APPENDIX E 

Dalton Hydro, LLC 

Operating Permit RACT provisions 

OP-04-020 

Issued on June 25, 2004 

Only portions highlighted are intended for inclusion in the SIP. 

Strikeout text is not intended for inclusion in SIP. 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill 

State of Vermen 

Agency of Natura l ReseurGes 

Poll uti on V V V V 

W N "A , V 

TITLE V 

Dermittses" 

Owner; , LLG 

762 

v North rv State Street 

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u

oh Q~I 9 (1Q 

vu Salt Lake u City v , Utah 84103 i-vv 

242 (~~nt~n vu v Avenue 

WtGn , MA 02186 

SOUFce! Gilman Paper Mull 

Riversid e AveR ue (P.O. Box 118) 

#OP-04-020 

DEC V V v--v -.-1v 

#AR-A4-A2A 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

FINDINGS OF FACT 

Gempany at their request. 

.,f -I,-I~ onu o rated . . 

/

°

\ PRIOR APPROVALS 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

(D) PERMIT ~APPLICABILITY 

Fee 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Reguiatl9f?SDcrmit to Operate . 

rmaGilfty Allowable Emissions, tonslyear 

0 S02 NOX Go ~ ~ HAP8 

444 95 241 2,366 69 negligible 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Applir.able Requirement from 

§5 204 Open BuFnin 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

e *R'"~T 

(4449tv'q and-5 

ShUtdOWA 

.,u ..  . .y., . 

Ag9R6y -qNBI#9*. 

/'21 Federal RequiFements., 

f dbT'rr . 

~rr r va 9 

RA on-Hatlsla qe 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Nonappler.able Regulations 

nprEAQiN-rv (K) STATE AND FEDERAL ENFo,-« 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

PERMIT CONDITIONS 

Construction and Equipment Specifications 

Operating Limits 

(2) The sulfur content of a ny fuel 6i t combusted in any~fue[ burning equip 

shall not exceed 2.0°lo'by weight . [1o vs:A . §5s6a(d)] 

(3) 

ent at the Facility 

The four (4) Babcock and Wilcox residual oil-fired boilers combined shall consume no 

more than 495,900 gallons of residual oil, based on any rolling twelve (12) calendar 

month basis. [Administrative Order, January 9,1996] 

(5) ?he Pomnittee shall properly operate and maintain its fuel burning equipment in order to 

minimizi~ the generation of air contaminants: Proper operation of the Zurn wood: fired 

boiler 'shall include the foliowing : 

(a) the"~use of good operating pradices when handling, mixing; -arid regulating the 

wood fuel fed into the furnace section of the wood-fired boiler. The Permittee 

shall utilize only wood fuel uncontaminated by glixes, preservatives, oils or similar 

foreign substances. Furkhermore, the moisture conterit of the wood fuel shall not 

exceed sixty (60)percent by weight, ribishall the size of the wood being fired in 

the boiler ;eXCeed-t1IV41 (2) inches by five,.(5~'"inches. "(Administratfve Order, January 0, 1996] 

(b) timization of .the :'overfire arid underFir e'air system tohii,nimize the generation 

the-air cQritamin~h'ts carbon monoxide (CO"), and riitrbgen o x ides (NOO. The 

Permittee submitted r6oorts to the Agency on November 15; '1595 and Match 7, 

1996 determining that the proper operating parameters for the Zurn wood-fired 

boiler at Me am loads betvveen 50,00U Ib/hr and 90;000 Iblhr are: 

Oxy~e"ri: 6.5 _'8.0 % 

Owerfire/Underfire Air 'Ratio*, ' 40/60 to ?O/30 

The PeriXiittee shall operate the Zurh wood-fired boiler within these limits to 

ensure continuous, compliance with the requirement to minimize the generation of 

CO and NO,, [Administrative i~rder, Jan iuary 9,~It996] 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

rowwiromon4c~ 

v,

" 

Errmissii,n 1 imifafions 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

98 9 

a dry basis, 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

: 

e e Reef, 

(15) Emissions of nitrogen oxides (NO,,) in the exhaust of the Zurn wood-fired boiler shall not 

exceed 0.:3 Ibs1MMBTU and a mass discharge rate of_~54 Ibs/hr ; These limits shall, ;be 

based on a rolling twenty-four;hour (24,- hour) average . J Gontink~ing compliance ,wit~ 

these limits shall be determined by the continuous emission monitoring system required 

in Condition (22) of this Permit . This emission limit shall apply at all times except startup and shutdown . Emissions during periods of start-up and shutdown shall comply with 

