- 

Environmental Consultants 

MODELING PROTOC L FOR ANALYSES OF 

BEST AVAILABLE RETROFIT TECHNOLOGY 

Prepared For: 

Interstate Paper, LLC 

2366 lnterstate Paper Road 

Riceboro, Georgia 31 323 

Prepared By: 

ENVIRONMENTAL PLANNING SPECIALISTS, INC. 

Atlanta, Georgia 

and 

ZEPHYR ENVIRONMENTAL CORPORATION 

Columbia, Maryland 

Engineering Manager 

EPS 

April 2006 

Project Manager 

Zephyr 

2250 North Druid Hills Road Suite 110 Atlanta, GA 30329 Phone (404) 3 15-91 13 Fax (404) 3 15-8509 

email: info(~envplaiming.com web page: www.envplanning .corn 
TABLE OF CONTENTS 

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

2.0 BACKGROUND ............................................................................................................ - 2 - 

2.1 BART OVERVIEW ................................................................................................. .- 2 - 

2.2 INTERSTATE PAPER'S BART ELIGIBILITY ................................................................. - 3 - 

2.2.1 Potential emissions of visibility-impairing pollutants ................................. - 3 - 

2.2.2 Chronological determination .................................................................... - 4 - 

2.2.3 26 source categories ............................................................................... - 4 - 

3.0 FACILITY DESCRIPTION ......................................................................................... - 5 - 

3.1 FACILITY LOCATION ................................................................................................ - 5 - 

3.2 SOURCE CHARACTERISTICS FOR BART-ELIGIBLE EMISSION UNITS .......................... - 8 - 

3.3 CLASS I AREAS WITHIN 300 KM .............................................................................. - 9 - 

4.0 INPUT PROVIDED BY VISTAS ............................................................................ - 11 - 

5.0 OVERVIEW OF CALPUFF MODELING SYSTEM ...................................................... - 13 - 

5.1 CALMET ............................................................................................................ - 13 - 

5.2 CALPUFF .......................................................................................................... - 13 - 

5.3 CALPOST .......................................................................................................... - 13 - 

5.4 POSTUTIL ........................................................................................................ .- 14 - 

6.0 PRESENTATION OF MODELING RESULTS ............................................................. - 15 - 

APPENDICES 

Appendix A 26 Listed Source Categories 

Appendix B February 18, 2005 Letter from EPD 

Appendix C Receptors 

Interstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
1.0 INTRODUCTION 

On February 18, 2005, the Georgia Environmental Protection Division (EPD) notified lnterstate 

Paper LLC (Interstate Paper) that, after using the most recent Best Available Retrofit 

Technology (BART) guidelines, two of its sources were BART-eligible. Specifically, the EPD 

cited a power boiler and a recovery boiler. 

Subsequently, on March 9, 2006, the EPD notified lnterstate Paper via an email that it was 

eligible for BART exemption modeling assistance from the Visibility Improvement State and 

Tribal Association of the Southeast (VISTAS). Specifically, VISTAS will conduct initial modeling 

using CALPUFF to determine lnterstate Paper's contribution to visibility degradation at nearby 

Class I areas; if lnterstate Paper's contribution is found to be less than 0.5 deciviews (dV) then it 

would be exempt from further BART requirements. On the other hand, if its contribution is found 

to be greater than 0.5 dV then it would have to either continue with an additional, more refined 

analysis, or proceed with a determination of BART for its facility. 

Also in that March 9, 2006 email the EPD stipulated that if a source wishes to pursue the 

exemption modeling assistance offered by VISTAS it would need to submit a Modeling Protocol 

to the EPD by May 1, 2006. lnterstate Paper has retained Environmental Planning Specialists, 

Inc. (EPS) and Zephyr Environmental Corporation (Zephyr) to develop the Modeling Protocol. 

This document presents the Modeling Protocol, which was based upon guidance contained in 

VISTAS' "Protocol for the Application of the CALPUFF Model for Analyses of Best Available 

Retrofit Technology (BART)" (December 22, 2005 and revised March 9, 2006), referred to as 

"VISTAS Guidance." Specifically, this Modeling Protocol presents a brief overview of BART, a 

description of lnterstate Paper's facility, what information will be provided by VISTAS, the 

modeling methodology, an overview of the modeling system, and a summary of the format of 

the results. 

