From: Holmes, Jill R. [mailto:JILL.HOLMES@GAPAC.com] 

Sent: Thursday, March 29, 2012 12:51 PM

To: Holloway, Thomas C. (Tom)

Cc: Bill Schrock; John Bradfield; Hanks, Katie P.

Subject: RE: Attention Docket ID No. EPA-HQ-OAR-2007-0544

Mr. Holloway,

Looking at the data changes, the stack parameters for emission units LG09 were revised to 

represent proper conversion from metric to English units. The temperature and velocity 

numbers appear to be accurate. I did notice that I made a mistake on the stack diameter when I 

changed it. The original value of 0.984 ft would be the correct value. You may change it back 

to this original number.

For LG11, the Lime Mud Filters, these sources release at the top of the filter building which is 

very near the 5LK stack location. They are different stacks. I have no specific data on the 

LG11 sources other than the height and the diameter of the angled fan exit. There is very little 

visible plume coming from those sources. Since they also errantly show the same stack IDs,

you could also change the LG11 stack IDs to 542V and 543V for the North (TV#L542) and 

South (TV#L543) Lime Mud Filters, respectively.

Please let me know if this answers your questions or if you need any further information for the 

BCI facility.

Thank you.

Jill R. Holmes

(912) 717-1768 (office)

(912) 399-6284 (cell)
From: Holloway, Thomas C. (Tom) [mailto:tcholloway@rti.org]

Sent: Monday, March 19, 2012 3:46 PM

To: Holmes, Jill R.

Cc: Bill Schrock; John Bradfield; Hanks, Katie P.

Subject: RE: Attention Docket ID No. EPA-HQ-OAR-2007-0544

Ms. Holmes,

We are EPA’s contractor for reviewing the revisions to the NEI file for the pulp and paper industry. We 

have reviewed your corrections to the model risk inputs for your facility (Brunswick Cellulose, NEI8196).

Thank you for taking the time to prepare the corrections.

We have some questions about the stack parameters for emission units LG09 (Slaker Vents L511 and 

L514 & Scrubbers) and LG11 (Lime Mud Filters (North & South) (L542 & L543). Specifically, we noted 

that you revised the stack height and stack diameter for these emission units and wanted to know 

whether there are any changes to be made to the stack temperature and/or exit gas velocity for these

emission units. (We can calculate the exit gas flow rate from the stack diameter and exit gas velocity 

values that are ultimately used.) For example, we noted that you changed the emission release point 

type for emission unit LG11 from fugitive to stack at the same time you revised the stack height and 

diameter and wanted to know whether you would like to change the stack temperature and exit gas 

velocity from the national default values of 72 degrees F and 0.0003 ft (which are assigned to fugitive 

sources) to something else. (If you do not have actual temperature and velocity values available, we can 

assign SCC default values for these parameters.)

We also noted that the latitude and longitude values for the lime mud filters (as revised) are similar to 

the latitude and longitude values for the lime kiln, a conclusion that appears to be supported by the two 

emission units having identical scrubber stack IDs in your mill’s ICR response. If the lime mud filters and 

lime kiln do exhaust through the same stack, we may want to revise the stack parameter and 

latitude/longitude data for the lime mud filters and lime kiln to make them identical. How would you 

like to proceed?

Thanks for looking into this for us. We really appreciate it. Let us know if you have any questions.

Thomas Holloway

RTI International

ppsurvey@rti.org

1-877-834-7065