John R. Kasich, Governor MaryTaylor, Lt. Governor ScottJ. 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 ofthe 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) ofOhio's original approved SIP submittal as follows: 1. Extend the compliance date from December 31, 2014 to January 31, 2017.

50WestTown 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 laterthan 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. Ifyou 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 LetterFebruary 6, 2014

Ms. Jennifer VanVlerah GLATFELTER Beyond Paper

Ohio EPA, Division ofAir Pollution Control Lazarus GovernmentCenter P.O. Box 1049 Columbus, Ohio 43216-1049 DearMs. VanVlerah, 

### 'db**·~'DC'** 

### oc:PA Rec 

## ·y U.L\1

.**.~~** t.-



### ZOII1 FEB -7 AM 9: 4

## i

As wediscussed, P.H. Glatfelter Company- ChillicotheFacility (Glatfelter) isrequesting a revision to the compliance dates for the Regional Haze Best Available RetrofitTechnology (BART) requirements. Glatfelter'sfacility includes two (2) sources that are specifically identifiedin the State Implementation Plan (SIP) as affectedunits thatmustcomplywith the requirements ofBART. These same sources, Boilers No.7 (B002) and No.8 (B003), are also affected sources underthe Industrial BoilerMACT (40 CFR Part 63, Subpart DDDDD) regulation. Industrial BoilerMACT (MACT) imposes emission control requirements for a range ofhazardous airpollutants including Carbon Monoxide (CO), Particulate Matter (PM), Mercury (Hg) and Hydrogen Chloride (HCl). As BoilersNo. 7 and No. 8 are affectedbytwo separateregulations, the control technology selected mustbecapahle ofachievingthe emissions limitations ofboth sets ofrequirements. Control technologies for the parameters ofconcern in MACT and BARTinclude scrubbers, flue gas desulfurization, fuel change, boilerfurnacemodifications and electrostatic precipitators among others. The compliance dates for MACT have changed multipletimes. MACT waspublished as a final ruleon September 13, 2004 butwas vacated on June 8, 2007. A revised rulewas proposed inJune 2010, and finalized on March 21, 2011. Theoriginal compliancetimetable for BART,December 31, 2014, wasbased upon, and in aligmnentwith, the compliancetimeframes for MACT. The actual Regional Haze rule allowed complianceup to 5years from approval ofOhio's StateImplementation Plan for Regional Haze. That date would beJuly2, 2017. MACT was subsequently delayed in May of2011 for further reconsideration. Themostrecent version oftheMACT rulewas published onJanuary 31, 2013. Until the limitations set forth in the final Industrial BoilerMACT were fully promulgated, theplanning and design necessary, for aproject ofthis magnitude, was nearly impossible. Glatfelterwas not comfortableimplementing a strategy to address BART Page 1of2

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

withouthaving confidenceitwould also address MACT and notrequire an additional investmentin time,resources and moneythatis notnecessitated in an already strained economy. Given thatthefederal regulations allow BART complianceupto July 2, 2017, Glatfelter requests thatthe BART compliance date berevised to coincidewith the timing ofMACT requirements. As you are aware, dueto the complexityoftheproject, Glatfelterrequested, and Ohio EPA approved, a !-yearextensionrequestto theMACT compliancedeadline (see attached). Glatfelter appreciates your consideration and looks forward to further workingwith Ohio EPA on theserequirements. Glatfelterreserves theright to submit future comments on the SIP as permitted andon the anticipatedrevised permit-to-install for the affected units. Glatfelter's Chillicothe facility and Ohio EPA have worked cooperativelyfor a number of years ontheserequirements and Glatfelter appreciatesthe efforts and considerations ofyou and your staff. Should youhave anyquestions concerning these comments,pleasecontactmeat 740-772-3387. Sincerely,

Katherine A. Wiedeman Director, Environment, Health and Safety KAW/ts attachment

cc: Skip Missimer- Global Director, Environmental Affairs EricWood- 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.comOctober 1, 2013

Mr. Dan Canter Ohio EPA- DAPC Southeast DistrictOffice 2195 Front**Stre~t** Logan, Ohio 

# 4i 138-9031 i GLATFELTER Beyond Paper

Re: ExtensioniRequest- 40 CFRPart63, SubpartDDDDD- NationalEmission Standards for**Hazardou~** AirPollutantsforIndustrial, Commercial, andInstitutional Boilers andProcess Heaters

1 I DearMr. Canter, P.H. Glatfelter ¢ompany- ChillicotheFacility(067!010028) is submitting this Extension of Compliancerequest pursuant to 40 CFR Part 63, Subpart A, 63.6(i) General Provisions and40 CFRPart 63, Subpart DDDDD- National Emission Standards for HazardousAirPollutants for Industrial, Commercial, and Institutional Boilers a11d Process Heaters. Glatfelter has**e~t** (8) industrial emission sources subjectto this rule: 1. No. 7 Qoal Boiler (B002) 2. No. 8 Qoal Boiler(B003) 3. No.6 \liood Residue Boiler (B013) 4. No. 1Phckage Boiler(8014) i 5. No.2 Package Boiler(B015) 6. No. 24 PaperMachine Dryer (P021) 7. No. 12 PaperMachine Dryer(P025) 8. No. 32 CoaterDryers (P350) No. 1Package Jiloiler, No.2PackageBoiler, No. 24 PaperMachineDryer, No. 12 PaperMachine Dryer, and No. 32 Coater Dryers are natural gas fired units. These emission units are not subject to ' emission limits,!but requireperiodic tune ups and a one-time energy assessment. The mill intends to meet the compliance date ofJanuary 31, 2016 for theseemission units; therefore,the extension request does not includ6 those five emissionunits. 