Interstate Paper, LLC BART Modeling Protocol 

Riceboro, Georgia -1 - April 2006 
2.0 BACKGROU 

The following sections present background information for this Modeling Protocol including an 

overview of BART requirements and details pertaining to lnterstate Paper's BART eligibility 

determination. 

2.1 BART OVERVIEW 

Published in the Federal Register on July 1, 1999, the U.S. Environmental Protection Agency's 

(EPA's) Regional Haze regulations were established to assist in reaching the goal of preventing 

"...any future, and the remedying of any existing, impairment of visibility in Class I areas which 

impairment results from manmade air pollution" as stipulated by Section 169A of the Clean Air 

Act. In particular, the Regional Haze Rule mandated that States establish goals and develop 

strategies to improve visibility in all 156 Class I areas throughout the country. 

State, local, and tribal agencies throughout the southeastern United States formed VISTAS to 

address regional haze and visibility issues throughout its region, which includes Alabama, 

Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West 

Virginia. VISTAS recognizes that air quality issues that affect Class I areas are regional in 

nature, and are best addressed by cooperation between stakeholders. However, it is important 

to note that VISTAS does not set binding policy for the regulatory agencies within its boundaries 

(such as the EPD), but rather it provides information and assistance to those agencies. 

One of the key components of EPA's visibility regulations is Best Available Retrofit Technology 

(BART). A source is subject to BART (BART-eligible) if it meets the following three criteria: 

1) It has emissions of at least 250 tpy of a visibility-impairing pollutant (defined by VISTAS 

as particulate matter less than ten microns (PMlo), sulfur dioxide (SO2), and oxides of 

nitrogen (NO,). VISTAS has determined that volatile organic compounds (VOC's), 

ammonia (NH3), and particulate matter (PM) are not visibility-impairing pollutants; 

2) It began operation between August 7, 1962 and August 7, 1977; and 

3) It is one of the 26 listed source categories listed in the BART Regional Haze regulations 

(see Appendix A). 

If a source meets all three of these criteria, then it has to proceed with a BART determination. 

Like Best Available Control Technology (BACT), BART is an emissions limitation-not a 

particular control technology. 

Interstate Paper, LLC BART Modeling Protocol 

Riceboro, Georgia -2- April 2006 
The process of determining a source's BART emissions limitation consists of three sequential 

steps: 

I) Determine whether or not a BART-eligible source can be excluded from BART controls 

by demonstrating the source cannot reasonably be expected to cause or contribute to 

visibility impairment in a Class I area. This is typically accomplished through the use of 

an air quality dispersion model such as CALPUFF. 

2) If the BART-eligible source cannot be excluded based on dispersion modeling, 

determine the BART controls by considering various control options and selecting the 

most appropriate option based on a variety of criteria. 

3) Incorporate the BART determination into the applicable State Implementation Plan for 

Regional Haze, due by December 2007. 

2.2 INTERSTATE PAPER'S BART ELIGIBIL~TY 

On February 18, 2005, the EPD sent lnterstate Paper a letter addressing BART eligibility for 

emission units at its facility. Attached to this letter was a spreadsheet addressing four sources: 

a lime kiln, a power boiler, a recovery boiler, and a bubbling fluidized bed boiler. This letter and 

the attachment are provided for reference in Appendix B. 

The following sections present the step-by-step analysis (referred to in Section 2.1) to determine 

whether or not each emission unit is BART-eligible. 

2.2.1 Potential emissions of visibility-impairing pollutants 

The first step is to assess the potential annual emissions of visibility-impairing pollutants. A 

summary of this assessment, taken from the February 18, 2005 letter from EPD to Interstate 

Paper, is given below. 

