1

 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

SECTOR POLICIES AND PROGRAMS DIVISION

OFFICE OF AIR QUALITY PLANNING AND STANDARDS

OFFICE OF AIR AND RADIATION

DATE: April 26, 2013

SUBJECT: Review of the Air Permits for Kraft Pulp Mills 

FROM: John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)

Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

TO: EPA-HQ-OAR-2012-0640

I. Introduction 

Section 111(b)(1)(B) of the Clean Air Act (CAA) mandates that the EPA review and, if 

appropriate, revise the existing new source performance standards (NSPS) at least every 8 years. 

The kraft pulp mills NSPS (40 CFR part 60, subpart BB) were promulgated in 1978 and 

reviewed in 1986. The NSPS regulate emissions of particulate matter (PM) from new, modified, 

and reconstructed recovery furnaces, smelt dissolving tanks (SDTs), and lime kilns at kraft pulp 

mills. The NSPS also regulate emissions of total reduce sulfur (TRS) compounds from new, 

modified, and reconstructed digesters, brown stock washers, multiple-effect evaporators, 

condensate strippers, recovery furnaces, SDTs, and lime kilns at kraft pulp mills. On December 

6, 2011, the Center for Biological Diversity, Greenpeace, and the Port Townsend Airwatchers 

filed a complaint (Clean Air Act citizen suit) against the EPA to review the NSPS for kraft pulp 

mills. The EPA has entered into a consent decree with the petitioners, specifying proposal of the 

NSPS review by May 15, 2013 and promulgation by March 14, 2014. See docket number EPAHQ-OGC-2012-0730 for a copy of this consent decree.

The purpose of this memorandum is to present the results of a review of the air permits for 

existing kraft pulp mills. These permits were obtained through state regulatory agencies as well 

as provided by the pulp and paper industry in response to a 2011 Information Collection Request 

(ICR) survey. This analysis is part of the EPA’s effort to review the NSPS for kraft pulp mills in 

accordance with section 111(b)(1)(B) of the CAA. 

II. General Approach to Tabulating and Reviewing Air Permits

Permits and permit limits were collected from the pulp and paper industry in 2011 in response 

to a CAA section114 ICR. The three-part survey was distributed by the EPA in February 2011 

and requested 2009 base year information needed to perform various regulatory reviews, 

including the review of the subpart BB NSPS. The ICR requested that permit limits for each 

emission unit be provided by populating the survey spreadsheet, or by providing a copy of the air 

operating permit. Permits that were not provided in response to the ICR were collected via state 

contacts and state websites. A list of state websites is provided in Table A-1 of Appendix A.
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The general approach for processing the permit data was to extract the data from the ICR 

responses and the permits into “tabulation spreadsheets.” Separate tabulation spreadsheets were 

developed for each source (recovery furnace, SDT, and lime kiln) to include emission limits for 

each pollutant (opacity, PM, and TRS). Emission limits for TRS were also extracted for noncondensable gas (NCG) sources (digesters, evaporators, and brown stock washers), as well as for 

condensate stripper systems. Facilities were identified by RTI facility code and emission units 

were identified by emission unit ID. A combined facility and emission unit ID was assigned to 

each permit limit, with the format of RTI facility code followed by emission unit ID with a 

period as a separator for the two values (e.g., 100.037A). After tabulation, a representative 

emission limit was determined for each pollutant and each emission unit. Incinerator operating 

and monitoring parameters were also collected from permits, as appropriate.

Permit limits extracted from the survey spreadsheets and the state permitting websites were 

converted to consistent units for comparison to the current NSPS emission limits. State-based 

mass limits were not requested to be reported in the spreadsheets and were not extracted from the 

permits unless the mass-based limit was the only limit reported for a pollutant. If a facility 

provided responses to the permit spreadsheet tab in the ICR, and the limit in the permit was 

higher than that specified in the ICR by the facility, the ICR limit was used as the representative 

limit, not what was written in the permit provided. In some cases, facilities identified that a limit 

was equivalent to a standard, but provided limits that were not equivalent. The representative 

limit for these units was assumed to be the limit in the standard that the facility identified as 

equivalent. A few facilities provided new limits in their ICR responses that were pending permit 

approval and were lower than the limits in the permit provided. The pending limits were used as 

the representative limit.

