John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

APR 14 2014 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA, Region 5 

77 West Jackson Blvd. 

Chicago, Illinois 60604 

Re: Revision to Ohio's State Implementation Plan (SIP) for Regional Haze- BART 

Compliance Date for P .H. Glatfelter 

Dear Administrator Hedman: 

On March 11, 2011, Ohio EPA submitted our Regional Haze SIP to U.S. EPA. Ohio's 

SIP was subsequently approved on July 2, 2012 (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. 

On February 6, 2014, Ohio EPA received a request (Appendix A) from P.H. Glatfelter to 

extend the original compliance date to January 31, 2017. This request is discussed in 

detail in the attached fetter and 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 stiff meets U.S. EPA's regulatory compliance date deadlines 

for BART, Ohio EPA is an agreement with this extension. We ask that U.S. EPA revise 

Section 8.5 (page 26) of Ohio's original approved SIP submittal as follows: 

1. Extend the compliance date from December 31, 2014 to January 31, 2017. 

50 West Town Street <11 Suite 700 • P.O. Box 1049 • Columbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644·3020 • (614) 644·3184 (fax) 
2014 BART Extension Request 

Page2 

2. Revise the requirement that P.H. Glatfelter submit an application for modification 

of the federally enforceable permit (that will include a compliance plan outlining, 

at a minimum, the specific, selected control technologies and methods of 

compliance) from December 31, 2013 to requiring the submittal provide for 

sufficient time for Ohio EPA to include these requirements, along with any 

appropriate monitoring, recordkeeping, and reporting requirements, in the 

federally enforceable permit by no later than January 31, 2017. 

3. Revise the requirement that a continuous emission monitoring system (CEMS) to 

be installed prior to January 31, 2017 rather than December 31, 2014. 

Ohio EPA held a public hearing on March 25, 2014 and accepted written comments 

through that date. The Federal Land Managers were consulted and included in the 

public comment process. Appendix B contains the public notice and results of this 

public comment period and hearing. 

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://www.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 614-644-3696 or 

jennifer. vanvlerah@epa .ohio .gov. 

Sincerely, 

Craig W. Butler 

Director 

Enclosures 

-

cc: Bob Hodanbosi, Ohio EPA, DAPC 

John Summerhays, U.S. EPA 
Appendix A 

P.H. Glatfelter's February 6, 2014 Letter 
February 6, 2014 

Ms. Jennifer Van Vlerah 

GLATFELTER 

Beyond Paper 

Ohio EPA, Division of Air Pollution Control 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Dear Ms. Van Vlerah, 

Rec 'db ·~'DC' oc:PA ·y U.L\1 . .~~ t.-

ZOII1 FEB - 7 AM 9: 4 i 

As we discussed, P.H. Glatfelter Company- Chillicothe Facility (Glatfelter) is requesting a 

revision to the compliance dates for the Regional Haze Best Available Retrofit Technology 

(BART) requirements. Glatfelter's facility includes two (2) sources that are specifically 

identified in the State Implementation Plan (SIP) as affected units that must comply with the 

requirements of BART. These same sources, Boilers No.7 (B002) and No.8 (B003), are also 

affected sources under the Industrial Boiler MACT (40 CFR Part 63, Subpart DDDDD) 

regulation. Industrial Boiler MACT (MACT) imposes emission control requirements for a 

range of hazardous air pollutants including Carbon Monoxide (CO), Particulate Matter (PM), 

Mercury (Hg) and Hydrogen Chloride (HCl). 

As Boilers No. 7 and No. 8 are affected by two separate regulations, the control technology 

selected must be capahle of achieving the emissions limitations of both sets of requirements. 

Control technologies for the parameters of concern in MACT and BART include scrubbers, 

flue gas desulfurization, fuel change, boiler furnace modifications and electrostatic 

precipitators among others. The compliance dates for MACT have changed multiple times. 

MACT was published as a final rule on September 13, 2004 but was vacated on June 8, 2007. 

A revised rule was proposed in June 2010, and finalized on March 21, 2011. 