Table 2-1 Potential emissions of visibility-impairing pollutants 

Emission Unit NO, PMIO Son 

Lime Kiln 149 128 9 

Power Boiler 409 0* 300 

I * Data from EPD not included in the February 18, 2006 letter and attachments (Appendix B) 

1 

lnterstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 

Recovery Boiler 

Bubbling Fluidized Bed Boiler 

350 

250 

0* 

39 

2 

250 
Because the lime kiln does not have the potential to emit more than 250 tpy of any visibilityimpairing pollutant, it is not BART-eligible. However, the power boiler, recovery boiler, and 

bubbling fluidized bed boiler have the potential to emit more than 250 tpy of a visibility-impairing 

pollutant. These units meet the 250 tons-per-year potential emission criterion, and their 

assessment is continued in the next step. 

2.2.2 Chronological determination 

Both the power boiler and recovery boiler were place in operation in 1968 (between August 7, 

1962 and August 7, 1977). These units meet the chronological criterion for BART eligibility. 

The bubbling fluidized bed boiler was installed in 2002 (after August 7, 1977). This unit does 

not meet the chronological criterion, and is not BART-eligible. 

2.2.3 26 source categories 

lnterstate Paper is a kraft pulp mill, one of the 26 named source categories listed in the 

Regional Haze regulations (see Appendix A). lnterstate Paper meets this criterion. 

In summary, considering the three steps above, the two emission units at lnterstate Paper that 

are subject to BART are the power boiler and the recovery boiler. 

lnterstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
3.0 FACILITY DESCRIPTION 

lnterstate Paper, LLC operates a kraft pulp mill that produces unbleached linerboard used in 

corrugated containers. Pine wood chips are purchased from outside sources and stored in a 

chip pile. The chips are reclaimed from the chip pile and charged to one of five batch digesters 

where they are cooked in white liquor (sodium hydroxidelsodium sulfide solution). When the 

cooking process is completed, the digester is opened and the contents are "blown" into a blow 

tank. The pulp is then refined, screened and washed in the three brownstock washers to 

remove the excess spent cooking liquor (black liquor). The black liquor is collected and 

processed in the recovery area. The washed pulp, referred to as stock, is removed from the 

washers, sent through the decker for thickening and stored in high-density stock tanks. 

The stock from the tanks is mixed with internally recycled pulp and certain additives to be 

processed on the paper machine. The paper machine forms the pulp into a continuous web 

(sheet), which is drained, pressed, dried and wound into large rolls of finished linerboard. 

The black liquor from the brownstock washers is reprocessed into white liquor for reuse by 

means of the chemical recovery cycle. The black liquor is concentrated to 45-55 percent solids 

in multiple effect evaporators then to 68 percent solids in the concentrator. The black liquor is 

then fired in the recovery boiler where organics are combusted in a reducing atmosphere, 

producing steam and generating molten sodium carbonate and sodium sulfides. The molten 

salts, called smelt, flow to the smelt dissolving tank in which weak wash from the causticizing 

area is mixed to create an intermediate stream called green liquor. The green liquor is 

processed in the causticizing area, where it is converted into white liquor by slaking with lime 

(calcium oxide) for reuse in the pulp digesting process. 

Additional process steam is provided by a bubbling fluidized bed multi-fuel (primarily wood 

waste) boiler rated at 300 MMBtuIhr. A power boiler (stand-by use only) that has a maximum 

heat input rating of 400 MMBTUIhr and fires natural gas and No. 6 fuel oil also generates 

steam. 

lnterstate Paper is located in Riceboro, Georgia. Situated in southeastern Georgia, the facility is 

just to the west of 1-95, approximately 17 miles west of the Atlantic Ocean and roughly 30 miles 

southwest of Savannah. The local region is depicted in Figure 3-1. 

Interstate Paper, LLC 

Riceboro, Georgia - 

BART Modeling Protocol 

April 2006 
s a more localized vie of the Interstate Paper facility. 

Interstate Paper, LLC BART Modeling Protocol 

Riceboro, Georgia -6- April 2006 
Interstate Paper, LLC 

Riceboro, Georgia 

Figure 3-2 Local Topographic Map 

BART Modeling Protocol 

April 2006 
3.2 SOURCE CHARACTERISTICS FOR BART-ELIGIBLEMISSION UNITS 

As described above, there are two emission units at lnterstate Paper that are BART-eligible: the 

power boiler and the recovery boiler. The location of these sources is shown in Figure 3-3. 