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for pulp and paper 

combustion sources (40 CFR part 63, subpart MM) establishes PM limits (as a surrogate for 

metal HAPs) for each affected source or emission unit (i.e., recovery furnaces, SDTs, and lime 

kilns). The NESHAP also provides an alternative approach for compliance, referred to as the PM 

bubble compliance alternative (§63.862(a)(ii)), which allows facilities to establish limits for the 

individual process units (recovery furnaces, SDTs, and lime kilns), as long as the combined limit 

for these units is no higher than the sum of the promulgated limits for the units. Information 

regarding the participation of facilities in the PM bubble compliance alternative was also 

collected, as participating units may have permitted limits lower than the standard if emissions 

were used as a credit, or higher than the standard if emissions were used as a debit. 

The NESHAP for pulping and papermaking (40 CFR part 63, subpart S) establishes a HAP 

reduction limit for digesters, evaporators, brown stock washers, and condensate strippers. If the 

permits did not reference the NSPS TRS requirements for these sources, but did reference 

incineration requirements from subpart S, incineration was noted in the tabulation spreadsheets 

as the method used to treat TRS. The NESHAP also provides an alternative approach for 

compliance, referred to as the clean condensate alternative (CCA). The CCA allows mills to 

meet the HVLC emission requirements by reducing the HAP emissions elsewhere, usually 

process water. This approach allows mills to control HAP emissions by reducing the amount of 

HAPs that are volatilized from selected process equipment instead of using combustion devices 
3

to control HVLC system vent streams. In a classic example, HAP condensates in paper machine 

process water are removed. By reducing the HAP concentration in process water, the amounts of 

volatilized HAPs are also reduced. For more information on CCA, see the memo titled Summary 

of Clean Condensate Alternative Technology Review in docket number EPA-HQ-OAR-2007-

0544.

The following sections discuss specific steps used to analyze the permit data for the separate 

standards. 

A. Permit Review: Opacity

Opacity limits were tabulated from the ICR responses and the state permitting websites and 

were analyzed. In many cases, multiple opacity limits were listed for a source. These limits were 

combined in the tabulation spreadsheet as the representative limit for the unit. For example, a 

recovery furnace with two separate opacity limits (in two separate columns of the spreadsheet) 

such as the following: permit limit 1) 25 percent (1-hour average), and permit limit 2) 35 percent

(6-min average), were combined into one column as the representative limit 25 percent (1-hour 

average) and 35 percent (6-min average). When multiple limits with the same averaging time 

were listed for an emission unit, the representative limit was assumed to be the most stringent of 

the limits. For example, if a recovery furnace had two separate opacity limits (in two separate 

columns of the spreadsheet) listed as 40 percent (6-min average) and 35 percent (6-min average), 

it was assumed that the limit that the unit must meet at all times is 35 percent (6-min average). 

Representative limits were assigned to all units for comparison purposes. 

Averaging times for the opacity limits were not always specified in the permit or in the ICR 

responses. For units where opacity limits were expected (e.g., a recovery furnace with an 

electrostatic precipitator [ESP]), the averaging time for the representative limit was assumed to 

be the same as the averaging time specified in the NSPS (6-min averages). For units where 

opacity limits were not expected (e.g., a smelt dissolving tank with a scrubber), the averaging 

time was not assumed, and the representative limit did not indicate an averaging period. 

B. Permit Review: Particulate Matter

Particulate matter limits were tabulated from the ICR responses and the state permitting 

websites and were analyzed. These limits were specified as PM, PM-filterable, total PM, and 

PM/PM10. Limits for PM and PM-filterable were considered to be the same, as PM-filterable is 

generally referred to as PM (both represent particles that are emitted directly by a source as a 

solid or liquid at stack conditions and can be captured on the filter of a stack test train), and these 

emissions are determined using EPA Method 5. Total PM is determined using a combination of 

Method 5 and Method 202, and represents both filterable PM and condensable PM emissions. 

