data 

collected in section d)(6), in pounds per million Btu and pounds per calendar day; 

Page 26 of 43 
�!!!2 

Protection Agency 

b. 

c. 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

the total sulfur dioxide emissions from this emissions unit and emissions unit 

8003, combined, based upon the data collected in section d)(6) for each unit, in 

pounds per calendar day; and 

the identification of any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and 

the unit's low-NOx concentric firing systemand vane close-coupled over fire air 

compartment were not operating. 

(9) The permittee shall maintain records for each day when emissions units 8002, 8003, 

and 8013 were all off line and the venting of high-volume low concentration NCG was 

uncontrolled. If emissions unit 8002 is permanently shut down after January 31, 2017, 

the permittee shall maintain records for each day when emissions units 8003 and 801 3 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

e) Reporting Requirements 

(1) The permittee shall submit reports (hardcopy or electronic format) within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting all instances of opacity values in excess of the limitation specified in 

section b)(1 )b. of these terms and conditions, detailing the date, commencement and 

completion times, duration, magnitude (percent opacity), reason (if known), and 

corrective actions taken (if any) of each 6-minute block average above the applicable 

opacity limitations. 

The reports shall also identify any excursions of the start-up and shutdown provisions 

specified in OAC rule 3745-17-07(A)(3) and document any continuous opacity 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason, and 

corrective action taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall be included in the quarterly 

report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the date, time, reason, and corrective action taken 

for each time period of monitoring system malfunction. The total operating time of the 

emissions unit and the total operating time of the analyzer while the emissions unit was 

on line also shall be included in the quarterly report. 

These quarterly excess emission reports shall be submitted by January 31 , April 30, July 

31 , and October 31 of each year, and each report shall address the data obtained during 

the previous calendar quarter. 

(2) The permittee shall submit quarterly deviation (excursion) reports that identify whenever 

a monthly composite sample collected pursuant to section d)(4) above indicates a 

deviation from the allowable sulfur dioxide emission rate. These reports shall be 

submitted in accordance with the reporting requirements specified in the Standard 

Terms and Conditions of this permit. 

Page 27 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(B) become effective on that date. 

(3) The permittee shall notify the Ohio EPA, Southeast District Office in writing of any record 

that shows a deviation of the allowable sulfur dioxide emission limitation based upon the 

calculated sulfur dioxide emission rates from section d)(5) above when firing number 2 

fuel oil. The notification shall include a copy of such record and shall be sent to the Ohio 

EPA, Southeast District Office. These reports shall be submitted in accordance with the 

reporting requirements specified in the Standard Terms and Conditions of this permit. 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(B) become effective on that date. 

(4) The permittee shall submit quarterly deviation (excursion) reports that identify any period 

of time when emissions units B002, B003, and B01 3 were all off line and the venting of 

high-volume low concentration NCG was uncontrolled. If emissions unit B002 is 

permanently shut down after January 31, 2017, the permittee shall submit deviation 

(excursion) reports that identify any period of time when emissions units B003 and B013 

were off line and the venting of high-volume low concentration NCG was 

uncontrolled.These reports shall be submitted in accordance with the reporting 

requirements specified in the Standard Terms and Conditions of this permit. 

(5) Beginning in calendar year 2017, the permittee shall submit reports within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting the date, commencement and completion times, duration, magnitude, 

reason (if known), and corrective actions taken (if any), of all instances of sulfur dioxide 

values in excess of the applicable limitations (pounds per million Btu and pounds per 

calendar day) specified in this permit. 

The reports shall document any continuous sulfur dioxide and exhaust gas flow 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action(s) taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason and 

corrective action(s) taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall also be included in the 

quarterly report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the emissions unit operating time during the 

reporting period and the date, time, reason, and corrective action(s) taken for each time 

period of emissions unit, control equipment, and/or monitoring system malfunctions. The 

total operating time of the emissions unit and the total operating time of the analyzer 

while the emissions unit was on line also shall be included in the quarterly report. These 

Page 28 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

quarterly excess emission reports shall be submitted by January 31, April 30, July 31, 

and October 31 of each year and shall address the data obtained during the previous 

calendar quarter. 

(6) Beginning in calendar year 2017, the permittee shall submit quarterly deviation 

(excursion) reports that identify any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and the 

unit's low-NOx concentric firing system and vane close-coupled over fire air compartment 

were not operating. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

f) Testing Requirements 

(1) Compliance with the emission limitations in section b)(1) of these terms and conditions 

shall be determined in accordance with the following methods: 

a. Emission Limitation: 

Visible particulate emissions from theexhaust stack serving emissions units B002 

and B003 shall not exceed 20% opacity as a 6-minute average, except as 

provided by the rule. 

Applicable Compliance Methods: 

lfrequired, compliance with thisemission limitation shall be demonstrated through 

visible emission observations performed in accordance with 40 CFR Part 60, 

Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-

03(B)(1 ). 

Ongoing compliance with this emission limitation may be demonstrated based 

upon the records required pursuant to section d)(1). 

b. Emission Limitation: 

Particulate emissions shall not exceed 0.10 pound per million Btu of actual heat 

input, when firing coal. 

Applicable Compliance Method: 

If required, compliance with this em1ss1on limitation shall be demonstrated 

through emission tests performed in accordance with 40 CFR Part 60, Appendix 

A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-

03(B)(9). 

c. Emission Limitation: 

Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

Page 29 of 43 
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Protection Agency 

Applicable Compliance Method: 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: To be entered upon final issuance 

Compliance with this emission limitation may be determined by multiplying an 

emission factor of 2.0 pounds of particulates per 1 000 gallons of fuel oil fired by 

the emissions unit's maximum hourly fuel oil firing capacity (1 584 gallons/hr}, 

dividing by the emissions unit's rated heat input capacity (422 million Btu/hr}, and 

dividing by 1 000. This emission factor is specified in U.S. EPA reference 

document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, 

Section 1 .3, Table 1 .3-1 (5/1 0). 

If required, the permittee shall demonstrate compliance with this emission 

limitation through emission tests performed in accordance with 40 CFR Part 60, 

Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 

3745-1 7-03(B)(9). 

d. Emission Limitation: 

Sulfur dioxide emissions shall not exceed 9.9 pounds per million Btu actual heat 

input 

Applicable Compliance Methods: 

When firing fuel oil, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(5). 

When firing coal, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(4). 

On and after installation and operation of the control technologyrequired under 

section b)(2)b. above is complete, compliance with this sulfur dioxide emission 

limitations shall be demonstrated based upon the records required pursuant to 

sectionsd)(6) and d){8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A 

e. Emission Limitation: 

By not later than January 31, 2017, sulfur dioxide emissions from emissions units 

B002 and B003, combined, shall not exceed 24,930 pounds per calendar day. 

Applicable Compliance Method: 

Compliance with this sulfur dioxide emission limitation shall be demonstrated 

based upon the records required pursuant to sections d)(6} and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A 

Page 30 of 43 
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Protection Agency 

g) Miscellaneous Requirements 

(1) None. 

Page 31 of 43 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date: To be entered upon final issuance 
�!!!2 

Protection Agency 

2. 8003, No. 8 Boiler 

Operations, Property and/or Equipment Description: 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: To be entered upon final issuance 

Emissions unit B003 (Boiler No.8) isa wall-fired,pulverized coal-fired boiler (Aistom/Combustion 

Engineering)having a maximum heat input capacity of 505 million Btu per hour, capable of 

firingnumber 2 fuel oil as backup fuel, and is a backup control device for non-condensable 

gases (NCG) generated by other facility emissions units. The emissionsunit is controlled with a 

cyclone/multi-clone, four low-NOx staged-combustion burners (Advanced Combustion 

Technology), and an electrostatic precipitator(Environmental Elements Dry 

Precipitator)(Administrative modification to PTI # P01 03673 issued 317/2011 to align compliance 

date for the BART requirements with the approved Boiler MACT compliance date of January 31, 

2017). 

a) The following emissions unit terms and conditions are federally enforceable with the exception 

of those listed below which are enforceable under state law only. 

(1) None. 

b) Applicable Emissions Limitations and/or Control Requirements 

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit 

along with the applicable rules and/or requirements and with the applicable emissions 

limitations and/or control measures are identified below. Emissions from each unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures 

a. OAC rule 3745-31-05(A)(3) See section c)(2) below. 

b. OAC rule 3745-1 7-07(A) Visible particulate emissions from the 

exhaust stack serving emissions units 

B002 and B003 shall not exceed 20% 

opacity as a 6-minute average, except as 

provided by the rule. 

OAC rule 3745-1 7-10(C)(1) Particulate emissions shall not exceed 

0.10 pound per million Btu of actual heat 

input, when firing coal. The particulate 

emission limitation specified in 40 CFR 

Part 63, Subpart DDDDD for this 

emissions unit, when firing coal, is 

currently more stringent than this 

particulate emission limitation. Unless the 

applicable 40 CFR Part 63, Subpart 

DDDDD emission limitation is revised 

under "reconsideration", after the 

specified compliance date for this 

emissions unit, this particulate emission 

limitation will be less stringent than the 

particulate emission limitation established 

Page 32 of 43 
fh!� 

Protection Agency 

Applicable Rules/Requirements 

OAC rule 3745-17-10(B)(1) 

OAC rule 3745-18-77(B)(1) 

OAC Chapters 3745-14and 

1 09 

40 CFR Part51 .308(e) 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date:To be entered upon final issuance 

Applicable Emissions Limitations/Control 

Measures 

pursuant to Subpart DDDDD. 

Particulate emissions shall not exceed 

0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel 

oil. The particulate emission limitation 

specified in 40 CFR Part 63, Subpart 

DDDDD for this emissions unit, when 

firing only number 2 fuel oil, is currently 

more stringent than this particulate 

emission limitation. Unless the applicable 

40 CFR Part 63, Subpart DDDDD 

emission limitation is revised under 

"reconsideration", after the specified 

compliance date for this emissions unit, 

this particulate emission limitation will be 

less stringent than the particulate 

emission limitation established pursuant 

to Subpart DDDDD. 

Sulfur dioxide emissions shall not exceed 

9.9 pounds per million Btu actual 

heatinput. After the compliance date 

listed under b)(2)b. below, this emission 

limitation will be less stringent than the 

emission limitation established pursuant 

to 40 CFR Part 51 .308(e) (see b)(1)g. 

below). 

3745- See section b)(2)a. below. 

After the compliance date listed under 

Federally enforceable limitation to b)(2)b. below, sulfur dioxide emissions 

comply with the BART requirements from emissions units B002 and B003, 

of u.s. EPA's Regional Haze combined, shall not exceed 24,930 

Regulations. pounds per calendar dav. 

40 CFR Part 63, Subpart DDDDD See b)(2)c. below. 

Also see 40 CFR Part 63.7500 and Table 

2 to Subpart DDDDD. 

40 CFR Part 63, Subpart A See 40 CFR Part 63.7565 and Table 10 

to Subpart DDDDD for the Applicability of 

General Provisions to this Subpart. 

(2) Additional Terms and Conditions 

a. Refer to Part B. - Facility-Wide Terms and Conditions of the permit for the 

requirements of OAC Chapter 3745-14 "NOx Budget Trading Program in 

Ohio"and OAC Chapter 3745-1 09 "Clean Air Interstate Rule." 

Page 33 of 43 
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Protection Agency 

b. 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

Emissions units B002 and B003 (Boilers No. 7 and No. 8, respectively) are 

subject to the Best Available Retrofit Technology (BART) requirements of the 

U.S. EPA's Regional Haze Regulations (40 CFR Part 51, Subpart P). The 

permittee shall operate and maintain control measures constituting an 

"alternative to BART" that will achieve greater reasonable progress than would 

be achieved through installation and operation of BART, as allowed under 40 

CFR Part 51 .308(e)(2). 

In addition to using a cyclone/multi-clone and an ESPto control the particulate 

emissions, emissions unit B003 (Boiler No. 8) is equipped with four Advanced 

Combustion Technology low-NOx staged-combustion burners, which, based 

upon Ohio EPA's analysis, satisfy the BART nitrogen oxides technology 

requirement. 

The permittee shall achieve the required nitrogen oxides emission reduction by 

not later than January 31, 201 7by routinely employing the four Advanced 

Combustion Technology staged-combustion burners in their lowest-NOx mode 

on a year-round basis, rather than limiting low-NOx operation to the control 

period (May 1 through September 30) specified in OAC Chapter 3745-14. 

The permittee shall achieve the required sulfur dioxide emission reduction, on a 

year-round basis, by not later than January 31, 201 7. As part of this "alternative 

to BART," the permittee shall install, operate, and maintain control technology 

sufficient to meet the emissions limitation in section b)(1)g. This may include an 

add-on control device, use of an alternative fuel, use of low sulfur fuel, 

permanent shutdown of emissions unit B002, or a combination of these 

measures. By no later than January 31, 201 7, the permittee shall submit to Ohio 

EPA an application for modification of this federally enforceable permit. The 

application shall include a compliance plan outlining, at a minimum, the specific, 

selected control technologies and methods of compliance; and these 

requirements, along with any appropriate monitoring, recordkeeping, and 

reporting requirements, shall be incorporated into the federally enforceable 

permit by no later than January 31 , 201 7. A continuous emission monitoring 

system (GEMS) shall be installed for this emissions unit by no later than January 

31 , 201 7 to measure and record the daily sulfur dioxide emissions. 

c. This emissions unit will be subject to the applicable requirements specified in 40 

CFR Part 63, Subpart DDDDD when the regulations become effective on 

January 31, 201 7. 

c) Operational Restrictions 

(1) The quality of the oil burned in this emissions unit shall meet a sulfur content that is 

sufficient to comply with the allowable sulfur dioxide emission limitation specified in 

section b)(1)e. above. 

(2) This emissions unit shall not be taken out of service at the same time as both emissions 

units B003 (Boiler No. 8) and 8013 0f'Jood Waste Boiler), except during emergency 

outages. Emissions unit B01 3 shall serve as the primary incineration point for highvolume low concentration NCG. Either emissions unit B002 or 8003 shall serve as a 

Page 34 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P011 8907 

Facility ID: 0671 01 0028 

Effective Date:To be entered upon final issuance 

backup control device for high-volume low concentration NCG combustion. If emissions 

unit 8002 is permanently shutdown, emissions unit 8003 shall serve as the backup 

control device for high-volume low concentration NCG combustion and shall not be 

taken out of service at the same time as emissions unit 801 3, except during emergency 

outages. 

d) Monitoring and/or Record keeping Requirements 

(1) The permittee shall operate and maintain equipment to continuously monitor and record 

the opacity of the visible particulate emissions of the combined emissions from 

emissions units 8002 and 8003. Such continuous monitoring and recording equipment 

shall comply with the requirements specified in 40 CFR Part 60.1 3. 

The continuous monitoring system consists of all the equipment used to acquire data 

and includes the data recording/processing hardware and software. 

The permittee shall maintain a letter of certification from the Ohio EPA, Central Office 

documenting that the continuous opacity monitoring system has been certified in 

accordance with the requirements of 40 CFR Part 60, Appendix 8, Performance 

Specification 1. The letter of certification shall be made available to the Ohio EPA, 

Southeast District Office upon request. 

The permittee shall maintain records of the following data obtained by the continuous 

opacity monitoring system: percent opacity on a 6-minute block average basis, results of 

daily zero/span calibration checks, and magnitudes of manual calibration adjustments. 

(2) The permittee shall maintain a written quality assurance/quality control plan for the 

continuous opacity monitoring system designed to ensure continuous valid and 

representative readings of opacity. The plan shall include, as a minimum, conducting 

and recording daily automatic zero/span checks, provisions for conducting a quarterly 

audit of the continuous opacity monitoring system, and a description of preventive 

maintenance activities. The quality assurance/quality control plan must be kept on site 

and available for inspection during regular office hours. 

(3) To obtain an exemption pursuant to OAC rule 3745-1 7-07(A)(3)(a)(i) or (A)(3)(b)(i), the 

permittee shall operate and maintain a temperature monitor and recorder that measures 

and records the temperature of the boiler exhaust gases entering the ESP during (a) all 

periods of start-up until the ESP is operational or until the inlet temperature of the ESP 

achieves the temperature level specified in OAC rule 3745-1 7-07(A)(3)(a)(i) and (b) all 

periods of shutdown until the inlet temperature of the ESP drops below the temperature 

level specified in OAC rule 3745-1 7-07(A)(3)(b)(i). An electronic or hardcopy record of 

the temperatures during periods of start-up and shutdown shall be maintained. 

The temperature monitor and recorder shall be installed, calibrated, operated, and 

maintained in accordance with manufacturer's recommendations, with any modifications 

deemed necessary by the permittee, and shall be capable of accurately measuring the 

temperature of the boiler exhaust gases in units of degrees Fahrenheit. 

(4) The permittee shall maintain monthly records of the total quantity of coal burned, and the 

results of the analyses for ash content, sulfur content, heat content, and the average 

Page 35 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 010028 

Effective Date: To be entered upon final issuance 

sulfur dioxide em1ss1on rate (in lbs/million Btu). The coal collection and sampling 

procedures and analyses for ash content, sulfur content, and heat content shall be 

performed in accordance with the following: 

The permittee shall collect monthly composite samples of the coal burned in this 

emissions unit. A sufficient number of individual samples shall be collected so that each 

composite sample is representative of the average quality of coal burned in this 

emissions unit during each calendar month. The coal sampling shall be performed in 

accordance with the most recent version of ASTM method 02234, Collection of a Gross 

Sample of Coal. 

Each monthly composite sample of coal shall be analyzed for ash content (in percent), 

sulfur content (in percent), and heat content (in Btu/pound). The analytical methods for 

ash content, sulfur content, and heat content shall be the most recent version of: ASTM 

method 03174, Ash in the Analysis of Coal and Coke; ASTM method 03177, Total 

Sulfur in the Analysis Sample of Coal and Coke or ASTM method 04239, Sulfur in the 

Analysis Sample of Coal and Coke Using High Temperature Tube Furnace Combustion 

Methods; and ASTM method 05865, Gross Calorific Value of Coal and Coke, 

respectively. Alternative, equivalent methods may be used upon written approval from 

the Ohio EPA, Southeast District Office. 

The requirements to analyze the sulfur content of the composite coal sample and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(5) The permittee shall comply with the requirements of one of the following alternatives 

pertaining to the use of number 2 fuel oil: 

a. Alternative 1: 

For each shipment of oil received for burning in this emissions unit, the permittee 

shall collect or require the oil supplier to collect a representative grab sample of 

oil and maintain records of the total quantity of oil received, the permittee's or oil 

supplier's analyses for sulfur content and heat content, and the calculated sulfur 

dioxide emission rate (in lbs/million Btu). The sulfur dioxide emission rate shall be 

calculated in accordance with the formula specified in OAC rule 3745-1 8-04(F). A 

shipment may be comprised of multiple tank truck loads from the same supplier's 

batch, and the quality of the oil for those loads may be represented by a single 

batch analysis from the supplier. 

b. Alternative 2: 

The permittee shall collect a representative grab sample of oil that is burned in 

this emissions unit for each day when the emissions unit is in operation. If 

additional fuel oil is added to the tank serving this emissions unit on a day when 

the emissions unit is in operation, the permittee shall collect a sufficient number 

of grab samples to develop a composite sample representative of the fuel oil 

Page 36 of 43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

burned in this emissions unit. A representative grab sample of oil does not need 

to be collected on days when this emissions unit is only operated for the purpose 

of ''test-firing." The permittee shall maintain records of the total quantity of oil 

burned each day, except for the purpose of test-firing, the permittee's analyses 

for sulfur content and heat content, and the calculated sulfur dioxide emission 

rate (in lbs/million Btu). The sulfur dioxide emission rate shall be calculated in 

accordance with the formula specified in OAG rule 3745-18-04(F). 

c. The permittee shall perform or require the supplier to perform the analyses for 

sulfur content and heat content in accordance with 40 GFR Part 60, Appendix A, 

Method 1 9, or the appropriate ASTM methods (such as, ASTM methods 0240 

and 04294), or equivalent methods as approved by the Director. 