Condition (24) of this Permit . [Administrative Order, January a, 1 s as] 

(16) Emissions of carbon monoxide (CO) in the exhaust of the Zurn wood-fired boiter shall 

not exceed 3.0 IbsIMMBTU and a mass discharge rateof 540 !bs/hr. These limits shall 

be based on a rolling 24 - hour average: Continuing compliance with these limits shall 

be determined by the, continuous emission monitoring system required by Condition (22) 

of this Permit. This emission limit shall apply `e't aill times except start-up and ,shutdown . 

Emissions during pertvds of start-up and shutdoh shall comply with Condition (24) of 

this Permit" tAdministrative Order, January 8, 1998] 

of the Rpm 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

ComplianGe Testing 

Continuous Emission Monitoring 

(22) ` The Permittee shall install a Continuous Emission Monitoring System ("CEMS'°) to 

measure and permanently record nitrogivn , oxides, carbon monoxide, oxygen 

concentrations ;and stack gas -volurnetric flow rate from the Zurn wood-fired boiler 

exhaust and install a 'Continuous Opacity Monitor gystem ("COMS") to measure and 

permanently record the visible emissions (opacity) from the heating plant exhaust. The 

Permittee shall operate and maintain such system in good working order and as 

specified below: 

(a) , Within 184 days of initial permit issuartce, the COMS must be capable of 

operation . irt compliance with this condition at an installation location that is 

dowrEstrearri firom the exhaust of t}~e Zurn wood=fired' boiler and four (4) oil boilers 

and is re'preseir~tative of the total emissions from all heating plant boilers . 

(b) The CEMS and COM8 must be 

I 

operated 'continuously _and re carding; valid data 

during` all periods of boiler;operation including'those periods of boiler startup, 

shutdown and malfunction; except for periods of CEMS and/or dCUMS Quality 

Control/Quality Assurance ("QA") identified- in the approved QA Plan, CEMS 

and/or COMS routine maintenance, or CEMS and/or COMS uncontrolled 

malfunction . Nevertheless, the Permittee must obtain valid CEMS and COMS 

data for all parameters for a minimum of 90°l0 of the operating hours, based on 

the calendar quarter. 

(c) The CEMS and COMS shall be installed, calibrated, maintained and operated 

according, to the Manufacturer's recommendations and in such a manner as to 

meet the requirements of 40 CFR, Part 60, Subpart A, 60.13, Appendix B, 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Performance Specifications 1, 2, 3, 4 and- 6, 40 GFR, Part 60, 'Appendix F, 

Quality Assurance Procedures; and .- the "Continuous 

11 

Emission M©nitoring 

Requirements" 0;the 

,Vermont 

Air Pollution Control ©ivisiori,'Technical Services 

Section (°TS'S") . 

(d) The Permittee shall develop, impIprYtetit ;and maintain a Quality Assuhance Plan 

("QA Plan") for the CEIVIS and COMS. The Permitteq shall submit a revised QA 

Pan to the TSS within 18,0 days of initia.l Permit issuance . Said -plan shall 

satisfact6rily document acceptable ' instrumentation, monitoring pro6edures, 

calibration procedures, QA/QC procedures, dMa,acquisition and handling and 

reporting procedures as required to demonstrate compliance with this Permit . 

The QA Plan shall also include any emission testing procedures required to 

determine CEMS relative accuracy . The Permittee shall review the QA Plan at 

least once each year and shall revise and,update the QA .Plan as necessary, 

based on °tf~e results of this review, or at the request of the Secretary of the 

Agency of Natural Resources or at any other appr6priate time to accurately 

document CEMS and COIVIS operations . The°Permittee shall notify the, TS $ in 

writing of the,results of the annuaf QA Plan review. All QA Plan modifications are 

subject to _TS$review and shall not be implemented 'until the Permittee has 

received written approval from the TSS. 

(e) The Permittee shall submit 'a summary; report for each calendar quarter, within 

thirty (34) days after the close ofthe quaiter, which meets the applicable TSS 

C EM Requirements and is in a format acceptable ;3o the TSS. The report shall 

include at a minimum all opacity, nitrogen oxides, and carbon monoxide 

emissions in excess of the emissions standards specified in Conditions 

(8),(10),(15);~(16) and (24) of this ,Permit, a frequency distribution that 

summarizes all the data collected, a suim~mary of valid data capture and periods 

of CEMS downtime and invalid data and calibration and audit results . 