Figure 3-3 Plot Plan 

For the purposes of dispersion modeling, the source characteristics, along with emission rates 

to be modeled, are presented in Tables 3-1 and 3-2, respectively. 

Table 3-1 Source characteristics for modeling 

lnterstate Paper, LLC 

Riceboro, Georgia 

Emission 

Unit 

Power 

Boiler 

Recovery 

Boiler 

BART Modeling Protocol 

April 2006 

UTM Location (m) Base 

Elevation 

( m ) 

50.90 

50.90 

East 

523043 

523043 

North 

3478725 

3478725 

Stack 

Height 

(m) 

46.02 

46.02 

Exit 

Velocity 

@Is) 

14.93 

13.72 

Diameter 

(m) 

1.98 

2.74 

Exit 

Temperature 

( K) 

486.48 

357.64 
Table 3-2 Emission rates for modeling 

Emission Unit 

Power boiler emission rates were determined using actual No. 6 fuel oil usage and sulfur 

content for the period 2002 through 2004 (maximum values occurred in March 2003) and US. 

EPA, AP-42 emissions factors. Recovery boiler emission rates were determined using stack 

test data and AP-42 emission factors as follows: 

Power Boiler 

Recove ry Boiler 

Particulate matter test results dated October 18, 2005 

Sulfur dioxide test results dated April 25, 1996 and actual black liquor solids (BLS) 

production rate of 32.1 1 tonslhr (maximum value occurred in February 2002) 

a Nitrogen oxide emission factor of 2 Iblair-dried ton pulp (ADTP), February 2002 black 

liquor solids (BLS) production rate of 32.1 1 tonslhr, and a conversion factor of 2, I82 Ib 

BLSIADTP. 

Maximum 24-hr emissions (gls) 

There are four Class I areas within 300 km of lnterstate Paper. In the order of closest to most 

distant from lnterstate Paper, they are the Wolf Island Wilderness within the Wolf Island 

National Wildlife Refuge (NWR) in Georgia, the Okefenokee Wilderness within the Okefenokee 

NWR in Georgia, the Cape Romain Wilderness within the Cape Romain NWR in South 

Carolina, and the St. Marks Wilderness within the St. Marks NWR in Florida. 

i 

2.1 

3.2 

lnterstate Paper, LLC 

Riceboro, Georgia 

PMIO NOx 

BART Modeling Protocol 

April 2006 

Son 

49 

0.1 1 

7.8 

7.4 
The location of lnterstate Paper relative to each of these Class I areas is depicted in Figure 3-4. 

Figure 3-4 Distances from lnterstate Paper to nearby Class I Areas 

Note that the next two closest Class I areas are more than 300 km from lnterstate Paper; the 

Bradwell Bay Wilderness is 334 km away, and the Chassahowitzka Wilderness within the 

Chassahowitzka NWR is 343 km away. 

In accordance with the VISTAS Guidance, the receptors to be modeled were taken from the 

National Park Service (found at htt~:llwww2.nature.n~s.nov/air/maos/Rece~torslindex.cfm). 

The specific receptors for the Wolf Island Wilderness, the Okefenokee Wilderness, the Cape 

Romain Wilderness, and the St. Marks Wilderness are presented in Appendix C. 

lnterstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
4.0 INPUT PROVIDED BY VISTAS 

In addition to the information presented in this Modeling Protocol specific to lnterstate Paper 

and the two closest Class I areas, VISTAS will provide two specific items for this analysis: 

VISTAS-specific version of CALPUFF; and, 

CALMET meteorological data. 

Earth Tech, the authors of CALPUFF, has developed a version of CALPUFF specific to 

VISTAS: Version 5.754. This version can be downloaded at the following website: 

htt~://www.src.com/verio/download/downIoad.htm#VISTAS VERSION 

VISTAS will also provide meteorological data for this analysis. Specifically, it will provide 12-km 

CALMET output files for 2001, 2002, and 2003. The 12-km modeling domain is presented in 

Figure 4-1. 