The requirements to analyze the sulfur content of the number 2 fuel oil and to calculate 

the pounds per million Btu sulfur dioxide emission rate pursuant to this term and 

condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(6) By not later than January 31 , 201 7, the permittee shall install, operate, and maintain 

equipment to continuously monitor and record sulfur dioxide and exhaust gas flow data 

for this emissions unit in units of the applicable standards (pounds per million Btu and 

pounds per day). Such continuous monitoring and recording equipment shall comply 

with the requirements specified in 40 GFR Part 60, Appendix B, Performance 

Specification 6, and be operated in accordance with 40 GFR Part 60.13 unless otherwise 

specified in d)(7) below. 

The permittee shall maintain records of all data obtained by the continuous sulfur dioxide 

and exhaust gas flow monitoring system including, but not limited to, minute-by-minute 

concentration data for sulfur dioxide; minute-by-minute flow data in AGFM; sulfur dioxide 

data in pounds per day; the results of all daily, weekly, and quarterly calibration checks; 

and the magnitude of any calibration adjustments. 

Each continuous emissions monitoring system (GEMS) consists of all the equipment 

used to acquire and record data and includes any sample extraction and transport 

hardware, sample conditioning hardware, analyzers, and data recording/processing 

hardware and software. 

The data recorded by the GEMS shall be used to determine compliance with the 

applicable emission limitations on an ongoing basis. 

(7) By not later than April 31, 2016, the permittee shall develop a written quality 

assurance/quality control plan for the continuous sulfur dioxide and exhaust gas flow 

monitoring system designed to meet all requirements as listed in 40 GFR Part 60, 

Appendix F and ensure continuous valid and representative readings of sulfur dioxide 

and flow. The plan shall describe in detail, complete, step-by-step procedures and 

operations for each of the following activities: 

Page 37 of 43 
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Protection Agency 

a. 

b. 

c. 

d. 

e. 

f. 

calibration of GEMS; 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

calibration drift determination and adjustment of GEMS; 

preventive maintenance of GEMS (including spare parts inventory); 

data recording, calculations, and reporting; 

accuracy audit procedures including sampling and analysis methods; and 

program of corrective action for malfunctioning GEMS. 

The permittee shall be required to complete a GEMS certification relative accuracy test 

audit (RATA), in accordance with the procedures specified in 40 CFR Part 60, Appendix 

F, by not later than January 31, 2017. From the date of GEMS certification forward, the 

permittee may forego annual RATA requirements as listed in 40 CFR Part 60, Appendix 

F, by completing a quarterly cylinder gas or relative accuracy audit, in accordance with 

40 CFR Part 60, Appendix F, for each quarter of the year. Should any GEMS not pass a 

cylinder gas or relative accuracy audit on the first attempt for two consecutive quarters 

(even though a recalibration or repair allows the second attempted cylinder gas or 

relative accuracy audit to pass), the permittee shall complete a RATA within 60 days of 

the second quarter's failed cylinder gas or relative accuracy audit. The permittee shall 

also complete a RATA for the GEMS within six months prior to the expiration of this 

permit. RATA testing may also be required if the GEMS as listed on the GEMS 

certification letter from the Ohio EPA, Central Office, or any GEMS associated 

equipment, is changed or modified. 

Beginning on January 31, 2017, the permittee shall perform daily zero/span calibration 

drift checks on each sulfur dioxide and flow GEMS for 60 consecutive operating days in 

accordance with the requirements specified in 40 CFR Part 60, Appendix F, section 4. 

If, on the first attempt, the results of each daily zero/span calibration drift check are less 

than the criteria for excessive calibration drift specified in 40 CFR Part 60, Appendix F, 

section 4.3 (as determined by the Ohio EPA, Southeast District Office), the permittee 

shall begin performing zero/span calibration drift checks on a weekly basis. If any 

GEMS should fail a weekly zero/span calibration drift check for two consecutive weeks 

(based on the criteria of being two times over the limit as stated in Appendix F, section 

4.3), the permittee shall perform daily zero/span calibration drift checks until such time 

as 60 consecutive daily zero/span calibration drift checks have been successfully 

completed within the criteria specified in Appendix F, section 4.3. 

The quality assurance/quality control plan and a logbook dedicated to the sulfur dioxide 

and flow GEMS must be kept on site and available for inspection during regular office 

hours. 

(8) By not later than January 31, 201 7, the permittee shall maintain daily records of the 

following information: 

a. the total sulfur dioxide emissions from this emissions unit based upon the data 

collected in section d)(6), in pounds per million Btu and pounds per calendar day; 

Page 38 of43 
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Protection Agency 

b. 

c. 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date:To be entered upon final issuance 

the total sulfur dioxide emissions from this emissions unit and emissions unit 

8002, combined, based upon the data collected in section d)(6)for each unit, in 

pounds per calendar day; and 

the identification of any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and 

the unit's low-NOx staged-combustion burners were not operating at their lowestNOx mode. 

(9) The permittee shall maintain records for each day when emissions units 8002, 8003, 

and 801 3 were all off line and the venting of high-volume low concentration NCG was 

uncontrolled. If emissions unit 8002 is permanently shut down after January 31 , 201 7, 

the permittee shall maintain records for each day when emissions units 8003 and 801 3 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

e) Reporting Requirements 

(1) The permittee shall submit reports (hardcopy or electronic format) within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting all instances of opacity values in excess of the limitation specified in 

section b)(1 )b. of these terms and conditions, detailing the date, commencement and 

completion times, duration, magnitude (percent opacity), reason (if known), and 

corrective actions taken (if any) of each 6-minute block average above the applicable 

opacity limitations. 

The reports shall also identify any excursions of the start-up and shutdown provisions 

specified in OAC rule 37 45-1 7-07 (A)(3) and document any continuous opacity 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason, and 

corrective action taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall be included in the quarterly 

report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the date, time, reason, and corrective action taken 

for each time period of monitoring system malfunction. The total operating time of the 

emissions unit and the total operating time of the analyzer while the emissions unit was 

on line also shall be included in the quarterly report. 

These quarterly excess emission reports shall be submitted by January 31, April 30, July 

31 , and October 31 of each year, and each report shall address the data obtained during 

the previous calendar quarter. 

(2) The permittee shall submit quarterly deviation (excursion) reports that identify whenever 

a monthly composite sample collected pursuant to section d)(4) above indicates a 

deviation from the allowable sulfur dioxide emission rate. These reports shall be 

submitted in accordance with the reporting requirements specified in the Standard 

Terms and Conditions of this permit. 

Page 39 of43 
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Protection Agency 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date:To be entered upon final issuance 

quarterly excess emission reports shall be submitted by January 31, April 30, July 31, 

and October 31 of each year and shall address the data obtained during the previous 

calendar quarter. 

(6) Beginning in calendar year 201 7, the permittee shall submit quarterly deviation 

(excursion) reports that identify any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and the 

unit's low-NOx staged-combustion burners were not operating at their lowest-NOx mode. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

f) Testing Requirements 

(1) Compliance with the emission limitations in section b)(1) of these terms and conditions 

shall be determined in accordance with the following methods: 

a. Emission Limitation: 

Visible particulate emissions from theexhaust stack serving emissions units B002 

and B003 shall not exceed 20% opacity as a 6-minute average, except as 

provided by the rule. 

Applicable Compliance Methods: 

lfrequired, compliance with thisemission limitation shall be demonstrated through 

visible emission observations performed in accordance with 40 CFR Part 60, 

Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-

03(B)(1). 

Ongoing compliance with this emission limitation may be demonstrated based 

upon the records required pursuant to section d)(1). 

b. Emission Limitation: 

Particulate emissions shall not exceed 0.10 pound per million Btu of actual heat 

input, when firing coal. 

Applicable Compliance Method: 

If required, compliance with this emission limitation also shall be demonstrated 

through emission tests performed in accordance with 40 CFR Part 60, Appendix 

A, Methods 1 through 5 and the procedures specified in OAC rule 3745-17-

03(B)(9). 

c. Emission Limitation: 

Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

Page 41 of 43 
f!!!� 

Protection Agency 

Applicable Compliance Method: 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: To be entered upon final issuance 

Compliance with this emission limitation may be determined by multiplying an 

emission factor of 2.0 pounds of particulates per 1 000 gallons offuel oil fired by 

the emissions unit's maximum hourly fuel oil firing capacity (3504 gallons/hr), 

dividing by the emissions unit's rated heat input capacity (505 million Btu/hr), and 

dividing by 1 000. This emission factor is specified in U.S. EPA reference 

document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, 

Section 1 .3, Table 1 .3-1 (5/1 0). 

If required, the permittee shall demonstrate compliance with this emission 

limitation through emission tests performed in accordance with 40 CFR Part 60, 

Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 

37 45-17 -03(8)(9). 

d. Emission Limitation: 

Sulfur dioxide emissions shall not exceed 9.9 pounds per million Btu actual heat 

input. 

Applicable Compliance Methods: 

When firing fuel oil, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(5). 

When firing coal, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(4). 

On and after installation and operation of the control technologyrequired under 

section b)(2)b. above is complete, compliance with this sulfur dioxide emission 

limitation shall be demonstrated based upon the records required pursuant to 

sectionsd)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

e. Emission Limitation: 

By not later than January 31 , 2017, sulfur dioxide emissions from emissions units 

8002 and 8003, combined, shall not exceed 24,930 pounds per calendar day. 

Applicable Compliance Method: 

Compliance with this sulfur dioxide emission limitation shall be demonstrated 

based upon the records required pursuant to sections d)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

Page 42 of 43 
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Protection Agency 

g) Miscellaneous Requirements 

(1) None. 

Page 43 of43 

Draft Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 0671 010028 

Effective Date: To be entered upon final issuance 
B. 

Public Notice 
The following matters are the subj ect of this public notice by the Ohio 

Environmental Protection Agency . The complete public notice, including any 

additional instructions for submit ting comme nts, reques t ing information, a 

public hearing, or fil ing an appeal may be obtained at: 

http : / /www.epa . ohio. gov/actions . aspx or Hearing Clerk, Ohio EPA, 50 W. Town 

St. P.O. Box 1049, Columbus, Ohio 43216. Ph : 614-644-2129 email : 

HClerk@epa . ohio . gov 

Air Pollution State Implementation Plan 

Date of Action : 0 6/02/2015 

On June 6, 2015 a public not i ce was published in this newspaper two 

items : {1) Revision to Ohio s Regional Haze State Implement ation 

Plan ( S IP) ; and (2) draft Air Pollut ion Permi t-to-Install 

( PTI) admini strative modi fication for P. H. Glatfelter Company ­

Chi llicothe Facility, 232 East 8TH S t ., Chillicothe, OH 45601 ( I D# 

P0118907 ) . The end of the comment period for those act ions was 

incorrect ly identified as June 2, 2014 . Written comments will be 

received on or before July 7, 2015 . Comments on the SIP should be 

directed to : Jenni fer . vanvlerah@epa . ohio . gov; or, Jennifer Van 

Vlerah, Ohio EPA, DAPC, P.O . Box 1049, C olumbus , Ohio 43216 -104 9. Ph : 

(614) 644-3696. The permit and complete instructions for reque s t ing 

information or submitting comro_ents on the draft PTI may be obtained 

at : http : / / epa . ohi o . gov/dapc/permitsonline . aspx by entering the ID # 

or : Christ ina Wieg, Ohio EPA DAPC- SEDO, 2195 Front St, Logan, OH 

43138 . Ph : (740) 385-8501 
The following matters are the s ub j ect of this public notice by the Ohio 

Environmental Protection Agency. The complete public notice, including any 

additional instructions for submitting comment s, requesting i nformat ion, a 

public hearing, or fil ing an appeal may be obtained at : 

http://www.epa . ohio . gov/actions . aspx or Hearing Clerk, Ohio EPA, 50 W. Town 

St . P.O. Box 1049, Columbus, Ohio 43216. Ph : 614-644- 2129 email : 

HClerk@epa . ohio . gov 

Draft Air Pollution Permit-to-Install Administrative Modi fication 

P. H. Glatfelter Company - Chillicothe Facil ity 

232 East 8TH St ., Chi l li cothe , OH 45601 

I D#: P 0 118907 

Date of Action : 6/2/2015 

Permit Des c: Administrative modi fication to PTI # P0103673 i ssued 

3/7/2011 to a l i gn compliance date for the BART requirements with the 

approved Boiler MACT comp l iance date of January 31, 2017 to request 

to align the compliance date . The reque st states that this will 

allow Glatfelter to implement a s trategy that meets comp l iance 

requirements as specified in Boiler MACT and the BART regulations as 

well as meet all regulatory compliance deadline s . 

The permit and complete instructions for requesting information or 

s ubmitting comments may be obtained a t : 

http : / /epa.ohio . gov/dapc /permitsonline . aspx by entering the ID # or: 

Christina Wieg, Ohio E PA DAPC, Southeast District Office, 219 5 Front 

Street, Logan , OH 43138 . Ph: (740) 385-8501 

Public Notice 

Ohio Environmental Protection Agency 

Revision to Ohio' s Regional Haze State Implementation Plan 

Notice is hereby given that the 

Protection Agency, ( Ohio E PA) is 

Director of the Ohio E nviro nmental 

requesting that the United States 

Environmental Protection Agency ( U .S. E PA) revise the current approved 

State Implementation Plan (SIP) for Regional Ha z e . On March 11, 2011, 

Ohio EPA submitted our Regional Haze SIP to U.S. E PA. Ohi o's SIP was 

subsequently approved on July 2, 2012 (77 FR 3917 7 ) . Ohio ' s SIP 

included the app l i cability of Best Avai lable Retrofit Technology 

( BART) to Ohio ' s only BART source , P.H. Glatfelter . Ohio' s s ubmittal 

included a compliance date for BART emiss ion reductions of December 

31, 2014 . This compliance date was al igned with P.H. Glatfelter ' s 

expected compliance 

Control Technology 

March of 2011 and 

date for the I ndustrial Boiler Maximum Achievable 

(MACT) requirements promulgated by U . S. EPA in 

allowed for achievement of BART well before the 
comp l iance date required by U.S. EPA' s BART regulations . Under U.S. 

E PA' s regulations (40 C FR 5 1 . 308 (3) (1) ( iv) ), BART is to be implemented 

"as expeditiously as practi cable, but in no event later than 5 years 

after approval of the implementation plan revis io n ." This date is 

July 2, 2017 . 

U.S. EPA' s Industrial Boiler MACT was subsequently litigated and a 

final revi sion was issued by U.S . E PA on January 31, 2013 which 

e stabl ished a new comp l iance date for the MACT . On February 6, 2014, 

Ohio EPA received a request from P.H. Glatfelter to extend the 

original comp l iance date for BART to January 31, 2017 to a l ign the 

BART comp liance with the new compliance date associated with the 

I ndustrial Boiler MACT (as extended by Ohio E PA) . The original 

comp l iance date was des i gned so that the se dates aligned and allowed 

for P. H. Glatfelter to select and implement a control s trategy that 

would address both the MACT and BART . 

Ohio EPA prepared a draft SIP request for U.S. E PA to revi se the 

approved Regional Haze SIP to al low for a comp l i ance date of January 

31, 2017 for BART . A public comment period and hearing were conducted 

in March of 2014 . The SIP revi sion was finali zed and submitted to 

U.S. E PA on April 14, 2014 . U.S. EPA is now requesting Ohio E PA 

revi se P.H. Glatfelter 's permit to include the compliance date 

extens ion and to submit the final permit BART requirements as part of 

Ohio' s SIP. 

These actions must be noticed to allow public c omment and to s at i sfy 

U.S. E PA requirements for publ ic involvement in SIP related activities . 

This notice addres ses Ohio E PA ' s request for U.S. E PA to approve a 

revi sion of the BART comp l iance requirements under the Regional Haze 

SIP. Written comments will be received on or before June 2, 2014 at 

the fol lowing : Jenni fer . vanvlerah@epa . ohio . gov; or, Jennifer Van 

Vlerah , Ohio EPA, DAPC, P.O. Box 1049, Columbus , Ohio 4321 6-1 049 . 

Que stions may be directed to ( 614) 644-36 96. 
C. 

Comments Received 
July 7, 2015 

Ms. Jennifer Van Vlerah 

Ohio EPA, DAPC 

P.O. Box 1049 

Columbus, Ohio 4321 6-1049 

Via email to Jennifer.vanvlera�.ohio.gov 

Re: Draft Air Pollution Permit-to-Install Administrative Modification to PTI # P0103673 issued 3/7/2011 

for P. H. Glatfelter Company - Chillicothe Facility 

Dear Ms. Van Vlerah, 

Thank you for the opportunity to comment on the Draft Air Pollution Permit-to-Install Administrative 

Modification to PTI # P0103673 issued 3/7/2011 for P. H. Glatfelter Company - Chillicothe Facility 

(Draft Permit). We submit these comments on behalf of NPCA and our members who live near and/or 

recreate in Class I areas that are adversely impacted by haze pollution from the Glatfelter facility, 

including Great Smoky Mountains, Mammoth Cave, and Shenandoah National Parks. We oppose the 

modified compliance date for the implementation of Best Available Retrofit Technology (BART) 

proposed by the Draft Permit, which would allow several years of additional, unnecessary emissions to 

continue to pollute and harm our public lands and nearby communities. 

The public notice's stated purpose of the modification is to "align the BART compliance with the new 

compliance date associated with the Industrial Boiler MACT ... to allow[) for P.H. Glatfelter to select and 

implement a control strategy that would address both the MACT and BART." However, the additional 

time is not necessary and contradicts the statutory requirement that BART be installed "as expeditiously 

as possible." BART could and should have been implemented within the original timeframe. 

The original date for BART compliance included several parts: 1 

1. With regard to nitrogen oxides, a requirement to "routinely employing the Alstom Power lowNOx concentric firing system and vane close-coupled over fire air compartment, on a year-round 

basis, rather than limiting low-NOx operation to the control period (May 1 through September 

30)" by December 31, 2014. 

2. With regard to sulfur dioxide, first, a requirement to submit an application containing "a 

compliance plan outlining, at a minimum, the specific, selected control teclmologies and methods 

of compliance" by December 31, 2013, a year prior to the emission compliance date. 

3. Also with regard to sulfur dioxide, to "achieve the required sulfur dioxide emission reduction, on 

a year-round basis" by December 31, 2014. 

4. A requirement to install a "continuous emission monitoring system (CEMS) ... to measure and 

record the daily sulfur dioxide emissions" by December 31, 201 4. 

The first and last of those requirements - employing equipment that is already installed at the facility, and 

installing a continuous emissions monitor - very clearly do not require any additional time for 

coordination with MACT requirements. These compliance dates should not be changed and to the extent 

that Glatfelter has not already complied with them, the facility is in violation of its federally enforceable 

permit. We ask OEPA not to change the compliance dates for these elements and to ensure that the 

Glatfelter facility is complying with them currently. 

1 See Final Division of Air Pollution Control Permit-to-Install for P. H. Glatfelter Company - Chillicothe Facility, 

3/7/2011, Ohio Regional Haze State Implementation Plan, Appendix H. 
As to the second and third requirements, as noted by OEPA, the final MACT revision was issued by US 

EPA on January 31, 2013. Therefore, Glatfelter had most of a year before it was required to submit its 

plan for achieving emission reductions sufficient to satisfy BART, during which time it could have 

selected a control strategy that complied with both MACT and BART. It is not clear whether Glatfelter 

submitted the application due on December 31, 2013, which was prior to its February 2014 request to 

extend the compliance date. There is no indication that anything in US EPA's revision to the MACT 

requirements actually altered Glatfelter's ability to comply with BART. The change in compliance date 

for MACT did not change the expeditiousness with which BART can be installed. 

We ask that OEPA not change the compliance dates for Glatfelter's application for a sulfur dioxide 

control strategy or for achieving the required emission reductions. However, if OEPA chooses to change 

the dates, it should require the application date a year prior to the emission reduction date (i.e. January 31, 

2016 rather than January 31, 2017), consistent with both logical workflow and the relative timing of the 

original requirements. 

Thank you again for the opportunity to comment on the Draft Permit. 