(f) CEMS data for nitrogen oxides and carbon monoxide shall be reported in units of 

Ibs/MMBTU aiid Ibs/hour both in terms of 24-hour rolling averages, calculated on 

an hourly basis. Reported, valid 24-hour rolling averages must contain valid 

CEMS data representing at least eighteen (18) hours out of the preceding 24-

hour period . In addition, the Permittee shall report the quarterly maximum and 

average 1 - hour and 24 - hour average emissions of NOX and CO in units of 

Ibs/MMBtu and Ibs/hr. 

(g) The Permittee shall maintain a file of all information reported in the quarterly 

summaries and all other data, collected by the monitoring systems for at least five 

(5) years from the date of collection of such data or submission of such 

summaries. All data records for the monitoring systems shall be marked to show 

the times of both start-up and shutdown of the 2urn wood-fired boiler . 

(h) If, on the basis of the continuous emission monitoring required by this condition, 

it is determined that the visible, nitrogen oxides or carbon monoxide, emissions 

exceed the standards specified in this Permit, the Permittee shall, through the 

application of good engineering practices, immediately review the major 

operating systems in the Facility in an effort to determine whether any such 

system has malfunctioned and will undertake its, best efforts to rectify the 

malfunctions, if any. 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

[10 V.S .A . §556e(d), and Administrative Order, January 9, 1996] 

Start-Up and Shutdown - Zurn, W60d-Fired Boiler 

(23) For the purposes of this Permit, the following definitions shall apply: 

(a) "start-up" periods are those periods of time from~the initiation of wood firing in the 

Zurn~ boiler until the unit ~ reaches -steady-state operations (85-100% load 

conditions). This period shall not -exceed eight (8) hours for a cold start-up, nor 

four (4) hours for a hot start=up. A cold `start-up shall be defined as a start-up 

when the boiler has been down for more than 24 - hours. 

(b) "shutdown" period shall not exceed four (4) hours from the moment the wood 

supply to the Zurribdiler is eliminated, ~~[Administrative order, January 9, 199s] 

(24) The Permittee shall operate the vi+ood-fired, boiler ~~d associat~d combustion air control 

system in a r'r'tianner, consistent' with best practicable air pollution control practices to 

minimize emissions during start-up and shutdown below the limits summarized below in 

Table 5, Start-Up and Shutdown Limits : 

Table , b: btart-u an af~bnutaown LIMITS 

Parameter Limit 

NpX 

1 54 Ibslhr (1- hour average) 

Co 110g lbs/hr (1 -hour average) 

Emissions in excess of the limits identified in Table 5 during start-up or shutdown shall 

be considered a violation of this Permit . The nurt~iber of hours that the boiler operates in 

a start-up ,of shutdown mode shall not exceed fifteen (15) percent of the total annual 

operating~tiours, of the Zurn wood-fired boiler . [Administrative Order, January 9, 1996] 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Malfuunctian Procedures 

(25) The Permittee shall :implement and maintain they malfunction abatement plan submitted 

to the Agency on May 16, 1995, for those systems/operations that affect regulated 

emissions from the Zurn wood-fired boiler . The plan shall be implemented whenever the 

Zurn wood-fired boiler suffers a malfunction or other breakdown occurs . 

The malfunction abatement plan shall contain at a minimum the following : 

(a) a complete preventive maintenance program including: 

(i) the identifiqation'of Individuals' or positions resporasible foe inspecting, 

maintaining, and repairing the wood: #ired , boiler system and a anciilary 

equipment; 

(ii) a description of the components that will be insp ted and maintained ; 

(iii) the frequency of inspection, maintenance services and repairs; and 

(iv) an identification and quantities of replacement parts for the wood-fired 

boiler that shall be maintained in inventory at the Facility for quick 

replacement; 

(b) an identification of the operating variables ° that may be monitored in order to 

detect a malfunction or faiiure; the no 

1

, operatiryg range of these variables; a 

descriptionof the method of monitortng ~;ar surveillance procedures; and a 

description of the methods or prc~cedures fhait will be used to inform operating 

personnel of any malfunctions, including alarm systems, lights or other indicators ; 

and 

(c) a description of the corrective procedures that will ,be taken in the event of a 

malfunction or failure an order to achieve compliance with the applicable limits as 

expeditiously as practicable but no longer th'an ;the next boiler or process outage 

that would provide for an orderly repair or correction of,~the malfunction ©i" fifteen 

(15) days, whichever is the shorter time interval.; . . If it is anticipated that the 

malfunction, would continue for more than°fifteen ,(15) days, a case by case repair 

schedule will be established by .the .Secretary in conjunction with the Permittee. 