The original compliance timetable for BART, December 31, 2014, was based upon, and in 

aligmnent with, the compliance timeframes for MACT. The actual Regional Haze rule 

allowed compliance up to 5 years from approval of Ohio's State Implementation Plan for 

Regional Haze. That date would be July 2, 2017. MACT was subsequently delayed in May 

of2011 for further reconsideration. The most recent version of the MACT rule was published 

on January 31, 2013. Until the limitations set forth in the final Industrial Boiler MACT were 

fully promulgated, the planning and design necessary, for a project of this magnitude, was 

nearly impossible. Glatfelter was not comfortable implementing a strategy to address BART 

Page 1 of2 

Environmental Department, 232 East 8th Street • Chillicothe, OH 45601 U.S.A • Phone 740~772·3893 • Fax 740-772-0014 

www.glatfelter.com 
GLATFELTER 

Beyond Paper 

without having confidence it would also address MACT and not require an additional 

investment in time, resources and money that is not necessitated in an already strained 

economy. 

Given that the federal regulations allow BART compliance up to July 2, 2017, Glatfelter 

requests that the BART compliance date be revised to coincide with the timing ofMACT 

requirements. As you are aware, due to the complexity of the project, Glatfelter requested, 

and Ohio EPA approved, a !-year extension request to the MACT compliance deadline (see 

attached). 

Glatfelter appreciates your consideration and looks forward to further working with Ohio 

EPA on these requirements. Glatfelter reserves the right to submit future comments on the 

SIP as permitted and on the anticipated revised permit-to-install for the affected units. 

Glatfelter's Chillicothe facility and Ohio EPA have worked cooperatively for a number of 

years on these requirements and Glatfelter appreciates the efforts and considerations of you 

and your staff. 

Should you have any questions concerning these comments, please contact me at 

740-772-3387. 

Sincerely, 

Katherine A. Wiedeman 

Director, Environment, Health and Safety 

KAW/ts 

attachment 

cc: Skip Missimer- Global Director, Environmental Affairs 

Eric Wood- VP, P1inting and Carbonless Papers 

Page 2 of2 

Environmental Department, 232 East 8th Street· Chillicothe, OH 45601 U.S.A. • Phone 740-772-3893 • Fax 740-772-0014 

www .glatfelter .com 
October 1, 2013 

Mr. Dan Canter 

Ohio EPA- DAPC 

Southeast District Office 

2195 Front Stre~t 

Logan, Ohio 4i 138-9031 

i 

GLATFELTER 

Beyond Paper 

Re: ExtensioniRequest- 40 CFR Part 63, Subpart DDDDD- National Emission Standards for 

Hazardou~ Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process 

Heaters 1 

I 

Dear Mr. Canter, 

P.H. Glatfelter ¢ompany- Chillicothe Facility (067!010028) is submitting this Extension of 

Compliance request pursuant to 40 CFR Part 63, Subpart A, 63.6(i) General Provisions and 40 CFR Part 

63, Subpart DDDDD- National Emission Standards for Hazardous Air Pollutants for Industrial, 

Commercial, and Institutional Boilers a11d Process Heaters. 

Glatfelter has e~t (8) industrial emission sources subject to this rule: 

1. No. 7 Qoal Boiler (B002) 

2. No. 8 Qoal Boiler (B003) 

3. No.6 \liood Residue Boiler (B013) 

4. No. 1 Phckage Boiler (8014) 

i 

5. No.2 Package Boiler(B015) 

6. No. 24 Paper Machine Dryer (P021) 

7. No. 12 Paper Machine Dryer (P025) 

8. No. 32 Coater Dryers (P350) 

No. 1 Package Jiloiler, No.2 Package Boiler, No. 24 Paper Machine Dryer, No. 12 Paper Machine 

Dryer, and No. 32 Coater Dryers are natural gas fired units. These emission units are not subject to 

' emission limits,! but require periodic tune ups and a one-time energy assessment. The mill intends to 

meet the compliance date of January 31, 2016 for these emission units; therefore, the extension request 

does not includ6 those five emission units. 

' ! 