Sincerely, 

Nathan Miller 

Engineering and Science Manager 

National Parks Conservation Association 

nmiller@npca.org 
Van Vlerah, Jennifer 

From: 

Sent: 

O'Dea, Claire B -FS <cbodea@fs.fed.us> 

Monday, June 08, 2015 2:39 PM 

To: Van Vlerah, Jennifer 

Subject: Revision to Ohio's SIP Approved Regional Haze SIP 

Hi Jennifer, 

Trent Wickman forwarded this email to me. For future reference, I should be included on all future Ohio EPA 

correspondence with FLMs ( PSD, RH SIP revisions, etc.). 

As for the specifics of the P.H. G latfelter permit, thank you for forwarding the draft permit with the updated compliance 

schedule incorporated. As stated in our FLM response to the SIP revision, we recognize that the extension of the BART 

compliance date falls within the timeframe required under the Federal BART rule, and therefore have no formal 

comments on the draft permit. We do still encourage "BART installation and operation as expeditiously as practicable." 

In addition, thank you to alerting us of the P.H. Glatfelter project to convert their boilers to natural gas. We look 

forward to participating and working cooperatively with your staff during that process. 

Thank you again. 

Best, 

Claire O'Dea, PhD 

Air Quality Specialist 

Forest Service 

Eastern Regional Office 

p: 202-205-1686 

c: 919-368-6879 

cbodea@fs.fed.us 

1400 1ndependence Ave, SVV, #1 121 

VVashington, DC 20250 

ww.fs.fed.us 

:="11 

Caring for the land and serving people 

From: Wickman, Trent R -FS 

Sent: Monday, June 08, 2015 1:00 PM 

To: O'Dea, Claire B -FS 

Subject: FW: Revision to Ohio's SIP Approved Regional Haze SIP 

From: Van Vlerah, Jennifer [mailto:Jennifer.VanVIerah@epa.ohio.gov] 

Sent: Monday, June 08, 2015 1 1 :38 AM 

To: Van Vlerah, Jennifer 

Cc: Wickman, Trent R -FS; tim allen@fws.gov; Patricia F Brewer@nps.gov; Anderson, Bret A -FS 

Subject: RE: Revision to Ohio's SIP Approved Regional Haze SIP 

Hello all, I am not sure who will be the right contacts for this notice so I apologize if I have too many, 

or to few. Please let me know if there are others I should get this too. 

1 
On March 1 1 , 201 1, Ohio EPA submitted our Regional Haze SIP to U.S. EPA. Ohio's SIP was 

subsequently approved on July 2, 2012 (77 FR 391 77). Ohio's SIP included the applicability of Best 

Available Retrofit Technology (BART) to Ohio's only BART source, P.H. Glatfelter. Ohio's submittal 

included a compliance date for BART emission reductions of December 31, 201 4. This compliance 

date was aligned with P.H. Glatfelter's expected compliance date for the Industrial Boiler Maximum 

Achievable Control Technology (MACT) requirements promulgated by U.S. EPA in March of 201 1 

and allowed for achievement of BART well before the compliance date required by U.S. EPA's BART 

regulations. Under U.S. EPA's regulations (40 CFR 51 .308(3)(1 )(iv)), BART is to be implemented "as 

expeditiously as practicable, but in no event later than 5 years after approval of the implementation 

plan revision." This date is July 2, 201 7. 

U.S. EPA's Industrial Boiler MACT was subsequently litigated and a final revision was issued by U.S. 

EPA on January 31, 2013 which established a new compliance date for the MACT. On February 6, 

201 4, Ohio EPA received a request from P.H. Glatfelter to extend the original compliance date for 

BART to January 31, 2017 to align the BART compliance with the new compliance date associated 

with the I ndustrial Boiler MACT (as extended by Ohio EPA). The original compliance date was 

designed so that these dates aligned and allowed for P.H. Glatfelter to select and implement a control 

strategy that would address both the MACT and BART. 

Ohio EPA prepared a draft SIP request for U.S. EPA to revise the approved Regional Haze SIP to 

allow for a compliance date of January 31, 2017 for BART. A public comment period and hearing 

were conducted in March of 201 4. We consulted with FLMs (see below) during that time period and 

received and considered comments. The SIP revision was finalized and submitted to U .S. EPA on 

April 1 4, 201 4. U.S. EPA is now requesting Ohio EPA revise P.H. Glatfelter's permit to include the 

compliance date extension and to submit the final permit BART requirements as part of Ohio's 

SIP. We issued a draft permit that incorporates the updated compliance schedule and there is a 

comment period open ending on 7/7/15. 

Here is a link to the issued document. 

It should also be noted that we are currently working with P .H. Glatfelter on a project to convert their 

boilers to natural gas as a result of the Boiler MACT. So in the end, they will have much greater than 

BART reductions by this compliance timeline. 

If you have any questions please feel free to contact me, 

Jennifer 

Jennifer Van Vlerah 

Manager, SIP, Rulemaking and Inventory Section 

Ohio EPA Division of Air Pollution Control 

6 14-644-3696 

From: Van Vlerah, Jennifer 

Sent: Tuesday, April 15, 2014 10:44 AM 

To: 'O'Dea, Claire B -FS' 

Cc: Wickman, Trent R -FS 

Subject: RE: Revision to Ohio's SIP Approved Regional Haze SIP - FLM Consultation and Public Comment Period 

2 
Hello Claire, Wanted to make sure you were notified that yesterday we submitted the SIP revision request to U.S. 

EPA. It was posted online this morning. 

http://www.epa.ohio.gov/dapc/SIP/haze.aspx 

see 4/14/2014 row of the table. 

Thank you, Jennifer 

Jennifer Van Vlerah 

Manager, SIP, Rulemaking and I nventory Section 

Ohio EPA Division of Air Pollution Control 

614-644-3696 

From: O'Dea, Claire B -FS [mailto:cbodea@fs.fed.us] 

Sent: Tuesday, March 04, 2014 1 :51 PM 

To: Van Vlerah, Jennifer 

Cc: Wickman, Trent R -FS 

Subject: RE: Revision to Ohio's SIP Approved Regional Haze SIP - FLM Consultation and Public Comment Period 

Hi Jennifer, 

Thank you for your email alerting us to Ohio's requested Regional Haze SIP revision to extend the BART compliance date 

for P.H. Glatfelter. We recognize that the requested extension does fall within the timeframe required under the 

Federal BART rule, and therefore have no formal comments on the requested SIP revision. We would, however, still like 

to encourage "BART installation and operation as expeditiously as practicable." 

Thank you, 

Claire O'Dea, Ph.D. 

Air Quality Specialist, USDA Forest Service Eastern Region 

1400 Independence Ave., SW, Mailstop: 1121 

Washington, DC 20250 

(202) 205-1686 

(919) 368-6879 (c) 

cbodea@fs.fed.us 

From: Van Vlerah, Jennifer [mailto:Jennifer.VanVIerah@epa.ohio.gov] 

Sent: Tuesday, February 18, 2014 3:02 PM 

To: Patricia F Brewer@nps.gov; Wickman, Trent R -FS; jill webster@fws.gov; O'Dea, Claire B -FS 

Subject: Revision to Ohio's SIP Approved Regional Haze SIP - FLM Consultation and Public Comment Period 

Hello all, 

Ohio is going to request a revision to our Regional Haze SIP to extend the BART compliance date for our only BART 

subject source, P.H. Glatfelter. The compliance date still falls within the compliance date timeframe required under the 

Federal BART rule. The following is a link to our request and explains the details and reason for the requested 

revision. It's fairly brief and the change will not require significant review on your part. In discussing this with Region 5, 

they felt it would be okay to just have our standard 30'ish day comment period and the FLM consultation 

concurrently. If for some reason you need the full 60 days please just let me know and I will extend that. We have it 

open to the public through 3/25/14 and we are holding a public hearing that day also. The link below p rovides the 

public notice and all the information you should need but if you would like to discuss further, feel free to contact me. 

http_://www .epa.ohio.gov /dapc/SIP /haze.aspx 

3 
Also, this email list comprises those that myself and Region 5 felt should be included. If you are aware of any other FLM 

contacts that should be included, please let me know. 

Sincerely, Jennifer 

Jennifer Van Vlerah 

Manager, SIP, Rulemaking and Inventory Section 

Ohio EPA Division of Air Pollution Control 

6 14-644-3696 

This electronic message contains information generated by the USDA solely for the intended recipients. Any 

unauthorized interception of this message or the use or disclosure of the information it contains may violate the 

law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, 

please notifY the sender and delete the email immediately. 

4 
D. 

Response to Comments 
!!!!2 

Protection Agency 

Facility ID: 

Facility Name: 

Facility Description: 

Facility Address: 

Permit: 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P0118907 

Facility ID: 067101 0028 

Response to Comments 

067101 0028 

P. H. Glatfelter Company - Chillicothe Facility 

Chillicothe Paper Mill. 

232 East 8TH St. 

Chillicothe, OH 45601 

Ross County 

P01 1 8907, Permit-To-Install - Administrative Modification 

Ohio EPA provided a public comment period on revisions to the permit-to-install to incorporate changes Ohio 

EPA submitted in its June 1 4, 2014 State Implementation Plan (SIP) regarding the Best Available Retrofit 

Technology (BART) compliance date requirements for P.H. Glatfelter. A public hearing was not requested on 

this permit and therefore was not held. A public notice for the draft permit issuance was published in the Ohio 

EPA Weekly Review and appeared in the Chillicothe Gazette on 06/06/2015. The comment per"tod ended on 

07/07/201 5. This document summarizes the comments during the associated comment period. 

Hearing date (if held) N/A 

Hearing Public Notice 

Date (if different from N/A 

draft public notice) 

The following comments were received during the comment period specified. Ohio EPA reviewed and 

considered all comments received during the public comment period. By law, Ohio EPA has authority to consider 

specific issues related to protection of the environment and public health. Often, public concerns fall outside the 

scope of that authority. For example, concerns about zoning issues are addressed at the local level. Ohio EPA 

rnay respond to those concerns in this document by identifying another government agency with more direct 

authority over the issue. 

In an effort to help you review this document, the questions are grouped by topic and organized in a consistent 

format. PDF copies of the original comments in the format submitted are available upon request. 

1. Topic: Compliance Date Extensions 

a. Comment: As for the specifics of the P.H. Glatfelter permit, thank you for forwarding the draft 

permit with the updated compliance schedule incorporated. As stated in our FLM response to the 

SIP revision, we recognize that the extension of the BART compliance date falls within the 

timeframe required under the Federal BART rule, and therefore have no formal comments on the 

draft permit. We do still encourage "BART installation and operation as expeditiously as 

practicable." (Claire O'Dea- USDA Forest Service Eastern Region, submitted via email) 

a. Response: Thank you for your comment. Ohio EPA agrees with the commenter that the 

extension falls within the Federal BART rule timeframe and; therefore, Ohio EPA believes the 

request should be approvable. The installation and operation of BART as expeditiously as 

practicable is a high priority to Ohio EPA and the agency feels this is being observed by P.H. 

Glatfelter. 

b. Comment: Thank you for the opportunity to comment on the Draft Air Pollution Permit-to-Install 

Administrative Modification to PTI # P01 03673 issued 3/7/2011 for P. H. Glatfelter Company -

Chillicothe Facility (Draft Permit). We submit these comments on behalf of NPCA and our 

members who live near and/or recreate in Class I areas that are adversely impacted by haze 
!!!!g 

Protection Agency 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

pollution from the Glatfelter facility, including Great Smoky Mountains, Mammoth Cave, and 

Shenandoah National Parks. We oppose the modified compliance date for the implementation of 

Best Available Retrofit Technology (BART) proposed by the Draft Permit, which would allow 

several years of additional, unnecessary emissions to continue to pollute and harm our public 

lands and nearby communities. 

The public notice's stated purpose of the modification is to "align the BART compliance with the 

new compliance date associated with the Industrial Boiler MACT ... to allow[] for P.H. Glatfelter to 

select and implement a control strategy that would address both the MACT and BART." However, 

the additional time is not necessary and contradicts the statutory requirement that BART be 

installed "as expeditiously as possible." BART could and should have been implemented within 

the original timeframe. 

The original date for BART compliance included several parts 1: 

1. With regard to nitrogen oxides, a requirement to "routinely employing the Alstom 

Power low-NOx concentric firing system and vane close-coupled over fire air 

compartment, on a year-round basis, rather than limiting low-NOx operation to the 

control period (May 1 through September 30)" by December 31, 2014. 

2. With regard to sulfur dioxide, first, a requirement to submit an application 

containing "a compliance plan outlining, at a minimum, the specific, selected 

control technologies and methods of compliance" by December 31, 201 3, a year 

prior to the emission compliance date. 

3. Also with regard to sulfur dioxide, to "achieve the required sulfur dioxide emission 

reduction, on a year-round basis" by December 31, 2014. 

4. A requirement to install a "continuous emission monitoring system (GEMS) ... to 

measure and record the daily sulfur dioxide emissions" by December 31 , 201 4. 

The first and last of those requirements - employing equipment that is already installed at the 

facility, and installing a continuous emissions monitor - very clearly do not require any additional 

time for coordination with MACT requirements. These compliance dates should not be changed 

and to the extent that Glatfelter has not already complied with them, the facility is in violation of its 

federally enforceable permit. We ask OEPA not to change the compliance dates for these 

elements and to ensure that the Glatfelter facility is complying with them currently. 

As to the second and third requirements, as noted by OEPA, the final MACT revision was issued 

by US EPA on January 31 , 201 3. Therefore, Glatfelter had most of a year before it was required to 

submit its plan for achieving emission reductions sufficient to satisfy BART, during which time it 

could have selected a control strategy that complied with both MACT and BART. It is not clear 

whether Glatfelter submitted the application due on December 31 , 201 3, which was prior to its 

February 2014 request to extend the compliance date. There is no indication that anything in US 

EPA's revision to the MACT requirements actually altered Glatfelter's ability to comply with BART. 

The change in compliance date for MACT did not change the expeditiousness with which BART 

can be installed. 

We ask that OEPA not change the compliance dates for Glatfelter's application for a sulfur dioxide 

control strategy or for achieving the required emission reductions. However, if OEPA chooses to 

--

change the dates, it should require the application date a year prior to the emission reduction date 

1 See Final Division of Air Pollution Control Permit-to-Install for P. H. Glatfelter Company - Chillicothe Facility, 

3/7/2011, Ohio Regional Haze State Implementation Plan, Appendix H. 
!h!2 

Protection Agency 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 010028 

(i.e. January 31, 2016 rather than January 31 , 201 7), consistent with both logical workflow and the 

relative timing of the original requirements (Nathan miller- National Parks Conservation 

Association, submitted via email) 

b. Response: The compliance date extensions fall within the Federal BART rule timeframe and; 

therefore, Ohio EPA believes the request should be approvable. Ohio EPA is currently working 

with P.H. Glatfelter to complete a natural gas conversion of the two coal-fired boilers that are 

subject to the BART requirements. This will provide even greater reductions in sulfur dioxide than 

those imposed by the BART requirements. Because the Federal BART rule timeframe allows 

more time for compliance, Ohio EPA felt it would be unreasonable to require the installation of a 

control technology to address the minimum BART requirements for the limited time period before 

P.H. Glatfelter's conversion to natural gas to address the Boiler MACT. 

With respect to the "first and last of those requirements" identified by the commentor above, 

Ohio's 201 1 State Implementation Plan (SIP) for Regional Haze stated "the NOx and primary 

particulate emissions were determined to require no control beyond what is currently provided" to 

address visibility impacts. However, because the compliance option selected by P.H. Glatfelter 

is to maintain control measures constituting an "alternative to BART" that will achieve greater 

reasonable progress than would be achieved through installation and operation of BART (as 

allowed under 40CFR Part 51 .308(e)(2)), P.H. Glatfelter's strategy for greater than reasonable 

progress included an agreement to operate this unit year round. Because the compliance dale 

was extended to implement the sulfur dioxide BART strategy necessary to improve visibility and 

that compliance date remained within the Federal BART rule timeframe, Ohio EPA felt it was also 

reasonable to extend the compliance date for the greater than reasonable progress component. 

It is important to note that P.H. Glatfelter has still been required by their previous permit(s) to 

operate their NOx controls and monitor in accordance with the requirements previously 

established at a minimum during the ozone season control period required under Ohio 

Administrative Code Chapter 3745-14. This action did not relieve P. H. Glatfelter from those 

existing requirements. Rather, by the compliance date established by the BART requirements, 

the additional year-round operation of NOx controls and compliance monitoring would become 

federally enforceable requirements as part of Ohio's State Implementation Plan for Regional 

Haze. 

In summary, P.H. Glatfelter's pending conversion to natural gas by the timeframe required by the 

Boiler MACT and within the timeframe intended under the Federal BART rule to address visibility 

will provide even greater reductions in pollutants than necessary to address P.H. Glatfelter's 

visibility requirements. Ohio EPA believes this is the best path forward to achieve greater than 

reasonable progress than would be achieved through BART alone. 
E. 

Final Federally Enforceable 

Permit 
f.h!2 John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Craig W. Butler, Director 

Protection Agency 

7/20/2015 

Kathy Wiedeman 

P. H. Glatfelter Company - Chillicothe Facility 

232 East 8th Street 

Chillicothe, OH 45601 

RE: FINAL AIR POLLUTION PERMIT-TO-INSTALL 

Facility ID: 067101 0028 

Permit Number: P01 1 8907 

Permit Type: Administrative Modification 

County: Ross 

Dear Permit Holder: 

Certified Mail 

No S�Nl"HETIC: rv11NOf'l TO .AVOID �AJSl.R NSR� 

No CEMS 

-··����'''"""�'' '"" ,,.,,.,_.� 

Yes MACT /GACT 

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No 

. .•... ..• �.N_�P�-- •• • ••...• 

NESHAPS 

, _ ,, ,,,_,�m 

MAJOR NON-ATTAINMENT 

'"" """ """""" ··· ·��-�·�· 

MAJOR GHG 

"""" " "'" ""'"'"�'--"'"""'�"""" "'"��<M•-�OOo 

. SYNT_I:IEO_TIQ..�INOR2.0__!1VOID MAJOR GH() _ 

Enclosed please find a final Ohio Environmental Protection Agency (EPA) Air Pollution Permit-to-Install (PTI) 

which will allow you to install or modify the described emissions unit(s) in a manner indicated in the permit. 

Because this permit contains several conditions and restrictions, we urge you to read it carefully. Because this 

permit contains conditions and restrictions, please read it very carefully. In this letter you will find the 

information on the following topics: 

• How to appeal this permit 

• How to save money, reduce pollution and reduce energy consumption 

• How to give us feedback on your permitting experience 

• How to get an electronic copy of your permit 

How to appeal this permit 

The issuance of this PTI is a final action of the Director and may be appealed to the Environmental Review 

Appeals Commission pursuant to Section 3745.04 of the Ohio Revised Code. The appeal must be in writing 

and set forth the action complained of and the grounds upon which the appeal is based. The appeal must be 

filed with the Commission within thirty (30) days after notice of the Director's action. The appeal must be 

accompanied by a filing fee of $70.00, made payable to "Ohio Treasurer Josh Mandel," which the Commission, 

in its discretion, may reduce if by affidavit you demonstrate that payment of the full amount of the fee would 

cause extreme hardship. Notice of the filing of the appeal shall be filed with the Director within three (3) days 

of filing with the Commission. Ohio EPA requests that a copy of the appeal be served upon the Ohio Attorney 

General's Office, Environmental Enforcement Section. An appeal may be filed with the Environmental Review 

Appeals Commission at the following address: 

Environmental Review Appeals Commission 

77 South High Street, 1 7th Floor 

Columbus, OH 43215 

50 West Town Street • Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
How to save money, reduce pollution and reduce energy consumption 

The Ohio EPA is encouraging companies to investigate pollution prevention and energy conservation. Not 

only will this reduce pollution and energy consumption, but it can also save you money. If you would like to 

learn ways you can save money while protecting the environment, please contact our Office of Compliance 

Assistance and Pollution Prevention at (61 4) 644-3469. Additionally, all or a portion of the capital expenditures 

related to installing air pollution control equipment under this permit may be eligible for financing and State tax 

exemptions through the Ohio Air Quality Development Authority ( OAQDA) under Ohio Revised Code Section 

3706. For more information, see the OAQDA website: www.ohioairquality.org/clean air 

How to give us feedback on your permitting experience 

Please complete a survey at www.epa.ohio.gov/survey.aspx and give us feedback on your permitting 

experience. We value your opinion. 