Condensable PM is material that is in vapor phase at stack conditions, but condenses and/or 

reacts upon cooling and dilution in the ambient air to form solid or liquid PM immediately after 

discharge. The final category, PM/PM10, is measured using EPA Method 201 or 201A, and 

determines the PM emissions that have an aerodynamic diameter of equal to or less than 10 

micrometers. This test method cannot be performed on wet stacks such as wet scrubber stacks;

therefore, PM/PM10 limits were only expected for units that use ESPs as their air pollution 
4

control device (APCD). Because the pulp and paper standards specify filterable PM limits, it is 

believed that PM/PM10 limits are permit annotations based on state implementation plans for the 

PM10 National Ambient Air Quality Standards (NAAQS). The PM/PM10 limits are interpreted 

as filterable PM limits for comparison to the standard, but are indicated separately in the analyses 

in this memo. Representative limits were determined for the emission units in this source 

category and were categorized as “PM”, “total PM”, and “PM/PM10” in the tabulation 

spreadsheet. 

Averaging times for the PM limits were not always specified in the permit or in the ICR 

responses. It was assumed that the averaging time was 3-hours (the length of three runs in a 

single stack test used for compliance), unless otherwise specified. Based on the ICR responses, 

no pulp and paper recovery furnaces, SDTs, or lime kilns operate PM continuous emission 

monitoring systems (CEMS). 

C. Permit Review: Total Reduced Sulfur

Total reduced sulfur limits were tabulated from the ICR responses and the state permitting 

websites and were analyzed. Total reduced sulfur represents four compounds--hydrogen sulfide

(H2S), methyl mercaptan, dimethyl sulfide, and dimethyl disulfide--and is measured and 

monitored using EPA Method 16 (or alternatively, 16A, 16B, or 16C) and TRS CEMS, 

respectively. Method 16 specifies that TRS concentration should be calculated based on H2S; 

therefore, we assumed that all permit limits are “as H2S” unless otherwise specified. 

Representative limits were determined for the emission units in this source category, and were 

added to the tabulation spreadsheet.

III. Summary of Permit Findings

A. Recovery Furnace Permits

Permits for all 151 of the recovery furnaces in the U.S. were compiled from the ICR responses 

and the permits from the state websites. Units and corresponding emission limits can be found in 

Table B-1 in Appendix B. 

1. Recovery Furnace Opacity

The NSPS currently requires recovery furnaces that were constructed, reconstructed, or 

modified after 1976 to meet a 35 percent opacity limit with a 6 percent monitoring allowance

that allows the unit to exceed the standard for 6 percent of the 6-minute averages in a quarter, 

without constituting a violation. This standard was based on the use of an ESP with a continuous 

opacity monitoring system (COMS). Currently, four recovery furnaces were permitted to use a 

combination of an ESP and a scrubber to control air emissions, and are thought to have a COMS 

between the ESP and the scrubber. Two additional furnaces were only permitted to have a 

scrubber, and are thought to meet the NESHAP limit based on parametric monitoring or a 

Method 9 stack test. Permits for many furnaces (59) specified an opacity limit of 35 percent, but 

were silent on the monitoring allowance (e.g., referred to the federal rule for details), and permits 

for 8 units specified the 35 percent opacity limit with the 6 percent monitoring allowance.
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Permits for seven additional units specified a 35 percent opacity limit with several variations of 

the monitoring allowance. Overall, it appears that permitted limits for 74 recovery furnaces 

match the 35 percent opacity limit in the NSPS.

The subpart MM NESHAP requires that new sources meet a 20 percent opacity limit. Similar 

to the NSPS, the NESHAP for new sources has a 6 percent monitoring allowance that allows the 

recovery furnace to exceed the standard for 6 percent of the 6-minute averages in a quarter.

Permits for many units (37) specified an opacity limit of 20 percent, but were silent on the 

monitoring allowance. Permits for three units specified a 20 percent opacity limit with varying 

monitoring allowances. One permit specified that the recovery furnace could exceed 20 percent 

for one 6-minute average per hour, and another permit specified the same, with the additional 

restraint that the furnace could not exceed 30 percent opacity during that period. One furnace had 

a more stringent monitoring allowance of 2 percent per quarter and 1 percent per year. Overall, it 

appears that permitted limits for 40 recovery furnaces match the 20 percent opacity limit of the 

new source NESHAP. 