Glatfelter is curtently evaluating options for complying with the Boiler MACT emission limitations, as 

well as the BestjAvailable Retrofit Technology (BART) requirements, for No.7 Coal Boiler and No. 8 

Boiler. These dptions include either retrofitting new control equipment or conversion to natural gas 

combustion, or a combination of both. Conversion to natural gas combustion would require installation 

of new gas pipelines and feed systems. Glatfelter is also exploring wet electrostatic precipitator 

(WESP) and cotnbustion upgrades to the No.6 Wood Residue Boiler to comply with the Boiler MACT 

emission limits.! The necessary equipment selection and design, air permitting, installation, and start-up 

for all three boi1ers will likely jeopardize Glatfelter's ability to attain compliance by January 31, 2016. 

Page 1 ofJ 

E!'lvlronmenta! 0f9partmeJ1t, 232 East 8th Street • Chllficothe. OH 45601 U.S.A. ~Phone 740-772-3893 • Fax 740-772~0014 

· www.glatfa!ter.com 
Glatfelter respe9tfully requests a one-year extension for compliance with the requirements of the 

following sectidns for the No. 7 Coal Boiler, No. 8 Coal Boiler, and No. 6 Wood Residue Boiler: 

• Requi~ments of 40 CFR Part 63, Subpart DDDDD- National Emission Standards for 

Hazardbus Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process 

Heaters! 

• Generdl requirements of 40 CFR Part 63, Subpart A- General Provisions as specified 

in 40 CFR Part 63, Subpart DDDDD, Table 10. 

The following is being submitted as required by Subpa.rt A, 63.6 (i)(6)(i): 

(A) Descli!jtion of the controls to be instal.led to comply with the standard: 

Glatfeltbr is evaluating two options for No.7 Coal Boiler and No. 8 Coal Boiler. One is 

conversion of these units to bum natural gas. This project would entail construction of gas 

pipelines and feed systems to the Chillicothe mill and to the boilers. The second option is 

installajion of retrotlt control equipment, such as a circulating dry scrubber and activated carbon 

injectioh system. A combination of these two options is also being reviewed. . ! 

Glatfeltbr is evaluating a WESP upgrade and combustion fuel/air ratio optimizations for the No. 

6 Wood Residue Boiler. 

(B) Compliance schedule: 

(1) Contracts for emission control systems, or process changes for emission control, are 

estimated to be awarded by September 2014. 

(2) On-site constiUction, installation of emission control equipment or the process changes is 

estiinated to be iPitiated by June 2015. 

(3) On-'site construction~ installation of emission control equipment or the process changes is 

estimated to be completed by September 2016. 

(4) Final compliance will be achieved by January 31, 2017. 

(C) Currently, No.7 Coal Boiler and No. 8 Coal Boiler are controlled with a. multi-clone collector 

and dry!ESP. No.6 Wood Residue Boiler is controlled with a wet scrubber and a wet ESP. 

While the mill anticipates all three boilers will meet some of the new Boiler MACT stardards, 

they will not meet all requirements. However, all of the boilers are in compliance with current 

regulatiOns. 

Glatfelter requests a letter reply from Ohio EPA indicating whether the requested compliance extension 

will be granted h Ohio EPA in accordance with the general provisions of 40 CFR 63 and the Ohio 

Administrative Code. 

Page 2 of3 

Environmental Department, 232 East 8th Street • Chillicothe, OH 4560i U.S.A. ·Phone 740-772-3893. Fax 740-772-0014 

v.tWW.glatfelter.com 
lfyou have any questions regarding this Extension of Compliance request, please contact Kathy 

Wiedeman at 740-772-3387. 

¥~ John R Blind 

Division Vice P;resident, Printing and Carbonless Papers 

JRB/kl 

cc: Kim Lute 

Kathy W ieaeman 

Page 3 of3 

Environmental D~partment, 232 East 8th Street • Chllr!cothe, OH 45601 U.SA • Phone 740-772-3893 • Fax 740-772-0014 

, www.glatfefter.com 

Appendix B 

Public Notice and Hearing Results 
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, 2011, Ohio EPA submitted our Regional Haze SIP to U.S. EPA. Ohio's 

SIP was subsequently approved on July 2, 2012 (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, 2017 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 is requesting U.S. EPA revise the approved Regional Haze SIP to allow for a 

compliance date of January 31, 2017 for BART. 