How to get an electronic copy of your permit 

This permit can be accessed electronically via the eBusiness Center: Air Services in Microsoft Word format or 

in Adobe PDF on the Division of Air Pollution Control (DAPC) Web page, ww

.epa.ohio.gov/dapc by clicking 

the "Search for Permits" link under the Permitting topic on the Programs tab. 

If you have any questions, please contact Ohio EPA DAPC, Southeast District Office at (740)385-8501 or the 

Office of Compliance Assistance and Pollution Prevention at (614) 644-3469. 

Sincerely, 

Michael E. Hopkins, P.E. 

Assistant Chief, Permitting Section, DAPC 

Cc: U.S. EPA 

Ohio EPA-SEDO; Kentucky 
!!!!2 

Protection Agency 

Facility ID: 

Facility Name: 

Facility Description: 

Facility Address: 

Permit: 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 0671 0 1 0028 

Response to Comments 

0671010028 

P. H. Glatfelter Company - Chillicothe Facility 

Chillicothe Paper Mill. 

232 East 8TH St. 

Chillicothe, OH 45601 

Ross County 

P01 18907, Permit-To-Install - Administrative Modification 

Ohio EPA provided a public comment period on revisions to the permit-to-install to incorporate changes Ohio 

EPA submitted in its June 1 4, 2014 State Implementation Plan (SIP) regarding the Best Available Retrofit 

Technology (BART) compliance date requirements for P.H. Glatfelter. A public hearing was not requested on 

this permit and therefore was not held. A public notice for the draft permit issuance was published in the 

Ohio EPA Weekly Review and appeared in the Chillicothe Gazette on 06/06/2015. The comment period 

ended on 07/07/201 5. This document summarizes the comments during the associated comment period. 

Hearing date (if held) N/A 

Hearing Public Notice 

Date (if different from N/A 

draft public notice) 

The following comments were received during the comment period specified. Ohio EPA reviewed and 

considered all comments received during the public comment period. By law, Ohio EPA has authority to 

consider specific issues related to protection of the environment and public health. Often, public concerns fall 

outside the scope of that authority. For example, concerns about zoning issues are addressed at the local 

level. Ohio EPA may respond to those concerns in this document by identifying another government agency 

with more direct authority over the issue. 

In an effort to help you review this document, the questions are grouped by topic and organized in a consistent 

format. PDF copies of the original comments in the format submitted are available upon request. 

1. Topic: Compliance Date Extensions 

a. Comment: As for the specifics of the P.H. Glatfelter permit, thank you for forwarding the draft 

perrnit with the updated compliance schedule incorporated. As stated in our FLM response to 

the SIP revision, we recognize that the extension of the BART compliance date falls within the 

timeframe required under the Federal BART rule, and therefore have no formal comments on 

the draft permit. We do still encourage "BART installation and operation as expeditiously as 

practicable." (Claire O'Dea- USDA Forest Service Eastern Region, submitted via email) 

a. Response: Thank you for your comment. Ohio EPA agrees with the commenter that the 

extension falls within the Federal BART rule timeframe and; therefore, Ohio EPA believes the 

request should be approvable. The installation and operation of BART as expeditiously as 

practicable is a high priority to Ohio EPA and the agency feels this is being observed by P.H. 

Glatfelter. 
!h!2 

Protection Agency 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P0118907 

Facility 10: 0671010028 

b. Comment: Thank you for the opportunity to comment on the Draft Air Pollution Permit-to-Install 

Administrative Modification to PTI # P0103673 issued 3/7/2011 for P. H. Glatfelter Company ­

Chillicothe Facility (Draft Permit). We submit these comments on behalf of NPCA and our 

members who live near and/or recreate in Class I areas that are adversely impacted by haze 

pollution from the Glatfelter facility, including Great Smoky Mountains, Mammoth Cave, and 

Shenandoah National Parks. We oppose the modified compliance date for the implementation 

of Best Available Retrofit Technology (BART) proposed by the Draft Permit, which would allow 

several years of additional, unnecessary emissions to continue to pollute and harm our public 

lands and nearby communities. 

The public notice's stated purpose of the modification is to "align the BART compliance with the 

new compliance date associated with the Industrial Boiler MACT ... to allow[] for P.H. Glatfelter 

to select and implement a control strategy that would address both the MACT and BART." 

However, the additional time is not necessary and contradicts the statutory requirement that 

BART be installed "as expeditiously as possible." BART could and should have been 

implemented within the original timeframe. 

The original date for BART compliance included several parts 1: 

1. With regard to nitrogen oxides, a requirement to "routinely employing the Alstom 

Power low-NOx concentric firing system and vane close-coupled over fire air 

compartment, on a year-round basis, rather than limiting low-NOx operation to 

the control period (May 1 through September 30)" by December 31 , 2014. 

2. With regard to sulfur dioxide, first, a requirement to submit an application 

containing "a compliance plan outlining, at a minimum, the specific, selected 

control technologies and methods of compliance" by December 31, 2013, a year 

prior to the emission compliance date. 

3. Also with regard to sulfur dioxide, to "achieve the required sulfur dioxide emission 

reduction, on a year-round basis" by December 31 , 2014. 

4. A requirement to install a "continuous emission monitoring system (CEMS) ... to 

measure and record the daily sulfur dioxide emissions" by December 31, 201 4. 

The first and last of those requirements - employing equipment that is already installed at the 

facility, and installing a continuous emissions monitor - very clearly do not require any additional 

time for coordination with MACT requirements. These compliance dates should not be changed 

and to the extent that Glatfelter has not already complied with them, the facility is in violation of 

its federally enforceable permit. We ask OEPA not to change the compliance dates for these 

elements and to ensure that the Glatfelter facility is complying with them currently. 

As to the second and third requirements, as noted by OEPA, the final MACT revision was 

issued by US EPA on January 31, 201 3. Therefore, Glatfelter had most of a year before it was 

required to submit its plan for achieving emission reductions sufficient to satisfy BART, during 

which time it could have selected a control strategy that complied with both MACT and BART. It 

is not clear whether Glatfelter submitted the application due on December 31 , 201 3, which was 

prior to its February 2014 request to extend the compliance date. There is no indication that 

anything in US EPA's revision to the MACT requirements actually altered Glatfelter's ability to 

1 See Final Division of Air Pollution Control Penmit-to-lnstall for P. H. Glatfelter Company - Chillicothe Facility, 

3/7/201 1, Ohio Regional Haze State Implementation Plan, Appendix H. 
f.h!2 

Protection Agency 

Response to Comments 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility 10: 067101 0028 

comply with BART. The change in compliance date for MACT did not change the 

expeditiousness with which BART can be installed. 

We ask that OEPA not change the compliance dates for Glatfelter's application for a sulfur 

dioxide control strategy or for achieving the required emission reductions. However, if OEPA 

chooses to change the dates, it should require the application date a year prior to the emission 

reduction date (i.e. January 31 , 2016 rather than January 31, 201 7), consistent with both logical 

workflow and the relative timing of the original requirements (Nathan miller- National Parks 

Conservation Association, submitted via email) 

b. Response: The compliance date extensions fall within the Federal BART rule timeframe and; 

therefore, Ohio EPA believes the request should be approvable. Ohio EPA is currently working 

with P.H. Glatfelter to complete a natural gas conversion of the two coal-fired boilers that are 

subject to the BART requirements. This will provide even greater reductions in sulfur dioxide 

than those imposed by the BART requirements. Because the Federal BART rule timeframe 

allows more time for compliance, Ohio EPA felt it would be unreasonable to require the 

installation of a control technology to address the minimum BART requirements for the limited 

time period before P.H. Glatfelter's conversion to natural gas to address the Boiler MACT. 

With respect to the "first and last of those requirements" identified by the commentor above, 

Ohio's 2011 State Implementation Plan (SIP) for Regional Haze stated "the NOx and primary 

particulate emissions were determined to require no control beyond what is currently provided" 

to address visibility impacts. However, because the compliance option selected by P.H. 

Glatfelter is to maintain control measures constituting an "alternative to BART" that will achieve 

greater reasonable progress than would be achieved through installation and operation of BART 

(as allowed under 40CFR Part 51.308(e)(2)), P.H. Glatfelter's strategy for greater than 

reasonable progress included an agreement to operate this unit year round. Because the 

compliance date was extended to implement the sulfur dioxide BART strategy necessary to 

improve visibility and that compliance date remained within the Federal BART rule timeframe, 

Ohio EPA felt it was also reasonable to extend the compliance date for the greater than 

reasonable progress component. 

It is important to note that P.H. Glatfelter has still been required by their previous permit(s) to 

operate their NOx controls and monitor in accordance with the requirements previously 

established at a minimum during the ozone season control period required under Ohio 

Administrative Code Chapter 3745-14. This action did not relieve P. H. Glatfelter from those 

existing requirements. Rather, by the compliance date established by the BART requirements, 

the additional year-round operation of NOx controls and compliance monitoring would become 

federally enforceable requirements as part of Ohio's State Implementation Plan for Regional 

Haze. 

In summary, P.H. Glatfelter's pending conversion to natural gas by the timeframe required by 

the Boiler MACT and within the timeframe intended under the Federal BART rule to address 

visibility will provide even greater reductions in pollutants than necessary to address P.H. 

Glatfelter's visibility requirements. Ohio EPA believes this is the best path forward to achieve 

greater than reasonable progress than would be achieved through BART alone. 
hio 

Ohio Environmental 

Protection Agency 

FINAL 

Division of Air Pollution Control 

Permit-to-Install 

for 

P. H. Glatfelter Company- Chillicothe Facility 

Facility ID: 

Permit Number: 

Permit Type: 

Issued: 

Effective: 

0671 01 0028 

P01 1 8907 

Administrative Modification 

7/20/2015 

7/20/2015 
!!!!2 

Protection Agency 

Division of Air Pollution Control 

Permit-to-Install 

for 

P. H. Glatfelter Company - Chillicothe Facility 

Table of Contents 

Authorization ........................................ ................................ .............. ..................... .................. ........................ 1 

A. Standard Terms and Conditions .............................. ........ .......................... ........................................ .......... 3 

1. Federally Enforceable Standard Terms and Conditions ........ ...................................................... ........... 4 

2. Severability Clause ....................................... ...................... .... ............................................................... 4 

3. General Requirements ............................ ....... ....................... ................................................................. 4 

4. Monitoring and Related Record Keeping and Reporting Requirements ......... . . . . . . . .... . ..... . . . . . . .............. . ... 5 

5. Scheduled Maintenance/Malfunction Reporting ..... .............. ........... ........................... .... .......... ..... ......... 6 

6. Compliance Requirements ........................... . ..... ........ . ................... . ....... ............... ... ..................... . ........ 6 

7. Best Available Technology ............... ....... ......................... ...... .................... ........................ .................... 7 

8. Air Pollution Nuisance . . ...... . ....... . ... . ..... . . . .......................... . ...... . ......... . ...... . .......... . . ....... . ........... . ......... ... 8 

9. Reporting Requirements . . . . . . . . . ... . ... . ... . .... . ..... . ................ ........................... . ............. . . . . ....... . . . . . . . .... . ....... . 8 

1 0. Applicability ... .. . . . .... .. ... .. ..... . . ..... ... . . . . .... . ...... . ...................... . ............... . . . . . . . . ... . . . ........... .. . . . . . . . . . ... . ..... . . . . . . . 8 

11. Construction of New Sources(s) and Authorization to Install . . . ........ . . . . . . . . ..... . . . . . . ........... . ... . ..... . . . ..... . . . . . .. 8 

1 2. Permit-To-Operate Application ......................................................... ........ .......................... ......... . .......... 9 

1 3. Construction Compliance Certification ........ ................................................................... ....... ............... 10 

14. Public Disclosure ............. .................................. ...... ......... ............... ............ ...... .... .......... ........ .... ........ 10 

1 5. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission 

Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations ................... 10 

1 6. Fees ..... ................ ................................................ .................................... ........................................... 10 

1 7. Permit Transfers ............ ............................... .......................................................... ............................ . 10 

1 8. Risk Management Plans ........................... ... ..... .......... ......................... ... ................ ............................. 10 

1 9. Title IV Provisions ....... ................................... ................. .................................... ................................. 10 

B. Facility-Wide Terms and Conditions ................... .................... .......... ......................................................... 11 

C. Emissions Unit Terms and Conditions .......... ...... ............ ...................... ...... .............. ................................. 19 

1. B002, No.7 Boiler .......... .......................... .................. ......... .... ....... ............ ........................ .... ............... 20 

2. B003, No. 8 Boiler ...................... ..... ................. ................... ......... ............. ........................................... 32 
�!!!2 

Protection Agency 

Facility ID: 

Facility Description: 

Application Number(s): 

Permit Number: 

Authorization 

0671010028 

Chillicothe Paper Mill. 

M0003371 

P01 1 8907 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 

Permit Description: Administrative modification to PTI # P0103673 issued 3/7/2011 to align compliance date for 

the BART requirements with the approved Boiler MACT compliance date of January 31, 2017 

to request to align the compliance date. The request states that this will allow Glatfelter to 

implement a strategy that meets compliance requirements as specified in Boiler MACT and 

the BART regulations as well as meet all regulatory compliance deadlines. 

Permit Type: Administrative Modification 

Permit Fee: $3,000.00 

Issue Date: 7/20/2015 

Effective Date: 7/20/2015 

This document constitutes issuance to: 

P. H. Glatfelter Company - Chillicothe Facility 

232 East 8TH St. 

Chillicothe, OH 45601 

of a Permit-to-Install for the emissions unit(s) identified on the following page. 

Ohio Environmental Protection Agency (EPA) District Office or local air agency responsible for processing and 

administering your permit: 

Ohio EPA DAPC, Southeast District Office 

2195 Front Street 

Logan, OH 431 38 

(7 40 )385-850 1 

The above named entity is hereby granted a Permit-to-Install for the emissions unit(s) listed in this section pursuant to 

Chapter 3745-31 of the Ohio Administrative Code. Issuance of this permit does not constitute expressed or implied 

approval or agreement that, if constructed or modified in accordance with the plans included in the application, the 

emissions unit(s) of environmental pollutants will operate in compliance with applicable State and Federal laws and 

regulations, and does not constitute expressed or implied assurance that if constructed or modified in accordance with 

those plans and specifications, the above described emissions unit(s) of pollutants will be granted the necessary permits 

to operate (air) or NPDES permits as applicable. 

This permit is granted subject to the conditions attached hereto. 

Ohio Environmental Protection Agency 

r�- w. \iS� 

g "v?J Butler 

Director 

Page 1 of 43 
Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Authorization (continued) 

Permit Number: P01 1 8907 

Permit Description: Administrative modification to PTI # P0103673 issued 3/7/2011 to align compliance date 

for the BART requirements with the approved Boiler MACT compliance date of January 

31 , 2017 to request to align the compliance date. The request states that this will allow 

Glatfelter to implement a strategy that meets compliance requirements as specified in 

Boiler MACT and the BART regulations as well as meet all regulatory compliance 

deadlines. 

Permits for the following Emissions Unit(s) or groups of Emissions Units are in this document as indicated 

below: 

Emissions Unit ID: 8002 

Company Equipment iD:. No.7 Boiler 

Superseded Permit Number: P0103673 

General Permit Category and Type: . Not Applicable 

Emissions Unit ID: 8003 

Company Equipment iD: No. 8 Boiler 

Superseded Permit Number: P0103673 

General Permit Category and Type: Not Applicable 

Page 2 of 43 
�!!!2 

Protection Agency 

A. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Standard Terms and Conditions 

Page 3 of 43 
�!!!2 

Protection Agency 

1. Federally Enforceable Standard Terms and Conditions 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 

a) All Standard Terms and Conditions are federally enforceable, with the exception of those listed 

below which are enforceable under State law only: 

(1) Standard Term and Condition A.2.a), Severability Clause 

(2) Standard Term and Condition A.3.c) through A. 3.e) General Requirements 

(3) Standard Term and Condition A.6.c) and A. 6.d), Compliance Requirements 

(4) Standard Term and Condition A.9., Reporting Requirements 

(5) Standard Term and Condition A.10., Applicability 

(6) Standard Term and Condition A.1 1 .b) through A.1 1.e), Construction of New Source(s) 

and Authorization to Install 

(7) Standard Term and Condition A.1 4., Public Disclosure 

(8) Standard Term and Condition A.1 5., Additional Reporting Requirements When There 

Are No Deviations of Federally Enforceable Emission Limitations, Operational 

Restrictions, or Control Device Operating Parameter Limitations 

(9) Standard Term and Condition A.16., Fees 

(10) Standard Term and Condition A.1 7., Permit Transfers 

2. Severability Clause 

a) A determination that any term or condition of this permit is invalid shall not invalidate the force or 

effect of any other term or condition thereof, except to the extent that any other term or condition 

depends in whole or in part for its operation or implementation upon the term or condition 

declared invalid. 

b) All terms and conditions designated in parts B and C of this permit are federally enforceable as 

a practical matter, if they are required under the Act, or any of its applicable requirements, 

including relevant provisions designed to limit the potential to emit of a source, are enforceable 

by the Administrator of the U.S. EPA and the State and by citizens (to the extent allowed by 

section 304 of the Act) under the Act. Terms and conditions in parts B and C of this permit shall 

not be federally enforceable and shall be enforceable under State law only, only if specifically 

identified in this permit as such. 

3. General Requirements 

a) Any noncompliance with the federally enforceable terms and conditions of this permit 

constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, 

revocation and re-issuance, or modification. 

Page 4 of 43 
th!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

b) It shall not be a defense for the permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

federally enforceable terms and conditions of this permit. 

c) This penmit may be modified, revoked, or revoked and reissued, for cause. The filing of a 

request by the permittee for a permit modification, revocation and reissuance, or revocation, or 

of a notification of planned changes or anticipated noncompliance does not stay any term and 

condition of this permit. 

d) This permit does not convey any property rights of any sort, or any exclusive privilege. 

e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of 

the Director, upon receipt of a written request and within a reasonable time, any information that 

may be requested to determine whether cause exists for modifying or revoking this permit or to 

determine compliance with this permit. Upon request, the permittee shall also furnish to the 

Director or an authorized representative of the Director, copies of records required to be kept by 

this permit. For information claimed to be confidential in the submittal to the Director, if the 

Administrator of the U.S. EPA requests such information, the permittee may furnish such 

records directly to the Administrator along with a claim of confidentiality. 

4. Monitoring and Related Record Keeping and Reporting Requirements 

a) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, 

the permittee shall maintain records that include the following, where applicable, for any 

required monitoring under this penmit: 

(1) The date, place (as defined in the penmit), and time of sampling or measurements. 

(2) The date(s) analyses were performed. 

(3) The company or entity that performed the analyses. 

(4) The analytical techniques or methods used. 

(5) The results of such analyses. 

(6) The operating conditions existing at the time of sampling or measurement. 

b) Each record of any monitoring data, testing data, and support information required pursuant to 

this permit shall be retained for a period of five years from the date the record was created. 

Support information shall include, but not be limited to all calibration and maintenance records 

and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by this permit. Such records may be maintained in computerized form. 

c) Except as may otherwise be provided in the terms and conditions for a specific emissions unit, 

the permittee shall submit required reports in the following manner: 

( 1) Reports of any required monitoring and/or recordkeeping of federally enforceable 

information shall be submitted to the Ohio EPA DAPC, Southeast District Office. 