Figure 4-1 VISTAS 12-km CALMET Modeling Domain 

Interstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
These files were developed from MM5 databases developed by EPA for 2001, VISTAS for 

2002, and Midwest RPO for 2003. Details related to the derivation of the meteorological dataset 

are provided in Section 4.3.2 of the VISTAS Guidance. 

Finally, VISTAS will provide a CALPUFF model configuration file to replicate CALPUFF 

modeling done for VISTAS using 12-km CALMET data, including the following: 

e Ozone data used to run CALPUFF, 

e Ammonia data used to run CALPUFF and to partition NO3 in POSTUTIL, 

e Background concentration files for use in POSTUTIL, and 

e All other setup files used in VISTAS 12-km CALPUFF run. 

Interstate Paper, LLC BART Modeling Protocol 

Riceboro, Georgia -12- April 2006 
5.0 OVERVIEW OF CALPUFF MODELING SYSTEM 

VISTAS has selected the CALPUFF modeling system because CALPUFF, along with its 

meteorological model CALMET is designed to properly account for complex terrain (i.e., terrain 

above stack top), large pollutant transport distances, chemical transformation and deposition, 

and other issues related to Class I visibility assessments. 

Brief descriptions of the three main components of the CALPUFF modeling system (CALMET, 

CALPUFF, and CALPOST) are provided below. For more detailed information, see Section 3 of 

the VISTAS Guidance. 

5.1 CALMET 

CALMET is the diagnostic meteorological model in the CALPUFF modeling system. It produces 

three-dimensional wind and temperature fields along with two-dimensional fields of mixing 

heights, surface characteristics, and other variables. 

For more details concerning CALMET, see the flow diagram presented in Figure 1-2 of "A 

User's Guide for the CALMET Meteorological Model (Version 5)," Earth Tech, January 2000. 

?\ 

1 5.2 CALPUFF 

Unlike dispersion models such as ISC3 or AERMOD, CALPUFF is a non-steady-state 

Lagrangian puff transport and dispersion model. CALPUFF is the standard accepted model for 

long-range transport (i.e., beyond 100 km), and has been adopted by EPA as a Guideline Model 

(68 FR 18440-18482). Moreover, it has been recommended for Class I impact assessments by 

the Federal Land Manger's Workgroup (FLAG) and the Interagency Workgroup on Air Quality 

Modeling (IWAQM). 

Specifically, CALPUFF is a dispersion model that simulates releases from sources as "puffs." 

The puffs are transported based upon the meteorological data fields created by CALMET. The 

main output files from CALPUFF are hourly concentration/deposition fluxes for the specified 

receptors; these files are then processed using CALPOST. 

For more details concerning CALPUFF, see the flow diagram presented in Figure 1-3 of "A 

User's Guide for the CALMET Meteorological Model (Version 5)'" Earth Tech, January 2000. 

5.3 CALPOST 

CALPOST is the program that post-processes the output files from CALPUFF according to user 

specifications. In the context of visibility modeling, CALPOST computes extinction coefficients 

and other measures of visibility, for the user-specified averaging times and locations. 

Interstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
For more details concerning CALPOST, see the flow diagram presented in Figure 1-4 of "A 

User's Guide for the CALMET Meteorological Model (Version 5)," Earth Tech, January 2000. 

5.4 POSTUTIL 

POSTUTIL is another postprocessor that sums the contributions of individual sources or groups 

to determine total impacts. It can be used to determine the difference between two sets of 

predicted impacts, a procedure useful in evaluating the effectiveness of BART controls (beyond 

the scope of this modeling). 

For more details concerning POSTUTIL, see Section 3.1.3 of the VISTAS Guidance. 

Interstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
6.0 PRESENTATION OF MODELING RESULTS 

In accordance with the VISTAS Guidance, the results of this analysis will contain the following: 

Map of source location and Class I areas within 300 km of lnterstate Paper (see Figure 

3-4 of this Modeling Protocol) including Wolf Island, Okefenokee, Cape Romain, and St. 