These actions must be noticed to allow public comment and to satisfy USEPA 

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 March 25, 2014 at the following address: 

E-mail: jennifer.vanvlerah@epa.state.oh.us 

Mailing address: Jennifer Van Vlerah 

Ohio Environmental Protection Agency, DAPC 

Lazarus Government Center 

P.O. Box 1049 

Columbus, Ohio 43216-1049 

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 
redesignation request will be conducted as follows: March 25, 2014 at 3:00 PM, in 

Conference Room B at Ohio EPA, 50 West Town Street, Suite 700, Columbus, OH 

43215. 

All interested persons are entitled to attend or be represented at the hearings and give 

written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on March 25, 2014 will be considered by Ohio EPA prior to final 

action on this redesignation. Written statements submitted after March 25, 2014 may be 

considered as time and circumstances permit, but will not be part of the official record 

of the hearing. 

This redesignation and maintenance request is available on Ohio EPA DAPC's Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/haze.aspx. 

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

Jennifer Van Vlerah, (614)-644-3696, or Jennifer.vanvlerah@epa.ohio.gov or mailed to 

Jennifer Van Vlerah at the above address. 
1 BEFORE THE OHIO ENVIRONMENTAL PROTECTION AGENCY 

2 

3 IN RE' 

4 STATE IMPLEMENTATION PLAN 

FOR REGIONAL HAZE. 

5 

6 

7 Public hearing held before Ms. Amber Kent, 

8 Public Involvement Coordinator for Ohio EPA 1 s Public 

9 Interest Center, taken before Diane L. Schad, Court 

10 Reporter, at Ohio EPArs Public Interest Center, 50 West 

11 Town Street, Suite 700, Columbus, Ohio 43215, 

12 commencing on Tuesday, March 25, 2014, at 3:00p.m. 

13 

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23 

24 

FRALEY, COOPER & ASSOCIATES 

222 East Town Street, Second Floor 

Columbus, Ohio 43215-4620 

(614) 228-0018 - (800) 852-6163 

Fax - I 614 I 224-5724 

1 
l 

2 

3 

P R 0 C E E D I N G S 

MS. KENT: My name is Amber Kent. I am a 

4 Public Involvement Coordinator for Ohio Environmental 

5 Protection Agency's Public Interest Center. I will be 

6 presiding over today's public hearing. 

7 Thank you for taking the time to attend this 

8 hearing before Ohio Environmental Protection Agency. 

9 The purpose of the hearing today is to obtain comments 

10 from any interested person regarding Ohio EPA 1 s 

11 proposed action. 

12 The State of Ohio is submitting to U.S. EPA a 

13 revision of the State Implementation Plan for Regional 

14 Haze for the State of Ohio. 

15 All interested persons are entitled to attend 

16 or be represented and to present oral and/or written 

17 comments concerning the proposed action. All written 

18 and oral comments received as part of the official 

19 record will be considered by the Director of Ohio EPA. 

20 To be included in the official record, 

21 written comments must be received by Ohio EPA by the 

22 close of business today, March 25th, 2014. These 

23 comments may be filed with me today or emailed to 

24 jennifervanvlerah@epa.ohio.gov. 

2 
1 All written comments submitted for the record 

2 receive the same consideration as oral testimony given 

3 today. Written statements submitted after today may be 

4 considered as time and circumstances permit, but will 

5 not be part of the official record of the hearing. 

6 If you wish to present oral testimony at this 

7 hearing today and have not already signed the 

8 registration sheet, please do so at this time. 

9 There is no cross-examination of speakers or 

10 representatives of Ohio EPA in public hearings such as 

11 this. Ohio EPA hearings such as this afford citizens 

12 the opportunity to provide comments on the official 

13 record, therefore we will not be able to answer any 

14 questions during the hearing. However, members of the 

15 panel may ask clarifying questions of the person 

16 testifying to ensure the record is as complete and 

17 accurate as possible. 

18 Is there anyone here who wishes to testify at 

19 this time? 

20 (No verbal response.) 