Page 5 of 43 
�!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

(2) Quarterly written reports of (i) any deviations from federally enforceable em1ss1on 

limitations, operational restrictions, and control device operating parameter limitations, 

excluding deviations resulting from malfunctions reported in accordance with OAC rule 

3745-1 5-06, that have been detected by the testing, monitoring and recordkeeping 

requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) 

any corrective actions or preventive measures taken, shall be made to the Ohio EPA 

DAPC, Southeast District Office. The written reports shall be submitted (i.e., 

postmarked) quarterly, by January 31 , April 30, July 31 , and October 31 of each year 

and shall cover the previous calendar quarters. See A.1 5. below if no deviations 

occurred during the quarter. 

(3) Written reports, which identify any deviations from the federally enforceable monitoring, 

recordkeeping, and reporting requirements contained in this permit shall be submitted to 

the Ohio EPA DAPC, Southeast District Office every six months, by January 31 and July 

31 of each year for the previous six calendar months. If no deviations occurred during a 

six-month period, the permittee shall submit a semi-annual report, which states that no 

deviations occurred during that period. 

(4) This permit is for an emissions unit located at a Title V facility. Each written report shall 

be signed by a responsible official certifying that, based on information and belief formed 

after reasonable inquiry, the statements and information in the report are true, accurate, 

and complete. 

d) The permittee shall report actual emissions pursuant to OAC Chapter 3745-78 for the purpose 

of collecting Air Pollution Control Fees. 

5. Scheduled Maintenance/Malfunction Reporting 

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with 

paragraph (A) of OAC rule 3745-15-06. The malfunction, i.e., upset, of any emissions units or any 

associated air pollution control system(s) shall be reported to the Ohio EPA DAPC, Southeast District 

Office in accordance with paragraph (B) of OAC rule 3745-1 5-06. {The definition of an upset condition 

shall be the same as that used in OAC rule 37 45-1 5-06(8)( 1) for a malfunction.) The verbal and written 

reports shall be submitted pursuant to OAC rule 3745-15-06. 

Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown 

or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the 

emission unit(s) that is (are) served by such control system(s). 

6. Compliance Requirements 

a) All applications, notifications or reports required by terms and conditions in this permit to be 

submitted or "reported in writing" are to be submitted to Ohio EPA through the Ohio EPA's 

eBusiness Center: Air Services web service ("Air Services"). Ohio EPA will accept hard copy 

submittals on an as-needed basis if the permittee cannot submit the required documents 

through the Ohio EPA eBusiness Center. In the event of an alternative hard copy submission in 

lieu of the eBusiness Center, the post-marked date or the date the document is delivered in 

person will be recognized as the date submitted. Electronic submission of applications, 

notifications or reports required to be submitted to Ohio EPA fulfills the requirement to submit 

the required information to the Director, the appropriate Ohio EPA District Office or contracted 

Page 6 of 43 
�!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 

local air agency, and/or any other individual or organization specifically identified as an 

additional recipient identified in this permit unless otherwise specified. Consistent with OAC rule 

37 45-15-03, the electronic signature date shall constitute the date that the required application, 

notification or report is considered to be "submitted". Any document requiring signature may be 

represented by entry of the personal identification n umber (PIN) by responsible official as part of 

the electronic submission process or by the scanned attestation document signed by the 

Authorized Representative that is attached to the electronically submitted written report. 

Any document (including reports) required to be submitted and required by a federally 

applicable requirement in this permit shall include a certification by a Responsible Official that, 

based on information and belief formed after reasonable inquiry, the statements in the 

document are true, accurate, and complete. 

b) Upon presentation of credentials and other documents as may be required by law, the permittee 

shall allow the Director of the Ohio EPA or an authorized representative of the Director to: 

( 1) At reasonable times, enter upon the permittee's premises where a source is located or 

the emissions-related activity is conducted, or where records must be kept under the 

conditions of this permit. 

(2) Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of this permit, subject to the protection from disclosure to the public of 

confidential information consistent with ORC section 3704.08. 

(3) Inspect at reasonable times any facilities, equipment (including monitoring and air 

pollution control equipment), practices, or operations regulated or required under this 

permit. 

( 4) As authorized by the Act, sample or monitor at reasonable times substances or 

parameters for the purpose of assuring compliance with the permit and applicable 

requirements. 

c) The permittee shall submit progress reports to the Ohio EPA DAPC, Southeast District Office 

concerning any schedule of compliance for meeting an applicable requirement. Progress 

reports shall be submitted semiannually or more frequently if specified in the applicable 

requirement or by the Director of the Ohio EPA. Progress reports shall contain the following: 

( 1) Dates for achieving the activities, milestones, or compliance required in any schedule of 

compliance, and dates when such activities, milestones, or compliance were achieved. 

(2) An explanation of why any dates in any schedule of compliance were not or will not be 

met, and any preventive or corrective measures adopted. 

7. Best Available Technology 

As specified in OAC Rule 3745-31 -05, new sources that must employ Best Available Technology (BAT) 

shall comply with the Applicable Emission Limitations/Control Measures identified as BAT for each 

subject emissions unit. 

Page 7 of 43 
�!!!2 

Protection Agency 

8. Air Pollution Nuisance 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

The air contaminants emitted by the emissions units covered by this permit shall not cause a public 

nuisance, in violation of OAC rule 3745-15-07. 

9. Reporting Requirements 

The permittee shall submit required reports in the following manner: 

a) Reports of any required monitoring and/or recordkeeping of state-only enforceable information 

shall be submitted to the Ohio EPA DAPC, Southeast District Office. 

b) Except as otherwise may be provided in the terms and conditions for a specific emissions unit, 

quarterly written reports of (a) any deviations (excursions) from state-only required emission 

limitations, operational restrictions, and control device operating parameter limitations that have 

been detected by the testing, monitoring, and recordkeeping requirements specified in this 

permit, (b) the probable cause of such deviations, and (c) any corrective actions or preventive 

measures which have been or will be taken, shall be submitted to the Ohio EPA DAPC, 

Southeast District Office. If no deviations occurred during a calendar quarter, the permittee 

shall submit a quarterly report, which states that no deviations occurred during that quarter. The 

reports shall be submitted quarterly, by January 31, April 30, July 31, and October 31 of each 

year and shall cover the previous calendar quarters. (These quarterly reports shall exclude 

deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.) 

10. Applicability 

This Permit-to-Install is applicable only to the em1ss1ons unit(s) identified in the Permit-to-Install. 

Separate application must be made to the Director for the installation or modification of any other 

emissions unit(s) not exempt from the requirement to obtain a Permit-to-Install. 

11. Construction of New Sources(s) and Authorization to Install 

a) This permit does not constitute an assurance that the proposed source will operate in 

compliance with all Ohio laws and regulations. This permit does not constitute expressed or 

implied assurance that the proposed facility has been constructed in accordance with the 

application and terms and conditions of this permit. The action of beginning and/or completing 

construction prior to obtaining the Director's approval constitutes a violation of OAC rule 37 45-

31-02. Furthermore, issuance of this permit does not constitute an assurance that the proposed 

source will operate in compliance with all Ohio laws and regulations. Issuance of this permit is 

not to be construed as a waiver of any rights that the Ohio Environmental Protection Agency (or 

other persons) may have against the applicant for starting construction prior to the effective date 

of the permit. Additional facilities shall be installed upon orders of the Ohio Environmental 

Protection Agency if the proposed facilities cannot meet the requirements of this permit or 

cannot meet applicable standards. 

b) If applicable, authorization to install any new em1ss1ons unit included in this permit shall 

terminate within eighteen months of the effective date of the permit if the owner or operator has 

not undertaken a continuing program of installation or has not entered into a binding contractual 

obligation to undertake and complete within a reasonable time a continuing program of 

installation. This deadline may be extended by up to 12 months if application is made to the 

Page 8 of 43 
�!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Director within a reasonable time before the termination date and the permittee shows good 

cause for any such extension. 

c) The permittee may notify Ohio EPA of any emissions unit that is permanently shut down (i.e., 

the emissions unit has been physically removed from service or has been altered in such a way 

that it can no longer operate without a subsequent "modification" or "installation" as defined in 

OAC Chapter 37 45-31) by submitting a certification from the authorized official that identifies the 

date on which the emissions unit was permanently shut down. Authorization to operate the 

affected emissions unit shall cease upon the date certified by the authorized official that the 

emissions unit was permanently shut down. At a minimum, notification of permanent shut down 

shall be made or confirmed by marking the affected emissions unit(s) as "permanently shut 

down" in "Air Services" along with the date the emissions unit(s) was permanently removed 

and/or disabled. Submitting the facility profile update electronically will constitute notifying the 

Director of the permanent shutdown of the affected emissions unit(s). 

d) The provisions of this permit shall cease to be enforceable for each affected emissions unit after 

the date on which an emissions unit is permanently shut down (i.e., emissions unit has been 

physically removed from service or has been altered in such a way that it can no longer operate 

without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31 ). All 

records relating to any permanently shutdown emissions unit, generated while the emissions 

unit was in operation, must be maintained in accordance with law. All reports required by this 

permit must be submitted for any period an affected emissions unit operated prior to permanent 

shut down. At a minimum, the permit requirements must be evaluated as part of the reporting 

requirements identified in this permit covering the last period the emissions unit operated. 

Unless otherwise exempted, no emissions unit certified by the responsible official as being 

permanently shut down may resume operation without first applying for and obtaining a permit 

pursuant to OAC Chapter 3745-31 and OAC Chapter 3745-77 if the restarted operation is 

subject to one or more applicable requirements. 

e) The permittee shall comply with any residual requirements related to this permit, such as the 

requirement to submit a deviation report, air fee emission report, or other any reporting required 

by this permit for the period the operating provisions of this permit were enforceable, or as 

required by regulation or law. All reports shall be submitted in a form and manner prescribed by 

the Director. All records relating to this permit must be maintained in accordance with law. 

12. Permit-To-Operate Application 

The permittee is required to apply for a Title V permit pursuant to OAC Chapter 3745-77. The 

permittee shall submit a complete Title V permit application or a complete Title V permit modification 

application within twelve ( 12) months after commencing operation of the emissions units covered by 

this permit. However, if operation of the proposed new or modified source(s) as authorized by this 

permit would be prohibited by the terms and conditions of an existing Title V permit, a Title V permit 

modification of such new or modified source(s) pursuant to OAC rule 3745-77-04(D) and OAC rule 

3745-77-08(C)(3)(d) must be obtained before operating the source in a manner that would violate the 

existing Title V permit requirements. 

Page 9 of 43 
�!!!2 

Protection Agency 

13. Construction Compliance Certification 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

The applicant shall identify the following dates in the "Air Services" facility profile for each new 

emissions unit identified in this permit. 

a) Completion of initial installation date shall be entered upon completion of construction and prior 

to start-up. 

b) Commence operation after installation or latest modification date shall be entered within 90 days 

after commencing operation of the applicable emissions unit. 

14. Public Disclosure 

The facility is hereby notified that this permit, and all agency records concerning the operation of this 

permitted source, are subject to public disclosure in accordance with OAC rule 37 45-49-03. 

1 5. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable 

Emission Limitations, Operational Restrictions, or Control Device Operating Parameter 

Limitations 

If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which 

states that no deviations occurred during that quarter. The reports shall be submitted quarterly by 

January 31, April 30, July 31 , and October 31 of each year and shall cover the previous calendar 

quarters. 

1 6. Fees 

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 

and OAC Chapter 37 45-78. The permittee shall pay all applicable permit-to-install fees within 30 days 

after the issuance of any permit-to-install. The permittee shall pay all applicable permit-to-operate fees 

within thirty days of the issuance of the invoice. 

1 7. Permit Transfers 

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The new 

owner must update and submit the ownership information via the "Owner/Contact Change" functionality 

in "Air Services" once the transfer is legally completed. The change must be submitted through "Air 

Services" within thirty days of the ownership transfer date. 

1 8. Risk Management Plans 

If the permittee is required to develop and register a risk management plan pursuant to section 1 12(r) of 

the Clean Air Act, as amended, 42 U.S.C. 7401 et seq. ("Act"), the permittee shall comply with the 

requirement to register such a plan. 

1 9. Title IV Provisions 

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee 

shall ensure that any affected emissions unit complies with those requirements. Emissions exceeding 

any allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder, 

are prohibited. 

Page 10 of 43 
�!!!2 

Protection Agency 

B. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Facility-Wide Terms and Conditions 

Page 11 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 0671 010028 

Effective Date: 7/20/2015 

1. All the following facility-wide terms and conditions are federally enforceable with the exception of those 

listed below which are enforceable under state law only: 

a) None. 

2. Nitrogen Oxides (NOx) Budget Trading Program 

OAC Chapter 3745-14 

a) Office of Regulatory Information System Facility Code - 0671010028 

b) The following regulated non-electrical generating unit is subject to the applicable requirements 

specified in OAC Chapter 3745-14 and the annual NOx allowance allocations listed below: 

Emissions Unit 

B002 - Boiler #7 

B003 - Boiler #8 

Annual Allowance for 

Calendar Years 

2004 through 2007 

205 

248 

Each emissions unit identified in Section 2.b) above is a NOx budget unit under OAC rule 3745-

1 4-01 (C)(1 ). 

[OAC rule 3745-14-01(C)(1 )(a)(i)] 

c) The NOx authorized account representative shall submit a complete NOx budget permit 

application in accordance with the deadlines specified in paragraphs (B)(2) and (B)(3) of OAC 

rule 3745-14-03. The NOx authorized account representative shall also submit, in a timely 

manner, any supplemental information that the Director determines is necessary in order to 

review a NOx budget permit application and issue or deny a NOx budget permit. 

[OAC rules 37 45-1 4-01 (E)( 1 )(a)(i), 37 45-14-01 (E)(1 )(a)(ii), and 37 45-14-03(B)( 1 )] 

d) Beginning May 31, 2004, the owners and operators of each NOx budget source and each NOx 

budget unit at the source shall hold NOx allowances available for compliance deductions under 

paragraph (E) of OAC rule 3745-14-06, as of the NOx allowance transfer deadline, in the unit's 

compliance account and the source's overdraft account in an amount not less than the total 

NOx emissions for the control period from the unit, as determined in accordance with OAC rule 

3745-14-08, plus any amount necessary to account for actual utilization under paragraph (C)(5) 

of OAC rule 3745-1 4-05 for the control period. 

[OAC rules 3745-14-01(E)(3)(a) and 3745-14-01(E)(3)(c)] 

e) NOx allowances shall be held in, deducted from, or transferred among NOx allowance tracking 

system accounts in accordance with OAC rules 3745-14-05, 3745-1 4-06, 3745-14-07, and 

3745-1 4-09. 

Page 12 of 43 
�h!2 

Protection Agency 

[OAC rule 3745-1 4-01(E)(3)(d)] 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

f) A NOx allowance shall not be deducted, in order to comply with the requirement under 

paragraph (E)(3)(a) of OAC rule 3745-14-01 , for a control period in a year prior to the year for 

which the NOx allowance was allocated. 

[OAC rule 3745-1 4-01(E)(3)(e)] 

g) Each ton of NOx emitted in excess of the NOx budget emission limitation, as defined in OAC 

rule 3745-14-01(B)(2)(yy), shall constitute a separate violation of OAC Chapter 3745-14, the 

Clean Air Act, and applicable Ohio law. The owners and operators of a NOx budget unit that has 

excess emissions in any control period shall surrender the NOx allowances required for 

deduction under paragraph (E)(4)(a) of OAC rule 3745-1 4-06 and pay any fine, penalty, or 

assessment or comply with any other remedy imposed under paragraph (E)(4)(c) of OAC rule 

3745-14-06. 

[OAC rules 3745-1 4-01 (E)(3)(b), 3745-1 4-01(E)(4)(a) and 3745-1 4-01 (E)(4)(b)] 

h) When recorded by the Administrator pursuant to OAC rules 3745-14-06 and 3745-14-07, every 

allocation, transfer, or deduction of a NOx allowance to or from a NOx budget unit's compliance 

account or the overdraft account of the source where the unit is located is deemed to amend 

automatically, and become a part of, any NOx budget permit of the NOx budget unit by 

operation of law without any further review. 

[OAC rule 3745-14-01(E)(3)(h)] 

i) Except as provided below, the Director shall revise the NOx budget permit, as necessary, in 

accordance with OAC rule 3745-77-08. Each NOx budget permit is deemed to incorporate 

automatically the definitions of terms under paragraph (B) of OAC rule 3745-1 4-01 and, when 

recorded by the Administrator, in accordance with OAC rules 3745-14-06 and 3745-14-07, 

every allocation, transfer, or deduction of a NOx allowance to or from the compliance accounts 

of the NOx budget units covered by the permit or the overdraft account of the NOx budget 

source covered by the permit. 

[OAC rules 3745-1 4-03(D)(2) and 3745-14-03(E)(1 )] 

j) The owner or operator of a NOx budget unit shall comply with the prohibitions under OAC rule 

3745-14-08(A)(5). 

[OAC rule 3745-1 4-08(A)(5)] 

k) The owners and operators of the NOx budget unit shall keep on site at the source each of the 

following documents for a period of five years from the date the document is created: (This 

period may be extended for cause, at any time prior to the end of five years, in writing by the 

Director or Administrator.) 

( 1) the account certificate of representation for the NOx authorized account representative 

for the NOx budget unit and all documents that demonstrate the truth of the statements 

in the account certificate of representation, in accordance with paragraph (D) of OAC 

rule 37 45-14-02, provided that the certificate and documents shall be retained on site at 

Page 13 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

the source beyond such five-year period until such documents are superseded because 

of the submission of a new account certificate or representation changing the NOx 

authorized account representative; 

(2) all emission monitoring information, in accordance with OAC rule 3745-14-08; 

(3) copies of all reports, compliance certifications, and other submissions and all records 

made or required under the NOx budget trading program; and 

(4) copies of all documents used to complete a NOx budget permit application and any 

other submission under the NOx budget trading program or to demonstrate compliance 

with the requirements of the NOx budget trading program. 

[OAC rule 3745-14-01 (E)(5)(a)(i) through (iv)] 

I) The permittee shall operate and maintain equipment to continuously monitor and record 

nitrogen oxides emissions from these emissions units in units of the applicable standard(s). 

Such continuous monitoring and recording equipment shall comply with the requirements 

specified in 40 CFR Part 75. 

Each continuous monitoring system consists of all the equipment used to acquire data and 

includes the sample extraction and transport hardware, sample conditioning hardware, 

analyzers, and data recording/processing hardware and software. This includes all systems 

required to monitor the NOx emission rate, NOx concentration, heat input rate, and stack flow 

rate, in accordance with 40 CFR Parts 75.71 and 75.72. 

The permittee shall comply with the initial and re-certification procedures of 40 CFR Part 75. 

The permittee shall maintain on-site documentation from the USEPA or the Ohio EPA that the 

continuous nitrogen oxides monitoring system has been certified in accordance with 40 CFR 

Part 75. The letter of certification shall be made available to the Director upon request. 

The permittee shall maintain records of the following data obtained by the continuous nitrogen 

oxides monitoring system: emissions of nitrogen oxides in lb/millionBtu actual heat input on an 

hourly average basis, emissions of nitrogen oxides in lbs/hr, results of daily zero/span 

calibration checks, and magnitude of manual calibration adjustments. 

Whenever the monitoring system fails to meet the quality assurance or data validation 

requirements of 40 CFR Part 75, data shall be substituted using the applicable procedures in 

Subpart D, Appendix D, or Appendix E of 40 CFR Part 75. 

[OAC rules 3745-14-01(E)(2)(a), 3745-14-01 (E)(5)(a)(ii), 3745-14-08(A)(2)(a) through (A)(2)(d), 

3745-14-08(8)(1), and 3745-14-08(C)(1 )] 

m) The permittee shall comply with the monitoring plan requirements of 40 CFR Part 75.62, except 

that the monitoring plan shall also include all of the information required by Subpart H of 40 CFR 

Part 75. 

[OAC rule 3745-1 4-08(E)(2)(a)] 

Page 14 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

n) The NOx authorized account representative of the NOx budget unit shall submit the reports and 

compliance certifications required under the NOx budget trading program, including those under 

OAC rules 3745-14-04 and 3745-14-08, to the Director and Administrator. 