Marks; 

Table with impacts at the four Class I areas within 300 km of lnterstate Paper; 

e Discussion of number of Class I areas with visibility impairment from lnterstate Paper on 

98'h percentile days in each year greater than 0.5 dv (total visibility impairment minus 

impairment on 20% best days for natural background visibility equals delta-dv, the 

visibility impact attributed to lnterstate Paper); and 

0 For the Class I area with the maximum impact, discussion of number of days below the 

98th percentile that lnterstate Paper's impact exceeds 0.5 dv, the number of receptors in 

the Class I area where the impact exceeds 0.5 dv, and the maximum impact. 

A sample table for the results from this modeling is presented below. 

Table 6-1 

Class I 

Area 

Wolf Island 

Okefenokee 

Cape 

Romain 

St. Marks 

Sample table of modeling results 

Distance 

(km) from 

mill to 

Class I 

area 

boundary 

4 1 

lo3 

207 

295 

area for 2001 area for 2002 area for 2003 

I I I I I I I I 

The VISTAS Guidance (see Summary/Recommendations/lII CALPUFF Application for BART, p. 

S-5) recommends the following procedure be followed for using these results: 

1) Compare the highest single 24-hr value across all receptors in the Class I area against 

the threshold of 0.5 dv; if all predicted values are below 0.5 dv the source is not subject 

to BART. 

2) If there are 24-hr values greater than 0.5 dv, the source may proceed with finer grid 

modeling (using a 4-km meteorological grid), or may accept that it is subject to BART 

and proceed directly with determining BART controls. 

lnterstate Paper, LLC 

Riceboro, Georgia 

BART Modeling Protocol 

April 2006 
APPENDIX B 

February 18,2005 LETTER FROM EPD 
. a-as-oC Georra[ia De~artment of Natural Resources . Environmental Protection Dhrblon Air Pratcsctlon Branch 

on piwe COPfdCt Efiaabeth at (464) 363-7103 or via at 


APPENDIX C 

WOLF ISLAND, OKEFENOKEE, CAPE ROMAIN, AND ST. MARKS 

RECEPTORS FROM NWS SITE 
Wolf lsland Wilderness within Wolf lsland NWR 

Wolf lsland Wilderness within Wolf lsland NWR 

FW Wilderness Boundary Source: 

NPS ARD files adjusted wilderness boundaries 

fmm htlp://\iwvw .nationalatlas .gov/atlasftp.Mml FWS NWR Boundary Source: 

http:f~ww.fws.govldata~4gi~boundary.hbTII 

September 12,21103 
Wolf Island Receptors 

(taken from 

Longitude Latitude Elev 

(degs) (degs) ( m ) 

-81.304167 31.304167 1 
Okefenokee Wilderness within Okefenokee NWR 

Qkefenokee Wilderness within Okefwokee NW 

500 Receptors 

M Wilderness Boundary Source: 

t-itlp:fEwww .nationalaUas.gwfaUasftp.Mrnl 

NVS NWR Boundary Source: 

m[P:/Ewww .AN~.g~fdat;llr4gis/bmnday~Mml 

September 12,2003 

++++ 

+*++* 

+++++++$+++ 

+++++*++++++++ 

*++++++++*++**++ 

+++++++9*++9+++++* 

..................... ...................... 

...................... 

+++a+++++++*+++++++**+*+ 

++++++ ++*++++++++++ 

++++++++++++ 

++$+++++++*++ 

+++++++++++++ 

+++*++++9++++9 

+++++++*++++++ 

+++*+++++++++*++ 

+++++++++*+++++ 

*+++++++++++*++ 

++++++++*+*+++++ 

++++++++++++++ 

++++++++++*+* 

*++++++++++++++ 

+++*+*+ 
Okefenokee Receptors 

(taken from h~~://www2.nature.n~s.aov/air/ma~s/Receptors/index.cfm) 

Longitude Latitude Elev 

(degs) (degs) (m) 

-82.19583333 30.5625 36 

-82.1791 6667 30.5625 36 

-82.3791 6667 30.5791 6667 27 

-82.3625 30.5791 6667 27 
11 Lonaitude I Latitude I Elev 

(degs) (degs) (m) 