21 As there is no one present who wishes to 

22 provide testimony, we will go off the record for 30 

23 minutes. It is currently 3:07 on March 25th, 2014. 

24 (A recess was taken.) 

3 
1 MS. KENT: We are now back on the record. It 

2 is 3:37. There are no attendees present to present 

3 testimony, so I will remind you that written comments 

4 can be submitted through 5:00 today. 

5 Thank you for attending. The time is now 

6 3:37 and this hearing is adjourned. 

7 

8 Thereupon, on Tuesday, March 25, 2014, at 

9 3:37p.m. the hearing was adjourned. 

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20 

21 

22 

23 

24 

4 
1 CERTIFICATE 

2 

I do hereby certify that the foregoing is a 

3 true and correct transcript of the proceedings taken by 

me in this matter before the Ohio EPA, on Tuesday, 

4 March 25, 2014. 

5 DIANE L. SCHAD, 

COURT REPORTER. 

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5 

Ohio EPA 

Division of Air Pollution Control 

Response to Comments 

Revision to Ohio's State Implementation Plan (SIP) for Regional HazeBART Compliance Date for P.H. Glatfelter 

Agency Contacts for this Project 

Division Contact: (Jennifer Van Vlerah, Division of Air Pollution Control, 614-644-3696, 

jennifer.vanvlerah@epa.ohio.gov) 

Ohio EPA held a public hearing in Columbus, OH on March 25, 2014, regarding the 

revised State Implementation Plan for Regional Haze BART compliance date for P. H. 

Glatfelter. This document summarizes the comments and questions received at the 

public hearing and during the associated comment period, which ended on March 25, 

2014. 

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. 

In an effort to help you review this document, the questions are grouped by topic and 

organized in a consistent format. The name of the commenter follows the comment in 

parentheses. 

Comment 1: 

Response 1: 

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." (Claire O'Dea- USDA Forest 

Service Eastern Region, submitted via email) 

Thank you for your comment. Ohio EPA agrees with the 

commenter that the extension falls within the Federal BART 

rule timeframe ancf; therefore, Ohio EPA believes the 

request should be approvable. The installation and operation 

of BART as expeditiously as practicable is a high priority to 
Comment2: 

Response 2: 

Ohio EPA and the agency feels this is being observed by 

P.H. Glatfelter. 

Thank you for the opportunity to review Ohio's proposed SIP 

revision for P.H. Glatfelter. P.H. Glatfelter is subject to 

an alternative to BART. P.H. Glatfelter is required to install a 

control device, use alternate fuel, use low sulfur fuel, use a 

combination of measures, or permanently shut down a boiler 

to achieve a S02 emission limit of 24,930 pounds per 

calendar day for Boilers 7 and 8 combined. P.H. Glatfelter is 

to comply with the alternative to BART emission limits 

by December 31, 2014. 

We are aware of requirements to add S02 scrubbers to 

satisfy BART at two other similar paper mills. The Georgia 

Pacific mill at Big island, VA has, instead converted the 

subject boiler to natural gas firing. The Georgia Pacific mill in 

Green Bay, WI has a compliance date for adding scrubbers 

(and tail-end selective catalytic reduction) by the end of 

2015. We know of no paper mill (besides Glatfelter) that has 

requested (or received) an extension of its BART compliance 

deadline. 

The Regional Haze Rule requires compliance as 

expeditiously as possible. Similar paper mills have either 

complied or are on a schedule to comply well before the July 

2, 2017 date proposed by Glatfelter. In the absence of a 

compelling reason for an extension, we believe that 

Glatfelter should meet its previously-approved December 31, 

2014 compliance deadline. (Pat Brewer- National Park 

Service, submitted via email) 

Thank you for submitting comments. Ohio EPA feels that 

P.H. Glatfelter's request for a BART compliance deadline 

extension from December 31, 2014 to January 31, 2017 is 

reasonable and they have provided justifiable reasons for 

this request. Ohio EPA is in agreement with this extension; 

due to the extension being within the original regulatory 

compliance date deadline of July 2, 2017. Ohio EPA 

believes this extension should be granted and will be 

sending P. H. Glatfelter's request to U.S. EPA for final 

approval. 

End of Response to Comments