[OAC rule 3745-14-01(E)(5)(b)] 

o) Each submission under the NOx budget trading program shall be submitted, signed, and 

certified by the NOx authorized account representative for each NOx budget source on behalf of 

which the submission is made. Each such submission shall include the following certification 

statement by the NOx authorized account representative: 

"I am authorized to make this submission on behalf of the owners and operators of the NOx 

budget sources or NOx budget units for which the submission is made. I certify under penalty of 

law that I have personally examined, and am familiar with, the statements and information 

submitted in this document and all its attachments. Based on my inquiry of those individuals 

with primary responsibility for obtaining the information, I certify that the statements and 

information are to the best of my knowledge and belief true, accurate, and complete. I am aware 

that there are significant penalties for submitting false statements and information or omitting 

required statements and information, including the possibility of fine or imprisonment." 

If the NOx authorized account representative for a NOx budget unit subject to an acid rain 

emission limitation who signed and certified any submission that is made under Subpart F or G 

of 40 CFR Part 75 and which includes data and information required under OAC rule 3745-14-

08 or Subpart H of 40 CFR Part 75 is not the same person as the designated representative or 

the alternate designated representative for the unit under 40 CFR Part 72, then the submission 

shall also be signed by the designated representative or the alternate designated 

representative. 

[OAC rules 3745-14-02(A)(5) and 3745-1 4-08(E)(1 )(b)] 

p) The NOx authorized account representative shall submit quarterly reports that include all of the 

data and information required in Subpart H of 40 CFR Part 75 for each NOx budget unit (or 

group of units using a common stack) and the data and information in Subpart G of 40 CFR Part 

75. These quarterly excess emission reports shall be submitted by January 30, April 30, July 30 

and October 30 of each year and shall be submitted in the manner specified in Subpart H of 40 

CFR Part 75 and 40 CFR Part 75.64. 

[OAC rules 3745-14-08(E)(4)(a) and 3745-14-08(E)(4)(c)(i)] 

q) The NOx authorized account representative shall submit to the Administrator a compliance 

certification in support of each quarterly report based on a reasonable inquiry of those persons 

with primary responsibility for ensuring that all of the unit's emissions are correctly and fully 

monitored. The compliance certification.shall state that: 

( 1) the monitoring data submitted were recorded in accordance with the applicable 

requirements of OAC rule 3745-14-08 and 40 CFR Part 75, including the quality 

assurance procedures and specifications; and 

(2) for a unit with add-on NOx emission controls and for all hours where data are substituted 

in accordance with 40 CFR Part 75.34(a)(1 ), the add-on emission control were operating 

Page 15 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/201 5 

within the range of parameters listed in the quality assurance program under Appendix B 

of 40 CFR Part 75 and the substitute values do not systematically underestimate the 

NOx emissions. 

[OAC rule 3745-14-08(E)(4)(d)(i) and (ii)] 

r) The NOx authorized account representative for a NOx budget unit shall submit written notice of 

monitoring system certification and re-certification test dates to the Director and the 

Administrator in accordance with 40 CFR Part 75.61. The NOx authorized account 

representative shall submit a certification application to the Administrator, U.S. EPA, Region V 

Office, and the Director within forty-five days after completing all initial or re-certification tests 

required under paragraph (B) of OAC rule 3745-14-08, including the information required under 

Subpart H of 40 CFR Part 75. 

[OAC rules 3745-14-08(D) and 3745-1 4-08(E)(3)] 

s) For each control period in which one or more NOx budget units at a source are subject to the 

NOx budget emission limitation, the NOx authorized account representative of the source shall 

submit to the Director and the Administrator, by November 30 of that year, a compliance 

certification report for each source covering all such units. 

The NOx authorized account representative shall include the following elements in the 

compliance certification report, in a format prescribed by the Administrator, concerning each unit 

at the source and subject to the NOx budget emission limitation for the control period covered 

by the report: 

( 1) identification of each NOx budget unit; 

(2) at the NOx authorized account representative's option, the serial numbers of the NOx 

allowances that are to be deducted from each unit's compliance account under 

paragraph (E) of OAC rule 3745-14-06 for the control period; 

(3) at the NOx authorized account representative's option, for units sharing a common stack 

and having NOx emissions that are not monitored separately or apportioned in 

accordance with OAC rule 3745-14-08, the percentage of allowances that is to be 

deducted from each unit's compliance account under paragraph (E)(5) of OAC rule 

3745-14-06; and 

(4) the compliance certification under paragraph (A)(3) of OAC rule 3745-14-04. 

[OAC rules 3745-14-04(A)(1) and 3745-14-04(A)(2)] 

t) In the compliance certification report under Section 2.s)(4) above, the NOx authorized account 

representative shall certify, based upon reasonable inquiry of those persons with the primary 

responsibility for operating the source and the NOx budget units at the source in compliance 

with the NOx budget trading program, whether each NOx budget unit for which the compliance 

certification is submitted was operated during the calendar year covered by the report in 

compliance with the requirements of the NOx budget trading program applicable to the unit, 

including all the following: 

Page 16 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

(1) whether the unit was operated in compliance with the NOx budget emission limitation; 

(2) whether the monitoring plan that governs the unit has been maintained to reflect the 

actual operation and monitoring of the unit, and contains all information necessary to 

attribute NOx emissions to the unit, in accordance with OAC rule 3745-1 4-08; 

(3) whether all the NOx emissions from the unit, or group of units (including the unit) using a 

common stack, were monitored or accounted for through the missing data procedures 

and reported in the quarterly monitoring reports, including whether conditional data were 

reported in the quarterly reports in accordance with OAC rule 3745-14-08, and if 

conditional data were reported, the permittee shall indicate whether the status of all 

conditional data has been resolved and all necessary quarterly report submissions have 

been made; and 

(4) whether the facts that form the basis for certification under OAC rule 3745-14-08 of each 

monitor at the unit or group of units (including the unit) using a common stack, or for 

using an excepted monitoring method or alternative monitoring method approved under 

OAC rule 3745-14-08, if any, have changed. If a change is required to be reported under 

Section 2.s )( 4) above, specify the nature of the change, the reason for the change, when 

the change occurred, and how the unit's compliance status was determined subsequent 

to the change, including what method was used to determine emissions when a change 

mandated the need for monitor re-certification. 

[OAC rule 3745-14-04(A)(3)] 

u) The NOx authorized account representative shall submit a complete NOx budget permit renewal 

application for the NOx budget source covering the NOx budget units at the source in 

accordance with paragraph (E) of OAC rule 3745-77-08. 

[OAC rule 3745-1 4-03(B)(3)(a)] 

v) The emission measurements recorded and reported in accordance with OAC rule 3745-14-08 

shall be used to determine compliance by the unit with the NOx budget emission limitation 

under paragraph (E)(3) of OAC rule 3745-14-01. 

[OAC rule 37 45-14-01 (E)(2)(b )] 

w) The permittee shall develop and maintain a written quality assurance/quality control plan for 

each continuous NOx monitoring system designed to ensure continuous valid and 

representative readings of NOx emissions in units of the applicable standard. The plan shall 

follow the requirements of 40 CFR Part 75, Appendix B. The quality assurance/quality control 

plan and a logbook dedicated to the continuous NOx monitoring system must be kept on-site 

and available for inspection during regular office hours. 

[OAC rules 3745-14-08(A)(2)(c) and 3745-1 4-08(A)(2)(d)] 

Note: Ohio EPA DAPC has completed rule amendments for OAC Chapter 3745-14, specifically OAC rule 

3745-1 4-01 and OAC rule 3745-14-06, to facilitate the transition of the affected units from OAC Chapter 

3745-14 into the federal Clean Air Interstate Rule (CAIR) program and to begin the process of "sunsetting" 

the parts of OAC Chapter 3745-14 which will no longer be needed as a result of Ohio's CAIR rules (OAC 

Page 17 of 43 
f!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 0671 01 0028 

Effective Date: 7/20/2015 

Chapter 3745-1 09). The revised applicability section of OAC C hapter 3745-14 allows the rules to remain 

available as a backup until court required revisions to the federal CAIR program have been completed. The 

revision to OAC rule 3745-14-01(C)(2)(a) requires all affected units to be subject to and meet the 

requirements of Ohio's CAIR program beginning in 2009. Should U.S. EPA eliminate or suspend the CAIR 

program, this revision would require these units to revert back and meet the requirements of OAC Chapter 

3745-1 4, provided a NOx allowance tracking system is maintained by U.S. EPA. 

Clean Air Interstate Rule - OAC Chapter 3745-109 

The permittee shall ensure that any CAIR NOx, S02, or NOx ozone season units complies with the 

requirements of OAC Chapter 3745-109, which includes submitting timely permit applications. The 

requirements of this rule will be specified in the Title V permit issued to this facility. 

Page 18 of 43 
tl�!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

C. Emissions Unit Terms and Conditions 

Page 19 of 43 
tl!!!� 

Protection Agency 

1. B002, No.7 Boiler 

Operations, Property and/or Equipment Description: 

Final Permit-to-Install 

P. H. Glatfelter Company · Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Emissions unit B002 (Boiler No. 7) is a wet bottom, pulverized coal-fired boiler (Combustion 

Engineering model VU-405) having a maximum heat input capacity of 422 million Btu per hour, 

capable of firing number 2 fuel oil as backup fuel, and is a backup control device for noncondensable gases (NCG) generated by other facility emissions units. The unit is controlled with 

a cyclone/multi-clone, an electrostatic precipitator (ESP), a low nitrogen oxides concentric firing 

system and a vane close-coupled over fire air compartment (Aistom Power)(Administrative 

modification to PTI # P0103673 issued 3/712011 to align compliance date for the BART 

requirements with the approved Boiler MACT compliance date of January 31, 201 7). 

a) The following emissions unit terms and conditions are federally enforceable with the exception 

of those listed below which are enforceable under state law only. 

(1) None. 

b) Applicable Emissions Limitations and/or Control Requirements 

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit 

along with the applicable rules and/or requirements and with the applicable emissions 

limitations and/or control measures are identified below. Emissions from each unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures 

a. OAC rule 3745-31-05(A)(3) See section c)(2) below. 

b. OAC rule 3745-1 7-07(A) Visible particulate emissions from the 

exhaust stack serving emissions units 

B002 and B003 shall not exceed 20% 

opacity as a 6-minute average, except as 

provided by the rule. 

c. OAC rule 3745-17-10(C)(1) Particulate emissions shall not exceed 

0.10 pound per million Btu of actual heat 

input, when firing coal. The particulate 

emission limitation specified in 40 CFR 

Part 63, Subpart DDDDD for this 

emissions unit, when firing coal, is 

currently more stringent than this 

particulate emission limitation. Unless the 

applicable 40 CFR Part 63, Subpart 

DDDDD emission limitation is revised 

' under "reconsideration", after the 

specified compliance date for this 

emissions unit, this particulate emission 1 

limitation will be less stringent than the · 

particulate emission limitation established 

pursuant to Subpart DDDDD. 

Page 20 of 43 
@!!!� 

Protection Agency 

d. 

e. 

f. 

g. 

h. 

i. 

Applicable Rules/Requirements 

OAC rule 3745-1 7-10(B)(1) 

OAC rule 3745-1 8-77(B)(1) 

OAC Chapters 3745-14 and 3745-

1 09 

. 40 CFR Part 51.308(e) 

Federally enforceable limitation to 

comply with the BART requirements 

of U.S. EPA's Regional Haze 

Regulations. 

I 40 CFR Part 63, Subpart DDDDD 

I 

40 CFR Part 63, Subpart A 

(2) Additional Terms and Conditions 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Applicable Emissions Limitations/Control 

Measures 

Particulate emissions shall not exceed 

0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

The particulate em1ss1on limitation 

specified in 40 CFR Part 63, Subpart 

DDDDD for this emissions unit, when 

firing only number 2 fuel oil, is currently 

more stringent than this particulate 

emission limitation. Unless the applicable 

40 CFR Part 63, Subpart DDDDD 

emission limitation is revised under 

"reconsideration", after the specified 

compliance date for this emissions unit, 

this particulate emission limitation will be 

less stringent than the particulate 

emission limitation established pursuant 

to Subpart DDDDD. 

Sulfur dioxide emissions shall not exceed 

9.9 pounds per million Btu actual heat 

input. After the compliance date listed 

under b)(2)b. below, this emission 

limitation will be less stringent than the · 

emission limitation established pursuant 

to 40 CFR Part 51.308(e) (see b)(1)g. 

below). 

See section b )(2)a. below. 

After the compliance date listed under 

b )(2)b. below, sulfur dioxide emissions 

from emissions units B002 and B003, 

combined, shall not exceed 24,930 

pounds per calendar day. 

See b)(2)c. below. 

Also see 40 CFR Part 63.7500 and Table , 2 to Subpart DDDDD. ' 

See 40 CFR Part 63.7565 and Table 10 

to Subpart DDDDD for the Applicability of 

General Provisions to this Subpart. 

a. Refer to Part B. - Facility-Wide Terms and Conditions of the permit for the 

requirements of OAC Chapter 3745-14 "NOx Budget Trading Program in Ohio" 

and OAC Chapter 3745-109 "Clean Air Interstate Rule." 

Page 21 of 43 
�!!!2 

Protection Agency 

b. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 06710 1 0028 

Effective Date: 7/20/2015 

Emissions units B002 and B003 (Boilers No. 7 and No. 8, respectively) are 

subject to the Best Available Retrofit Technology (BART) requirements of the 

U.S. EPA's Regional Haze Regulations (40 CFR Part 51 , Subpart P). The 

permittee shall operate and maintain control measures constituting an 

"alternative to BART" that will achieve greater reasonable progress than would 

be achieved through installation and operation of BART, as allowed under 40 

CFR Part 51.308(e)(2). 

In addition to using a cyclone/multi-clone and an ESP to control the particulate 

emissions, emissions unit B002 (Boiler No. 7) is equipped with an Alstom Power 

low nitrogen oxides (low-NOx) concentric firing system and a vane close-coupled 

over fire air compartment, which, based upon Ohio EPA's analysis, satisfy the 

BART nitrogen oxides technology requirement. 

The permittee shall achieve the required nitrogen oxides emission reduction by 

not later than January 31, 201 7 by routinely employing the Alstom Power lowNOx concentric firing system and vane close-coupled over fire air compartment, 

on a year-round basis, rather than limiting low-NOx operation to the control 

period (May 1 through September 30) specified in OAC Chapter 3745-1 4. 

The permittee shall achieve the required sulfur dioxide emission reduction, on a 

year-round basis, by not later than January 31 , 2017. As part of this "alternative 

to BART," the permittee shall install, operate, and maintain control technology 

sufficient to meet the emissions limitation in section b)( 1 )g. This may include an 

add-on control device, use of an alternative fuel, use of low sulfur fuel, 

permanent shutdown of emissions unit B002, or a combination of these 

measures. By no later than January 31 , 201 7, the permittee shall submit to Ohio 

EPA an application for modification of this federally enforceable permit. The 

application shall include a compliance plan outlining, at a minimum, the specific, 

selected control technologies and methods of compliance; and these 

requirements, along with any appropriate monitoring, recordkeeping, and 

reporting requirements, shall be incorporated into the federally enforceable 

permit by no later than January 31, 201 7. A continuous emission monitoring 

system ( CEMS) shall be installed for this emissions unit by no later than January 

31 , 2017 to measure and record the daily sulfur dioxide emissions. 

c. This emissions unit will be subject to the applicable requirements specified in 40 

CFR Part 63, Subpart DDDDD when the regulations become effective on 

January 31, 201 7. 

c) Operational Restrictions 

( 1) The quality of the oil burned in this emissions unit shall meet a sulfur content that is 

sufficient to comply with the allowable sulfur dioxide emission limitation specified in 

section b)( 1 )e. above. 

(2) This emissions unit shall not be taken out of service at the same time as both emissions 

units B003 (Boiler No. 8) and B01 3 (Wood Waste Boiler), except during emergency 

outages. Emissions unit B013 shall serve as the primary incineration point for highvolume low concentration NCG. Either emissions unit B002 or B003 shall serve as a 

Page 22 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

backup control device for high-volume low concentration NCG combustion. If emissions 

unit 8002 is permanently shutdown, emissions unit 8003 shall serve as the backup 

control device for high-volume low concentration NCG combustion and shall not be 

taken out of service at the same time as emissions unit 801 3, except during emergency 

outages. 

d) Monitoring and/or Recordkeeping Requirements 

(1) The permittee shall operate and maintain equipment to continuously monitor and record 

the opacity of the visible particulate emissions of the combined emissions from 

emissions units 8002 and 8003. Such continuous monitoring and recording equipment 

shall comply with the requirements specified in 40 CFR Part 60.13. 

The continuous monitoring system consists of all the equipment used to acquire data 

and includes the data recording/processing hardware and software. 

The permittee shall maintain a letter of certification from the Ohio EPA, Central Office 

documenting that the continuous opacity monitoring system has been certified in 

accordance with the requirements of 40 CFR Part 60, Appendix 8, Performance 

Specification 1. The letter of certification shall be made available to the Ohio EPA, 

Southeast District Office upon request. 

The permittee shall maintain records of the following data obtained by the continuous 

opacity monitoring system: percent opacity on a 6-minute block average basis, results of 

daily zero/span calibration checks, and magnitudes of manual calibration adjustments. 

(2) The permittee shall maintain a written quality assurance/quality control plan for the 

continuous opacity monitoring system designed to ensure continuous valid and 

representative readings of opacity. The plan shall include, as a minimum, conducting 

and recording daily automatic zero/span checks, provisions for conducting a quarterly 

audit of the continuous opacity monitoring system, and a description of preventive 

maintenance activities. The quality assurance/quality control plan must be kept on site 

and available for inspection during regular office hours. 

(3) To obtain an exemption pursuant to OAC rule 3745-1 7-07(A)(3)(a)(i) or (A)(3)(b)(i), the 

permittee shall operate and maintain a temperature monitor and recorder that measures 

and records the temperature of the boiler exhaust gases entering the ESP during (a) all 

periods of start-up until the ESP is operational or until the inlet temperature of the ESP 

achieves the temperature level specified in OAC rule 3745-1 7-07(A)(3)(a)(i) and (b) all 

periods of shutdown until the inlet temperature of the ESP drops below the temperature 

level specified in OAC rule 3745-1 7-07(A)(3)(b)(i). An electronic or hardcopy record of 

the temperatures during periods of start-up and shutdown shall be maintained. 

The temperature monitor and recorder shall be installed, calibrated , operated, and 

maintained in accordance with manufacturer's recommendations, with any modifications 

deemed necessary by the permittee, and shall be capable of accurately measuring the 

temperature of the boiler exhaust gases in units of degrees Fahrenheit. 

(4) The permittee shall maintain monthly records of the total quantity of coal burned, and the 

results of the analyses for ash content, sulfur content, heat content, and the average 

Page 23 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

sulfur dioxide em1ss1on rate (in lbs/million Btu). The coal collection and sampling 

procedures and analyses for ash content, sulfur content, and heat content shall be 

performed in accordance with the following: 

The permittee shall collect monthly composite samples of the coal burned in this 

emissions unit A sufficient number of individual samples shall be collected so that each 

composite sample is representative of the average quality of coal burned in this 

emissions unit during each calendar month. The coal sampling shall be performed in 

accordance with the most recent version of ASTM method 02234, Collection of a Gross 

Sample of Coal. 

Each monthly composite sample of coal shall be analyzed for ash content (in percent), 

sulfur content (in percent), and heat content (in Btu/pound). The analytical methods for 

ash content, sulfur content, and heat content shall be the most recent version of: ASTM 

method 031 74, Ash in the Analysis of Coal and Coke; ASTM method 03177, Total 

Sulfur in the Analysis Sample of Coal and Coke or ASTM method 04239, Sulfur in the 

Analysis Sample of Coal and Coke Using High Temperature Tube Furnace Combustion 

Methods; and ASTM method 05865, Gross Calorific Value of Coal and Coke, 

respectively. Alternative, equivalent methods may be used upon written approval from 

the Ohio EPA, Southeast District Office. 