[Administrative Order, January 9, 1996] 

(26) Any amendments to the malfunction abatement plan'shall be reviewed and approved by 

the Secretary prior to its use. If the amendments do not adequately carry out the 

objectives of Condition (25) above, the. Secretary shall disapprove the amendments, and 

shall state his/her ~feasons for this disapproval. Jhe Permittee shall submit to the 

Secretary for his/her approval amendments reflecting changes in any element of the 

plan required by Condition (25) of this pern-mit or amendments when requested by the 

Secretary. The malfunction abatement plan amendments 'shall be implemented within 

sixty (60) days of receipt of written notice of approval by the Secretary. [Administrative 

Order, January 9, 1996 

(27) If, for a period of four (4) hours or more, the wood-fired boiler discharges excess 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

emissions that are caused by a ; malfunction .or breakdown of the wood-fired boiler 

system or, its anciliai~equiprrtent ; or other abnormal 'conditions, the Permittee shall: 

(a) °vdrbaily;:notify the Agency of any such occurrence within 72 hours of becoming 

awai`eo"f the occurrence as described below: 

(i) name and location of the facility, 

(ii) ~ the nature and cause of the excess emissions, 

(iii) the time when the excess emissions were first observed, 

(iv) the expected duration, and 

(v) an estimated rate of emissions ; 

(b) notify, the Secretary immediately when the corrective measures have been 

accomplished; 

(c) submit to the Secretary within 15 days after the notification required in Condition 

(27)(a) above a written report which includes : 

([) riarnearid location ofthe facility, 

(ii) identification oi- description of the components, processes and control 

devices involved in the excess emissions, 

(iii)' the cause and nature of the event, 

(iv) ' date,' time and duration of the violation or the expected duration of the 

excess emission if the cause of the excess emissions has not been fixed, 

(v) , estimated quantity of pollutant emitted; 

(vi) steps taken to control the excess emissions and to prevent reoccurrences 

and, if the cause of the excess emission has not been fixed, steps 

planned to be taken, and 

(vii) any other pertinent information requested by the Secretary. 

[Administrative Order, January 9, 1996] 

Recordkeeping and Reporting 

(29) The Permittee shall, maintain records of all fuel oil consumed in the four, (4) Babcock and 

Wilcox boilers, irt or'cler to ;demonstrate , compliance with Conditiort° (3) of this Permit . 

[Adrrtiinistrative'dtder, January 9, 1996]. 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

(34) The Permittee. shall submit to the Agency every six months from the date of issuance of 

this Permit a report containing the following information; [§5-405(l) of the Regulations] 

(a) a summary of the gallons of gasoline delivered to the facility required to be 

recorded by Condition (31) of this Permit; 

(b) a summary of the gallons of fuel, oil, consumed by the Babcock and Wilcox boilers 

required to be recorded by Condition (29) of this Permit ; and 

(c) VOC emission records required to be maintained by Condition (33) of this Permit; 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

Boston, MA 02203 

D° 

(40) Ail records of monitoring data,and support anformation'skiall be retained for a minimum of 

five (5) years from the date of sampling, measurement, or report. All data records for the 

monitoririg sysfems; shall be marked to show the times of both start=up and shutdown of 

the,, Zurn wood-fired boiler [§s-ao~(l), §5-1o15(a)(5) ; and §5,-1015(b) of the Regulations and Administrative 

Order, January 9, 1996j] 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

R9gulat19MnS], 

Standard Condotoons 

j§5 1015(a )( 11) of the 

arrm °

crtaca-po --V.S .A,"§r-JrJ- 6'7 

boYtdttton ; 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

V-.S.,4 . §556afc4l 

the Oen.d~Ffnnol n'~~-c°9°~°~°r~°I 

V.S.A-.-§Jd6a(o 

R°9°'vc'°rTVI 
Dalton Hydro, LLC/Dirigo Paper Company - Gilman Paper Mill #OP-04-020 

9 9 er--cae--rseea~ar~e 

and -F2gulat16RS-