## ' ! Glatfelter is curtentlyevaluating options for complying withthe BoilerMACT emission limitations, as well astheBestjAvailableRetrofit Technology (BART) requirements, forNo.7Coal Boiler and No. 8 Boiler. These dptions include eitherretrofitting new control equipment or conversionto natural gas combustion, ora combination ofboth. Conversionto natural gas combustionwould requireinstallation ofnew gas pipelines and feed systems. Glatfelteris also exploring wet electrostaticprecipitator (WESP) and cotnbustion upgrades to theNo.6 Wood Residue Boilerto complywith the BoilerMACT emission limits.! The necessary equipment selection and design, airpermitting, installation,and start-up forall threeboi1ers will likelyjeopardizeGlatfelter's ability to attain compliancebyJanuary 31, 2016. Page 1ofJ

E!'lvlronmenta! 0f9partmeJ1t, 232 East 8th Street • Chllficothe. OH 45601 U.S.A.**~Phone** 740-772-3893 • Fax**740-772~0014** · www.glatfa!ter.comGlatfelterrespe9tfullyrequests a one-yearextensionfor compliancewith therequirements ofthe following sectidns forthe No. 7 Coal Boiler, No. 8 Coal Boiler, andNo. 6 WoodResidue Boiler:

•

# Requi~ments of40 CFRPart 63, SubpartDDDDD- National Emission Standards for Hazardbus AirPollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters! • Generdl requirements of40 CFR Part 63, SubpartA- General Provisions as specified in40 CFR Part 63, Subpart DDDDD, Table 10. The following is being submitted as requiredby Subpa.rt A, 63.6 (i)(6)(i): (A)Descli!jtion ofthe controlstobeinstal.ledto complywith the standard: Glatfeltbr is evaluating two options for No.7 Coal Boiler andNo. 8Coal Boiler. Oneis conversion ofthese units to bumnatural gas. This project would entail constructionofgas pipelines and feed systems to the Chillicothe mill andtotheboilers. The second option is installajion ofretrotlt control equipment, such as acirculatingdryscrubberand activated carbon injectioh system. A combination ofthese two options is alsobeingreviewed.

. ! Glatfeltbr is evaluating aWESP upgrade and combustion fuel/air ratio optimizations forthe No. 6 Wood Residue Boiler. (B) Compliance schedule: (1) Contracts for emission control systems, orprocess changes for emissioncontrol, are estimatedto be awarded by September2014. (2) On-site constiUction, installation ofemission control equipmentortheprocesschangesis estiinated to beiPitiated by June 2015. (3) On-'site**construction~** installation ofemission control equipment orthe process changes is estimatedto be completedbySeptember2016. (4) Final compliance will beachievedbyJanuary 31, 2017. (C) Currently, No.7 Coal Boiler and No. 8Coal Boilerare controlled with a.multi-clonecollector anddry!ESP. No.6 Wood Residue Boileris controlledwitha wet scrubberand a wetESP. While themill anticipates all three boilers willmeet some ofthenew BoilerMACT stardards, theywill not meet all requirements. However, all oftheboilers are in compliancewith current regulatiOns. Glatfelterrequests a letterreply from Ohio EPAindicating whetherthe requestedcompliance extension will begranted

## h OhioEPAinaccordance with the generalprovisions of40 CFR63 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.comlfyou have anyquestions regardingthis Extension ofCompliancerequest, pleasecontact Kathy Wiedeman at 740-772-3387.

# ¥~ John R Blind Division Vice P;resident, Printing and CarbonlessPapers JRB/kl

cc: Kim Lute Kathy Wieaeman

Page 3of3

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 ofthe 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 ofJanuary 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 atthe 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 ofthe 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 JenniferVan 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 14 15 16 17 18 19 20 21 22 23 24 FRALEY, COOPER & ASSOCIATES 222 East Town Street, Second Floor Columbus, Ohio 43215-4620 (614) 228-0018

- (800) 852-6163 Fax

- I614 I 224-5724 1l 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. 21 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.) 31 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. 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 41 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. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5

# I I I I I I I I

I I I I I I I I

# OhioEPA

Division ofAir Pollution Control Response to Comments Revision to Ohio's State Implementation Plan (SIP) for Regional HazeBART Compliance Date for P.H. Glatfelter Agency Contacts forthis Project Division Contact: (Jennifer Van Vlerah, Division ofAir 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 authorityto consider specific issues related to protection ofthe 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 ofthe commenterfollows the comment in parentheses.

Comment 1:

Response 1: Thank you foryour email alerting us to Ohio's requested Regional Haze SIP revision to extend the BART compliance datefor P.H. Glatfelter. We recognize that the requested extension does fall within the timeframe required underthe 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 commenterthatthe 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 agencyfeels this is being observed by P.H. Glatfelter.

Thank you forthe 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 sulfurfuel, use a combination of measures, or permanently shut down a boiler to achieve a S02 emission limit of24,930 pounds per calendar dayfor 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 EPAfeels 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 agreementwith this extension; due to the extension being within the original regulatory compliance date deadline ofJuly 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