The requirements to analyze the sulfur content of the composite coal sample and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this term 

and condition shall terminate on January 31, 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(S) become effective on that date. 

(5) The permittee shall comply with the requirements of one of the following alternatives 

pertaining to the use of number 2 fuel oil: 

a. Alternative 1: 

For each shipment of oil received for burning in this emissions unit, the permittee 

shall collect or require the oil supplier to collect a representative grab sample of 

oil and maintain records of the total quantity of oil received, the permittee's or oil 

supplier's analyses for sulfur content and heat content, and the calculated sulfur 

dioxide emission rate (in lbs/million Btu). The sulfur dioxide emission rate shall be 

calculated in accordance with the formula specified in OAC rule 3745-1 8-04(F). A 

shipment may be comprised of multiple tank truck loads from the same supplier's 

batch, and the quality of the oil for those loads may be represented by a single 

batch analysis from the supplier. 

b. Alternative 2: 

The permittee shall collect a representative grab sample of oil that is burned in 

this emissions unit for each day when the emissions unit is in operation. If 

additional fuel oil is added to the tank serving this emissions unit on a day when 

the emissions unit is in operation, the permittee shall collect a sufficient number 

of grab samples to develop a composite sample representative of the fuel oil 

Page 24 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

burned in this emissions unit. A representative grab sample of oil does not need 

to be collected on days when this emissions unit is only operated for the purpose 

of "test-firing." The permittee shall maintain records of the total quantity of oil 

burned each day, except for the purpose of test-firing, the permittee's analyses 

for sulfur content and heat content, and the calculated sulfur dioxide emission 

rate (in lbs/million Btu). The sulfur dioxide emission rate shall be calculated in 

accordance with the formula specified in OAC rule 37 45-18-04(F). 

c. The permittee shall perform or require the supplier to perform the analyses for 

sulfur content and heat content in accordance with 40 CFR Part 60, Appendix A, 

Method 19, or the appropriate ASTM methods (such as, ASTM methods 0240 

and 04294), or equivalent methods as approved by the Director. 

The requirements to analyze the sulfur content of the number 2 fuel oil and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this 

term and condition shall terminate on January 31, 2017 because the sulfur 

dioxide continuous monitoring system required under section d)(6) and the 

monitoring and recordkeeping provisions for the pounds per million Btu and 

pounds per calendar day emission limitations under section d)(8) become 

effective on that date. 

(6) By not later than January 31, 2017, the permittee shall install, operate, and maintain 

equipment to continuously monitor and record sulfur dioxide and exhaust gas flow data 

for this emissions unit in units of the applicable standards (pounds per million Btu and 

pounds per calendar day). Such continuous monitoring and recording equipment shall 

comply with the requirements specified in 40 CFR Part 60, Appendix B, Performance 

Specification 6, and be operated in accordance with 40 CFR Part 60.13 unless otherwise 

specified in d)(7) below. 

The pemnittee shall maintain records of all data obtained by the continuous sulfur dioxide 

and exhaust gas flow monitoring system including, but not limited to, minute-by-minute 

concentration data for sulfur dioxide; minute-by-minute flow data in ACFM; sulfur dioxide 

data in pounds per day; the results of all daily, weekly, and quarterly calibration checks; 

and the magnitude of any calibration adjustments. 

Each continuous emissions monitoring system (CEMS) consists of all the equipment 

used to acquire and record data and includes any sample extraction and transport 

hardware, sample conditioning hardware, analyzers, and data recording/processing 

hardware and software. 

The data recorded by the CEMS shall be used to determine compliance with the 

applicable emission limitations on an ongoing basis. 

(7) By not later than April 31 , 2016, the permittee shall develop a written quality 

assurance/quality control plan for the continuous sulfur dioxide and exhaust gas flow 

monitoring system designed to meet all requirements as listed in 40 CFR Part 60, 

Appendix F and ensure continuous valid and representative readings of sulfur dioxide 

and flow. The plan shall describe in detail, complete, step-by-step procedures and 

operations for each of the following activities: 

Page 25 of 43 
�!!!� 

Protection Agency 

a. 

b. 

c. 

d. 

e. 

f. 

calibration of CEMS; 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 

calibration drift determination and adjustment of CEMS; 

preventive maintenance of CEMS (including spare parts inventory); 

data recording, calculations, and reporting; 

accuracy audit procedures including sampling and analysis methods; and 

program of corrective action for malfunctioning CEMS. 

The permittee shall be required to complete a CEMS certification relative accuracy test 

audit (RATA), in accordance with the procedures specified in 40 CFR Part 60, Appendix 

F, by not later than January 31, 2017 . From the date of CEMS certification forward, the 

permittee may forego annual RATA requirements as listed in 40 CFR Part 60, Appendix 

F, by completing a quarterly cylinder gas or relative accuracy audit, in accordance with 

40 CFR Part 60, Appendix F, for each quarter of the year. Should any CEMS not pass a 

cylinder gas or relative accuracy audit on the first attempt for two consecutive quarters 

(even though a recalibration or repair allows the second attempted cylinder gas or 

relative accuracy audit to pass), the permittee shall complete a RATA within 60 days of 

the second quarter's failed cylinder gas or relative accuracy audit. The permittee shall 

also complete a RATA for the CEMS within six months prior to the expiration of this 

permit. RATA testing may also be required if the GEMS as listed on the CEMS 

certification letter from the Ohio EPA, Central Office, or any CEMS associated 

equipment, is changed or modified. 

Beginning on January 31, 2017, the permittee shall perform daily zero/span calibration 

drift checks on each sulfur dioxide and flow CEMS for 60 consecutive operating days in 

accordance with the requirements specified in 40 CFR Part 60, Appendix F, section 4. 

If, on the first attempt, the results of each daily zero/span calibration drift check are less 

than the criteria for excessive calibration drift specified in 40 CFR Part 60, Appendix F, 

section 4.3 (as determined by the Ohio EPA, Southeast District Office), the permittee 

shall begin performing zero/span calibration drift checks on a weekly basis. If any 

CEMS should fail a weekly zero/span calibration drift check for two consecutive weeks 

(based on the criteria of being two times over the limit as stated in Appendix F, section 

4.3), the permittee shall perform daily zero/span calibration drift checks until such time 

as 60 consecutive daily zero/span calibration drift checks have been successfully 

completed within the criteria specified in Appendix F, section 4.3. 

The quality assurance/quality control plan and a logbook dedicated to the sulfur dioxide 

and flow CEMS must be kept on site and available for inspection during regular office 

hours. 

(8) By not later than January 31, 2017, the permittee shall maintain daily records of the 

following information: 

a. the total sulfur dioxide emissions from this emissions unit based upon the data 

collected in section d)(6), in pounds per million Btu and pounds per calendar day; 

Page 26 of 43 
�!!!2 

Protection Agency 

b. 

c. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671010028 

Effective Date: 7/20/2015 

the total sulfur dioxide emissions from this emissions unit and emissions unit 

8003, combined, based upon the data collected in section d)(6) for each unit, in 

pounds per calendar day; and 

the identification of any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-1 4) when this emissions unit was in service and 

the unit's low-NOx concentric firing system and vane close-coupled over fire air 

compartment were not operating. 

(9) The permittee shall maintain records for each day when emissions units 8002, 8003, 

and 8013 were all off line and the venting of high-volume low concentration NCG was 

uncontrolled. If emissions unit 8002 is permanently shut down after January 31, 201 7, 

the permittee shall maintain records for each day when emissions units 8003 and 801 3 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

e) Reporting Requirements 

(1) The permittee shall submit reports (hardcopy or electronic format) within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting all instances of opacity values in excess of the limitation specified in 

section b)(1)b. of these terms and conditions, detailing the date, commencement and 

completion times, duration, magnitude (percent opacity), reason (if known), and 

corrective actions taken (if any) of each 6-minute block average above the applicable 

opacity limitations. 

The reports shall also identify any excursions of the start-up and shutdown provisions 

specified in OAC rule 3745-1 7-07(A)(3) and document any continuous opacity 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason, and 

corrective action taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall be included in the quarterly 

report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the date, time, reason, and corrective action taken 

for each time period of monitoring system malfunction. The total operating time of the 

emissions unit and the total operating time of the analyzer while the emissions unit was 

on line also shall be included in the quarterly report. 

These quarterly excess emission reports shall be submitted by January 31, April 30, July 

31, and October 31 of each year, and each report shall address the data obtained during 

the previous calendar quarter. 

(2) The permittee shall submit quarterly deviation (excursion) reports that identify whenever 

a monthly composite sample collected pursuant to section d)(4) above indicates a 

deviation from the allowable sulfur dioxide emission rate. These reports shall be 

submitted in accordance with the reporting requirements specified in the Standard 

Terms and Conditions of this permit. 

Page 27 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31, 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(3) The permittee shall notify the Ohio EPA, Southeast District Office in writing of any record 

that shows a deviation of the allowable sulfur dioxide emission limitation based upon the 

calculated sulfur dioxide emission rates from section d)(5) above when firing number 2 

fuel oil. The notification shall include a copy of such record and shall be sent to the Ohio 

EPA. Southeast District Office. These reports shall be submitted in accordance with the 

reporting requirements specified in the Standard Terms and Conditions of this permit. 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(4) The permittee shall submit quarterly deviation (excursion) reports that identify any period 

of time when emissions units B002, B003, and B013 were all off line and the venting of 

high-volume low concentration NCG was uncontrolled. If emissions unit B002 is 

permanently shut down after January 31, 2017, the permittee shall submit deviation 

(excursion) reports that identify any period of time when emissions units B003 and B013 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

(5) Beginning in calendar year 201 7, the permittee shall submit reports within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting the date, commencement and completion times. duration. magnitude, 

reason (if known). and corrective actions taken (if any), of all instances of sulfur dioxide 

values in excess of the applicable limitations (pounds per million Btu and pounds per 

calendar day) specified in this permit. 

The reports shall document any continuous sulfur dioxide and exhaust gas flow 

monitoring system downtime while the emissions unit was on line (date, time. duration 

and reason) along with any corrective action(s) taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time. reason and 

corrective action(s) taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall also be included in the 

quarterly report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the emissions unit operating time during the 

reporting period and the date. time, reason. and corrective action(s) taken for each time 

period of emissions unit, control equipment. and/or monitoring system malfunctions. The 

total operating time of the emissions unit and the total operating time of the analyzer 

while the emissions unit was on line also shall be included in the quarterly report. These 

Page 28 of 43 
!!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P011 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 

quarterly excess emission reports shall be submitted by January 31 , April 30, July 31, 

and October 31 of each year and shall address the data obtained during the previous 

calendar quarter. 

(6) Beginning in calendar year 201 7, the permittee shall submit quarterly deviation 

(excursion) reports that identify any days (excluding any days within the "control period" 

specified in OAC Chapter 37 45-14) when this emissions unit was in service and the 

unit's low-NOx concentric firing system and vane close-coupled over fire air 

compartment were not operating. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

f) Testing Requirements 

(1) Compliance with the emission limitations in section b)(1) of these terms and conditions 

shall be determined in accordance with the following methods: 

a. Emission Limitation: 

Visible particulate emissions from the exhaust stack serving emissions units 

B002 and B003 shall not exceed 20% opacity as a 6-minute average, except as 

provided by the rule. 

Applicable Compliance Methods: 

If required, compliance with this emtsston limitation shall be demonstrated 

through visible emission observations performed in accordance with 40 CFR Part 

60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-

03(B)(1 ). 

Ongoing compliance with this emission limitation may be demonstrated based 

upon the records required pursuant to section d)(1 ). 

b. Emission Limitation: 

Particulate emissions shall not exceed 0.10 pound per million Btu of actual heat 

input, when firing coal. 

Applicable Compliance Method: 

If required, compliance with this emtsston limitation shall be demonstrated 

through emission tests performed in accordance with 40 CFR Part 60, Appendix 

A, Methods 1 through 5 and the procedures specified in OAC rule 3745-1 7-

03(B)(9). 

c. Emission Limitation: 

Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

Page 29 of 43 
rlh!2 

Protection Agency 

Applicable Compliance Method: 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Compliance with this emission limitation may be determined by multiplying an 

emission factor of 2.0 pounds of particulates per 1 000 gallons of fuel oil fired by 

the emissions unit's maximum hourly fuel oil firing capacity ( 1 584 gallons/hr}, 

dividing by the emissions unit's rated heat input capacity ( 422 million Btu/hr), and 

dividing by 1 000. This emission factor is specified in U.S. EPA reference 

document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, 

Section 1 .3, Table 1 .3-1 (5/1 0). 

If required, the permittee shall demonstrate compliance with this emission 

limitation through emission tests performed in accordance with 40 CFR Part 60, 

Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 

3745-1 7-03(B)(9). 

d. Emission Limitation: 

Sulfur dioxide emissions shall not exceed 9.9 pounds per million Btu actual heat 

input. 

Applicable Compliance Methods: 

When firing fuel oil, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d}(5). 

When firing coal, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(4). 

On and after installation and operation of the control technology required under 

section b )(2)b. above is complete, compliance with this sulfur dioxide emission 

limitations shall be demonstrated based upon the records required pursuant to 

sections d)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

e. Emission Limitation: 

By not later than January 31, 201 7, sulfur dioxide emissions from emissions units 

B002 and B003, combined, shall not exceed 24,930 pounds per calendar day. 

Applicable Compliance Method: 

Compliance with this sulfur dioxide emission limitation shall be demonstrated 

based upon the records required pursuant to sections d)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

Page 30 of 43 
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Protection Agency 

g) Miscellaneous Requirements 

(1) None. 

Page 31 of 43 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015 
�1l!� 

Protection Agency 

2. 8003, No. 8 Boiler 

Operations, Property and/or Equipment Description: 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Emissions unit B003 (Boiler No. 8) is a wall-fired, pulverized coal-fired boiler 

(Aistom/Combustion Engineering) having a maximum heat input capacity of 505 million Btu per 

hour, capable of firing number 2 fuel oil as backup fuel, and is a backup control device for noncondensable gases (NCG) generated by other facility emissions units. The emissions unit is 

controlled with a cyclone/multi-clone, four low-NOx staged-combustion burners (Advanced 

Combustion Technology), and an electrostatic precipitator (Environmental Elements Dry 

Precipitator) (Administrative modification to PTI # P0103673 issued 3/7/2011 to align 

compliance date for the BART requirements with the approved Boiler MACT compliance date of 

January 31, 2017). 

a) The following emissions unit terms and conditions are federally enforceable with the exception 

of those listed below which are enforceable under state law only. 

(1 ) None. 

b) Applicable Emissions Limitations and/or Control Requirements 

(1) The specific operation(s), property, and/or equipment that constitute each emissions unit 

along with the applicable rules and/or requirements and with the applicable emissions 

limitations and/or control measures are identified below. Emissions from each unit shall 

not exceed the listed limitations, and the listed control measures shall be specified in 

narrative form following the table. 

Applicable Rules/Requirements Applicable Emissions Limitations/Control 

Measures 

a. OAC rule 3745-31-05(A)(3) See section c)(2) below. 

b. OAC rule 3745-1 7-07(A) Visible particulate emissions from the 

exhaust stack serving emissions units 

B002 and B003 shall not exceed 20% 

opacity as a 6-minute average, except as 

provided by the rule. 

OAC rule 3745-1 7-1 0(C)(1) Particulate emissions shall not exceed 

0.10 pound per million Btu of actual heat 

input, when firing coal. The particulate 

1 emission limitation specified in 40 CFR 

Part 63, Subpart DDDDD for this 

emissions unit, when firing coal, is 

I currently more stringent than this 

particulate emission limitation. Unless the 

applicable 40 CFR Part 63, Subpart 

DDDDD emission limitation is revised 

under "reconsideration", after the 

specified compliance date for this 

emissions unit, this particulate emission 

limitation will be less stringent than the 

particulate emission limitation established 

Page 32 of 43 

i 
�!!!2 

Protection Agency 

Applicable Rules/Requirements 

OAC rule 3745-1 7-10(B)(1) 

I 

OAC rule 3745-18-77(B)(1 ) 

OAC Chapters 37 45-14 and 37 45-

1 09 

40 CFR Part 51.308(e) 

Federally enforceable limitation to 

comply with the BART requirements 

of U.S. EPA's Regional Haze 

Reoulations. 

40 CFR Part 63, Subpart DDDDD 

40 CFR Part 63, Subpart A 

(2) Additional Terms and Conditions 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Applicable Emissions Limitations/Control 

Measures 

pursuant to Subpart DDDDD. 

Particulate emissions shall not exceed 

0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

The particulate emission limitation 

specified in 40 CFR Part 63, Subpart 

DDDDD for this emissions unit, when 

firing only number 2 fuel oil, is currently 

more stringent than this particulate 

emission limitation. Unless the applicable 

40 CFR Part 63, Subpart DDDDD 

emission limitation is revised under 

"reconsideration", after the specified 

compliance date for this emissions unit, 

this particulate emission limitation will be 

less stringent than the particulate 

emission limitation established pursuant 

to Subpart DDDDD. ; 

Sulfur dioxide emissions shall not exceed' 

9.9 pounds per million Btu actual heat 

input. After the compliance date listed 

under b )(2)b. below, this emission 

limitation will be less stringent than the 

emission limitation established pursuant 

to 40 CFR Part 51.308(e) (see b)(1 )g. 

below). 

See section b )(2)a. below. 

After the compliance date listed under 

b )(2)b. below, sulfur dioxide emissions 

from emissions units B002 and B003, 

combined, shall not exceed 24,930 

pounds per calendar dav. 

See b )(2)c. below. 

Also see 40 CFR Part 63.7500 and Table 

2 to Subpart DDDDD. 

See 40 CFR Part 63.7565 and Table 10 

to Subpart DDDDD for the Applicability of 

General Provisions to this Subpart. 

a. Refer to Part B. - Facility-Wide Terms and Conditions of the pemnit for the 

requirements of OAC Chapter 3745-14 "NOx Budget Trading Program in Ohio" 

and OAC Chapter 3745-1 09 "Clean Air Interstate Rule." 

Page 33 of 43 
rlh!� 

Protection Agency 

b. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

Emissions units B002 and B003 (Boilers No. 7 and No. 8, respectively) are 

subject to the Best Available Retrofit Technology (BART) requirements of the 

U.S. EPA's Regional Haze Regulations (40 CFR Part 51 , Subpart P). The 

permittee shall operate and maintain control measures constituting an 

"alternative to BART" that will achieve greater reasonable progress than would 

be achieved through installation and operation of BART, as allowed under 40 

CFR Part 51.308(e)(2). 

In addition to using a cyclone/multi-clone and an ESP to control the particulate 

emissions, emissions unit B003 (Boiler No. 8) is equipped with four Advanced 

Combustion Technology low-NOx staged-combustion burners, which, based 

upon Ohio EPA's analysis, satisfy the BART nitrogen oxides technology 

requirement. 

The permittee shall achieve the required nitrogen oxides emission reduction by 

not later than January 31, 2017 by routinely employing the four Advanced 

Combustion Technology staged-combustion burners in their lowest-NOx mode 

on a year-round basis, rather than limiting low-NOx operation to the control 

period (May 1 through September 30) specified in OAC Chapter 3745-1 4. 

The permittee shall achieve the required sulfur dioxide emission reduction, on a 

year-round basis, by not later than January 31 , 201 7. As part of this "alternative 

to BART," the permittee shall install, operate, and maintain control technology 

sufficient to meet the emissions limitation in section b)( 1 )g. This may include an 

add-on control device, use of an alternative fuel, use of low sulfur fuel, 

permanent shutdown of emissions unit B002, or a combination of these 

measures. By no later than January 31, 201 7, the permittee shall submit to Ohio 

EPA an application for modification of this federally enforceable permit. The 

application shcil

 include a compliance plan outlining, at a minimum, the specific, 

selected control technologies and methods of compliance; and these 

requirements, along with any appropriate monitoring, recordkeeping, and 

reporting requirements, shall be incorporated into the federally enforceable 

permit by no later than January 31 , 201 7. A continuous emission monitoring 

system (CEMS) shall be installed for this emissions unit by no later than January 

31, 201 7 to measure and record the daily sulfur dioxide emissions. 

c. This emissions unit will be subject to the applicable requirements specified in 40 

CFR Part 63, Subpart DDDDD when the regulations become effective on 

January 31, 201 7. 

c) Operational Restrictions 

( 1) The quality of the oil burned in this emissions unit shall meet a sulfur content that is 

sufficient to comply with the allowable sulfur dioxide emission limitation specified in 

section b)(1)e. above. 