-82.29583333 30.61 25 36 

-82.2791 6667 30.6125 36 

-82.2625 30.6125 36 

11 Lonaitude I Latitude I Elev 

degs (degs) ( m ) 1 (-82.!125 30.69583333 36 
11 Longitude I Latitude I Elev 11 

(degs) 

-82.39583333 

-82.3791 6667 

(degs) 

30.74583333 

30.74583333 

( m ) 

36 

36 
Longitude Latitude Elev 

(degs) (degs) ( m ) 
11 Longitude I Latitude I Elev 

(degs) (degs) ( m ) 

-82.34583333 30.8291 6667 36 

-82.3291 6667 30.82916667 36 


Longitude Latitude Elev 

(degs) (degs) (m) 

-82.4625 30.92916667 35 

-82.44583333 30.9291 6667 30 

-82.42916667 30.9291 6667 36 

-82.41 25 30.92916667 36 
Longitude Latitude Elev 

(degs) (degs) (m) 

-82.32916667 30.9625 36 

-82.31 25 30.9625 36 

-82.29583333 30.9625 36 

-82.2791 6667 30.9625 36 

Cape Romain Wilderness within Cape Romain NWR 

Cape Rornain W~lderness within Cape Romain NWR 

164 Receptors 

FWS Wilderness Boundary Source 

NPS ARD files adjusted wilderness boundarm 

from http/hw.nationalatlas gw/atlasftp.html FWS NWR Boundary Source 

http://www.fvvs.gov/datalr4g1s/boundary html 

September l5,2OO3 
Cape Romain Receptors 

(taken from 
Longitude I Latitude I Elev 11 

(digs) 

-79.4875 

(degs) 

33.0041 6667 

(m' 1 I 
Longitude Latitude Elev 

(degs) (degs) ( m ) 

-79.47083333 33.0375 1 
11 Longitude I Latitude I Elev 1 

digs (degs) 1 ( -79.:875 33.0625 
St. Marks Wilderness within St. Marks NWR 

St Marks Wilderness Mnthln St MarksNWR 

101 Receptors 

FWS Wdderness Boundary Source NPS ARD files adlusted Ulderness boundalres 

from http Ilwww natlonalatlas govlatlasftp htm I 

FWS NWR Boundary Source 

http ttwwfws govtdatatrrlgislboundary html 

Septem ber 15,2003 
St. Marks Receptors 

(taken from http://www2.nature.nps.~ov/air/maps/Receptors/index.cfm) 

Longitude Latitude 

-84.4541 6667 29.97916667 

-84.4375 29.97916667 
Longitude Latitude Elev 

(degs) (degs) (m) 

-84.09583333 30.10416667 1 

-84.0875 30.1 041 6667 1 

-84.079 16667 30.10416667 1 
11 Longitude I Latitude I Elev 

(degs) 

-84.19583333 

-84.1 875 

(degs) 

30.1291 6667 

30.1291 6667 

( m ) 

1 

2 
Environmental Consultants 

April 28, 2006 

Pete Countney 

Data and Modeling UnitIPlanning and Support Program 

Air Protection Branch 

Georgia Environmental Protection Division 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Re: BART Modeling Protocol 

lnterstate Paper, LLC 

2366 lnterstate Paper Road 

Riceboro, GA 31323 

Dear Mr. Courtney: 

On behalf of lnterstate Paper, LLC, enclosed please find one copy of the Modeling 

Protocol for Analyses of Best Available Retrofit Technology (BART) for the referenced 

facility. The protocol is submitted in response to EPD's electronic mail dated March 9, 

2006. EPD notified lnterstate Paper that it was eligible for BART exemption modeling 

assistance from the Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS). The protocol presents a brief overview of BART, a description of lnterstate 

Paper's facility, what information will be provided by VISTAS, the modeling methodology, 

an overview of the modeling system, and a summary of the format of the results. 

If you have any questions, please call. 

Sincerely, 

~bndal M. Reynolds, p.6 

Engineering Manager 

2250 North Druid Hills Road Suite 1 10 Atlanta, GA 30329 a Phone (404) 3 15-9 1 13 * Fax (404) 3 15-8509 

email: info@envplanning.com * web page: www.envplanning.com