(2) This emissions unit shall not be taken out of service at the same time as both emissions 

units B003 (Boiler No. 8) and B013 (Wood Waste Boiler), except during emergency 

outages. Emissions unit B01 3 shall serve as the primary incineration point for highvolume low concentration NCG. Either emissions unit B002 or B003 shall serve as a 

Page 34 of 43 
rl!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

backup control device for high-volume low concentration NCG combustion. If emissions 

unit B002 is permanently shutdown, emissions unit B003 shall serve as the backup 

control device for high-volume low concentration NCG combustion and shall not be 

taken out of service at the same time as emissions unit B01 3, except during emergency 

outages. 

d) Monitoring and/or Record keeping Requirements 

(1) The permittee shall operate and maintain equipment to continuously monitor and record 

the opacity of the visible particulate emissions of the combined emissions from 

emissions units B002 and B003. Such continuous monitoring and recording equipment 

shall comply with the requirements specified in 40 CFR Part 60.13. 

The continuous monitoring system consists of all the equipment used to acquire data 

and includes the data recording/processing hardware and software. 

The permittee shall maintain a letter of certification from the Ohio EPA, Central Office 

documenting that the continuous opacity monitoring system has been certified in 

accordance with the requirements of 40 CFR Part 60, Appendix B, Performance 

Specification 1. The letter of certification shall be made available to the Ohio EPA, 

Southeast District Office upon request. 

The permittee shall maintain records of the following data obtained by the continuous 

opacity monitoring system: percent opacity on a 6-minute block average basis, results of 

daily zero/span calibration checks, and magnitudes of manual calibration adjustments. 

(2) The permittee shall maintain a written quality assurance/quality control plan for the 

continuous opacity monitoring system designed to ensure continuous valid and 

representative readings of opacity. The plan shall include, as a minimum, conducting 

and recording daily automatic zero/span checks, provisions for conducting a quarterly 

audit of the continuous opacity monitoring system, and a description of preventive 

maintenance activities. The quality assurance/quality control plan must be kept on site 

and available for inspection during regular office hours. 

(3) To obtain an exemption pursuant to OAC rule 3745-1 7-07(A)(3)(a)(i) or (A)(3)(b)(i), the 

permittee shall operate and maintain a temperature monitor and recorder that measures 

and records the temperature of the boiler exhaust gases entering the ESP during (a) all 

periods of start-up until the ESP is operational or until the inlet temperature of the ESP 

achieves the temperature level specified in OAC rule 3745-1 7-07(A)(3)(a)(i) and (b) all 

periods of shutdown until the inlet temperature of the ESP drops below the temperature 

level specified in OAC rule 3745-1 7-07(A)(3)(b)(i). An electronic or hardcopy record of 

the temperatures during periods of start-up and shutdown shall be maintained. 

The temperature monitor and recorder shall be installed, calibrated, operated, and 

maintained in accordance with manufacturer's recommendations, with any modifications 

deemed necessary by the permittee, and shall be capable of accurately measuring the 

temperature of the boiler exhaust gases in units of degrees Fahrenheit. 

(4) The permittee shall maintain monthly records of the total quantity of coal burned, and the 

results of the analyses for ash content, sulfur content, heat content, and the average 

Page 35 of 43 
!!!!� 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

sulfur dioxide em1ss1on rate (in lbs/million Btu). The coal collection and sampling 

procedures and analyses for ash content, sulfur content, and heat content shall be 

performed in accordance with the following: 

The permittee shall collect monthly composite samples of the coal burned in this 

emissions unit. A sufficient number of individual samples shall be collected so that each 

composite sample is representative of the average quality of coal burned in this 

emissions unit during each calendar month. The coal sampling shall be performed in 

accordance with the most recent version of ASTM method 02234, Collection of a Gross 

Sample of Coal. 

Each monthly composite sample of coal shall be analyzed for ash content (in percent), 

sulfur content (in percent), and heat content (in Btu/pound). The analytical methods for 

ash content, sulfur content, and heat content shall be the most recent version of: ASTM 

method 031 74, Ash in the Analysis of Coal and Coke; ASTM method 031 77, Total 

Sulfur in the Analysis Sample of Coal and Coke or ASTM method 04239, Sulfur in the 

Analysis Sample of Coal and Coke Using High Temperature Tube Furnace Combustion 

Methods; and ASTM method 05865, Gross Calorific Value of Coal and Coke, 

respectively. Alternative, equivalent methods may be used upon written approval from 

the Ohio EPA, Southeast District Office. 

The requirements to analyze the sulfur content of the composite coal sample and to 

calculate the pounds per million Btu sulfur dioxide emission rate pursuant to this term 

and condition shall terminate on January 31, 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(5) The permittee shall comply with the requirements of one of the following alternatives 

pertaining to the use of number 2 fuel oil: 

a. Alternative 1 : 

For each shipment of oil received for burning in this emissions unit, the permittee 

shall collect or require the oil supplier to collect a representative grab sample of 

oil and maintain records of the total quantity of oil received, the permittee's or oil 

supplier's analyses for sulfur content and heat content, and the calculated sulfur 

dioxide emission rate (in lbs/million Btu). The sulfur dioxide emission rate shall be 

calculated in accordance with the formula specified in OAC rule 3745-1 8-04(F). A 

shipment may be comprised of multiple tank truck loads from the same supplier's 

batch, and the quality of the oil for those loads may be represented by a single 

batch analysis from the supplier. 

b. Alternative 2: 

The permittee shall collect a representative grab sample of oil that is burned in 

this emissions unit for each day when the emissions unit is in operation. If 

additional fuel oil is added to the tank serving this emissions unit on a day when 

the emissions unit is in operation, the permittee shall collect a sufficient number 

of grab samples to develop a composite sample representative of the fuel oil 

Page 36 of 43 
t!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

burned in this emissions unit. A representative grab sample of oil does not need 

to be collected on days when this emissions unit is only operated for the purpose 

of "test-firing." The permittee shall maintain records of the total quantity of oil 

burned each day, except for the purpose of test-firing, the permittee's analyses 

for sulfur content and heat content, and the calculated sulfur dioxide emission 

rate (in lbs/million Btu). The sulfur dioxide emission rate shall be calculated in 

accordance with the formula specified in OAG rule 3745-1 8-04(F). 

c. The permittee shall perform or require the supplier to perform the analyses for 

sulfur content and heat content in accordance with 40 GFR Part 60, Appendix A, 

Method 1 9, or the appropriate ASTM methods (such as, ASTM methods 0240 

and 04294 ), or equivalent methods as approved by the Director. 

The requirements to analyze the sulfur content of the number 2 fuel oil and to calculate 

the pounds per million Btu sulfur dioxide emission rate pursuant to this term and 

condition shall tenminate on January 31, 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(6) By not later than January 31, 2017, the permittee shall install, operate, and maintain 

equipment to continuously monitor and record sulfur dioxide and exhaust gas flow data 

for this emissions unit in units of the applicable standards (pounds per million Btu and 

pounds per day). Such continuous monitoring and recording equipment shall comply 

with the requirements specified in 40 GFR Part 60, Appendix B, Performance 

Specification 6, and be operated in accordance with 40 GFR Part 60.13 unless otherwise 

specified in d)(7) below. 

The penmittee shall maintain records of all data obtained by the continuous sulfur dioxide 

and exhaust gas flow monitoring system including, but not limited to, minute-by-minute 

concentration data for sulfur dioxide; minute-by-minute flow data in AGFM; sulfur dioxide 

data in pounds per day; the results of all daily, weekly, and quarterly calibration checks; 

and the magnitude of any calibration adjustments. 

Each continuous emissions monitoring system (GEMS) consists of all the equipment 

used to acquire and record data and includes any sample extraction and transport 

hardware, sample conditioning hardware, analyzers, and data recording/processing 

hardware and software. 

The data recorded by the GEMS shall be used to determine compliance with the 

applicable emission limitations on an ongoing basis. 

(7) By not later than April 31, 2016, the permittee shall develop a written quality 

assurance/quality control plan for the continuous sulfur dioxide and exhaust gas flow 

monitoring system designed to meet all requirements as listed in 40 GFR Part 60, 

Appendix F and ensure continuous valid and representative readings of sulfur dioxide 

and flow. The plan shall describe in detail, complete, step-by-step procedures and 

operations for each of the following activities: 

Page 37 of 43 
�!!!2 

Protection Agency 

a. 

b. 

c. 

d. 

e. 

f. 

calibration of GEMS; 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

calibration drift determination and adjustment of GEMS; 

preventive maintenance of GEMS (including spare parts inventory); 

data recording, calculations, and reporting; 

accuracy audit procedures including sampling and analysis methods; and 

program of corrective action for malfunctioning GEMS. 

The permittee shall be required to complete a GEMS certification relative accuracy test 

audit (RATA), in accordance with the procedures specified in 40 CFR Part 60, Appendix 

F, by not later than January 31, 201 7. From the date of GEMS certification forward, the 

permittee may forego annual RATA requirements as listed in 40 CFR Part 60, Appendix 

F, by completing a quarterly cylinder gas or relative accuracy audit, in accordance with 

40 CFR Part 60, Appendix F, for each quarter of the year. Should any GEMS not pass a 

cylinder gas or relative accuracy audit on the first attempt for two consecutive quarters 

(even though a recalibration or repair allows the second attempted cylinder gas or 

relative accuracy audit to pass), the permittee shall complete a RATA within 60 days of 

the second quarter's failed cylinder gas or relative accuracy audit. The permittee shall 

also complete a RATA for the GEMS within six months prior to the expiration of this 

permit RAT A testing may also be required if the GEMS as listed on the GEMS 

certification letter from the Ohio EPA, Central Office, or any GEMS associated 

equipment, is changed or modified. 

Beginning on January 31, 201 7, the permittee shall perform daily zero/span calibration 

drift checks on each sulfur dioxide and flow GEMS for 60 consecutive operating days in 

accordance with the requirements specified in 40 CFR Part 60, Appendix F, section 4. 

If, on the first attempt, the results of each daily zero/span calibration drift check are less 

than the criteria for excessive calibration drift specified in 40 CFR Part 60, Appendix F, 

section 4.3 (as determined by the Ohio EPA, Southeast District Office), the permittee 

shall begin performing zero/span calibration drift checks on a weekly basis. If any 

GEMS should fail a weekly zero/span calibration drift check for two consecutive weeks 

(based on the criteria of being two times over the limit as stated in Appendix F, section 

4.3), the permittee shall perform daily zero/span calibration drift checks until such time 

as 60 consecutive daily zero/span calibration drift checks have been successfully 

completed within the criteria specified in Appendix F, section 4.3. 

The quality assurance/quality control plan and a logbook dedicated to the sulfur dioxide 

and flow GEMS must be kept on site and available for inspection during regular office 

hours. 

(8) By not later than January 31 , 201 7, the permittee shall maintain daily records of the 

following information: 

a. the total sulfur dioxide emissions from this emissions unit based upon the data 

collected in section d)(6), in pounds per million Btu and pounds per calendar day; 

Page 38 of 43 
�!!!2 

Protection Agency 

b. 

c. 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

the total sulfur dioxide emissions from this emissions unit and emissions unit 

B002, combined, based upon the data collected in section d)(6)for each unit, in 

pounds per calendar day; and 

the identification of any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and 

the unit's low-NOx staged-combustion burners were not operating at their lowestNOx mode. 

(9) The permittee shall maintain records for each day when emissions units 8002, B003, 

and B013 were all off line and the venting of high-volume low concentration NCG was 

uncontrolled. If emissions unit B002 is permanently shut down after January 31 , 201 7, 

the permittee shall maintain records for each day when emissions units B003 and B013 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

e) Reporting Requirements 

(1) The permittee shall submit reports (hardcopy or electronic format) within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting all instances of opacity values in excess of the limitation specified in 

section b)( 1 )b. of these terms and conditions, detailing the date, commencement and 

completion times, duration, magnitude (percent opacity), reason (if known), and 

corrective actions taken (if any) of each 6-minute block average above the applicable 

opacity limitations. 

The reports shall also identify any excursions of the start-up and shutdown provisions 

specified in OAC rule 3745-1 7-07(A)(3) and document any continuous opacity 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason, and 

corrective action taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall be included in the quarterly 

report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the date, time, reason, and corrective action taken 

for each time period of monitoring system malfunction. The total operating time of the 

emissions unit and the total operating time of the analyzer while the emissions unit was 

on line also shall be included in the quarterly report. 

These quarterly excess emission reports shall be submitted by January 31, April 30, July 

31, and October 31 of each year, and each report shall address the data obtained during 

the previous calendar quarter. 

(2) The permittee shall submit quarterly deviation (excursion) reports that identify whenever 

a monthly composite sample collected pursuant to section d)(4) above indicates a 

deviation from the allowable sulfur dioxide emission rate. These reports shall be 

submitted in accordance with the reporting requirements specified in the Standard 

Terms and Conditions of this permit. 

Page 39 of 43 
Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 0671 01 0028 

Effective Date: 7/20/2015 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(3) The permittee shall notify the Ohio EPA, Southeast District Office in writing of any record 

that shows a deviation of the allowable sulfur dioxide emission limitation based upon the 

calculated sulfur dioxide emission rates from section d)(5) above when firing number 2 

fuel oil. The notification shall include a copy of such record and shall be sent to the Ohio 

EPA, Southeast District Office. These reports shall be submitted in accordance with the 

reporting requirements specified in the Standard Terms and Conditions of this permit. 

The requirements to submit quarterly deviation (excursion) reports pursuant to this term 

and condition shall terminate on January 31 , 2017 because the sulfur dioxide continuous 

monitoring system required under section d)(6) and the monitoring and recordkeeping 

provisions for the pounds per million Btu and pounds per calendar day emission 

limitations under section d)(8) become effective on that date. 

(4) The permittee shall submit quarterly deviation (excursion) reports that identify any period 

of time when emissions units B002, B003, and B013 were all off line and the venting of 

high-volume low concentration NCG was uncontrolled. If emissions unit B002 is 

permanently shut down after January 31, 2017, the permittee shall submit deviation 

(excursion) reports that identify any period of time when emissions units B003 and B013 

were off line and the venting of high-volume low concentration NCG was uncontrolled. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

(5) Beginning in calendar year 2017, the permittee shall submit reports within one month 

following the end of each calendar quarter to the Ohio EPA, Southeast District Office 

documenting the date, commencement and completion times, duration, magnitude, 

reason (if known), and corrective actions taken (if any), of all instances of sulfur dioxide 

values in excess of the applicable limitations (pounds per million Btu and pounds per 

day) specified in this permit. 

The reports shall document any continuous sulfur dioxide and exhaust gas flow 

monitoring system downtime while the emissions unit was on line (date, time, duration 

and reason) along with any corrective action(s) taken. The permittee shall provide the 

emissions unit operating time during the reporting period and the date, time, reason and 

corrective action(s) taken for each time period of emissions unit and control equipment 

malfunctions. The total operating time of the emissions unit and the total operating time 

of the analyzer while the emissions unit was on line shall also be included in the 

quarterly report. 

If there are no excess emissions during the calendar quarter, the permittee shall submit 

a statement to that effect along with the emissions unit operating time during the 

reporting period and the date, time, reason, and corrective action(s) taken for each time 

period of emissions unit, control equipment, and/or monitoring system malfunctions. The 

total operating time of the emissions unit and the total operating time of the analyzer 

while the emissions unit was on line also shall be included in the quarterly report. These 

Page 40 of 43 
�!!!2 

Protection Agency 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 1 8907 

Facility ID: 067101 0028 

Effective Date: 7/20/2015 

quarterly excess emission reports shall be submitted by January 31 , April 30, July 31, 

and October 31 of each year and shall address the data obtained during the previous 

calendar quarter. 

(6) Beginning in calendar year 201 7, the permittee shall submit quarterly deviation 

(excursion) reports that identify any days (excluding any days within the "control period" 

specified in OAC Chapter 3745-14) when this emissions unit was in service and the 

unit's low-NOx staged-combustion burners were not operating at their lowest-NOx mode. 

These reports shall be submitted in accordance with the reporting requirements 

specified in the Standard Terms and Conditions of this permit. 

f) Testing Requirements 

(1) Compliance with the emission limitations in section b)(1) of these terms and conditions 

shall be determined in accordance with the following methods: 

a. Emission Limitation: 

Visible particulate emissions from the exhaust stack serving em1ss1ons units 

B002 and B003 shall not exceed 20% opacity as a 6-minute average, except as 

provided by the rule. 

Applicable Compliance Methods: 

If required, compliance with this em1ss1on limitation shall be demonstrated 

through visible emission observations performed in accordance with 40 CFR Part 

60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-1 7-

03(B)(1 ). 

Ongoing compliance with this emission limitation may be demonstrated based 

upon the records required pursuant to section d)(1 ). 

b. Emission Limitation: 

Particulate emissions shall not exceed 0.10 pound per million Btu of actual heat 

input, when firing coal. 

Applicable Compliance Method: 

If required, compliance with this emission limitation also shall be demonstrated 

through emission tests performed in accordance with 40 CFR Part 60, Appendix 

A, Methods 1 through 5 and the procedures specified in OAC rule 37 45-17-

03(B)(9). 

c. Emission Limitation: 

Particulate emissions shall not exceed 0.020 pound per million Btu of actual heat 

input, when firing only number 2 fuel oil. 

Page 41 of 43 
�!!!2 

Protection Agency 

Applicable Compliance Method: 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility 10: 0671010028 

Effective Date: 7/20/2015 

Compliance with this emission limitation may be determined by multiplying an 

emission factor of 2.0 pounds of particulates per 1 000 gallons of fuel oil fired by 

the emissions unit's maximum hourly fuel oil firing capacity (3504 gallons/hr), 

dividing by the emissions unit's rated heat input capacity (505 million Btu/hr), and 

dividing by 1 000. This emission factor is specified in U.S. EPA reference 

document AP-42, Fifth Edition, Compilation of Air Pollution Emission Factors, 

Section 1 .3, Table 1 .3-1 (5/1 0). 

If required, the permittee shall demonstrate compliance with this emission 

limitation through emission tests performed in accordance with 40 CFR Part 60, 

Appendix A, Methods 1 through 5 and the procedures specified in OAC rule 

3745-1 7-03(B)(9). 

d. Emission Limitation: 

Sulfur dioxide emissions shall not exceed 9.9 pounds per million Btu actual heat 

input. 

Applicable Compliance Methods: 

When firing fuel oil, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(5). 

When firing coal, compliance with this sulfur dioxide emission limitation may be 

demonstrated based upon the records required pursuant to section d)(4). 

On and after installation and operation of the control technology required under 

section b )(2)b. above is complete, compliance with this sulfur dioxide emission 

limitation shall be demonstrated based upon the records required pursuant to 

sections d)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

e. Emission Limitation: 

By not later than January 31, 2017, sulfur dioxide emissions from emissions units 

B002 and B003, combined, shall not exceed 24,930 pounds per calendar day. 

Applicable Compliance Method: 

Compliance with this sulfur dioxide emission limitation shall be demonstrated 

based upon the records required pursuant to sections d)(6) and d)(8). 

Also, if required, the permittee shall demonstrate compliance with the allowable 

sulfur dioxide emission limitation through emission tests performed in accordance 

with 40 CFR Part 60, Appendix A, Methods 1 through 4 and 6 or 6A. 

Page 42 of 43 
�!!!2 

Protection Agency 

g) Miscellaneous Requirements 

(1) None. 

Page 43 of 43 

Final Permit-to-Install 

P. H. Glatfelter Company - Chillicothe Facility 

Permit Number: P01 18907 

Facility 10: 067101 0028 

Effective Date: 7/20/2015