Additionally, the subpart MM NESHAP requires that existing sources meet a 35 percent 

opacity limit based on 6-minute averages (violation level) and a 20 percent opacity limit based 

on 10 consecutive 6-minute averages (corrective action level). Similar to the NSPS and the new 

source NESHAP, the NESHAP for existing sources has a 6 percent monitoring allowance that 

allows the unit to exceed the standard for 6 percent of the 6-minute averages in a quarter. Permits 

for eight units specified an opacity limit of 20 percent for 10 consecutive 6-minute averages and 

a 35 percent 6-minute average, with no monitoring allowance specified. Permits for six units 

specified an opacity limit with the monitoring allowance, not to exceed 40 percent. One 

additional permit specified the same limit with the monitoring allowance. Similarly, permits for 

three units specified a 20 percent opacity limit based on a 1-hour average and a 35 percent 

opacity limit based on 6-minute averages. Overall, it appears that permitted limits for 18

recovery furnaces match the 35 percent (with 20 percent corrective action) opacity limit of the 

existing source NESHAP. 

The NESHAP for industrial, commercial, and institutional major source boilers (also known 

as boiler MACT) requires that boilers meet a 20 percent opacity limit based on 6-minute 

averages, and units are allowed to exceed the 20 percent opacity limit for one 6-minute average 

per hour, not to exceed 27 percent. Permits for eight recovery furnaces specified a separate limit 

for periods when the furnace is burning fuel oil, most similar to the boiler MACT. Permits for 

two units specified the subpart MM NESHAP existing source limit for periods when black liquor 

is burned and the boiler MACT limit for when fuel oil is burned. Permits for two units specified 

a 35 percent opacity limit for periods of burning black liquor and the boiler MACT limit for 

periods of burning fuel oil, and permits for three additional units specified a 35 percent opacity 

limit for periods of burning black liquor and a 20 percent opacity limit for periods of burning 

fuel oil, without the allowance to exceed up to 27 percent. One permit specified a 35 percent 

opacity limit for burning black liquor, with the ability to exceed up to 40 percent for periods of 

startup and shutdown for up to 15 minutes (not to exceed two startup and shutdown events in a 

24-hour period) and a 20 percent opacity limit for periods of burning fuel oil. Overall, eight

recovery furnaces had separate permitted limits for burning black liquor and burning fuel oil.
6

Nine recovery furnaces had permitted opacity limits that were different from, but no less 

stringent than, the federal regulations. One unit was permitted to meet a 30 percent opacity limit 

based on 6-minute averages. One unit was permitted to meet a 60 percent 1-minute average, a 35 

percent 6-minute average, and a 20 percent average based on 10 consecutive 6-minute averages,

with the ability to exceed 20 percent for no more than 3 minutes per hour. One unit had a 20 

percent opacity limit based on 3-minute averages, not to exceed 35 percent. Two units had a 

separate opacity limit for periods of startup and cleaning. These units had a 20 percent opacity 

limit based on 6-minute averages for periods of normal operation and an 80 percent (6-minute) 

limit for startup and cleaning periods, not to exceed more than 6 minutes in any hour. Two units 

were permitted to meet 20 percent opacity (6-minute average) and up to 35 percent during 

startup and shutdown, not to exceed 4 hours per event. One unit had a 25 percent hourly opacity 

limit and a 35 percent 6-minute average, and one unit had a 30 percent 6-minute average not to 

exceed for more than one 6-minute average in a 3-hour period. 

Interestingly, two units had opacity limits that were less stringent than all of the federal 

regulations (i.e., subpart MM NESHAP, NSPS, and boiler MACT). One of these units had an 

opacity limit of 40 percent based on 6-minute averages without a monitoring allowance 

specified. This is the Louisiana state limit, and this unit complies with subpart MM through a 

monitoring alternative (§60.84(e)(13)) by measuring ESP total power every 15 minutes and 

meeting the minimum requirements on an hourly basis. One unit had a permitted opacity limit of 

40 percent with a monitoring allowance. This unit was allowed to exceed the 40 percent for one 

6-minute period per hour, not to exceed 4 per 24-hour period, up to 90 percent opacity. This is 

the North Carolina opacity limit. Subpart MM was applicable to this unit and mentioned in the 

permit, but opacity values were not explicitly stated.

Table 1 below summarizes the representative opacity limits for recovery furnaces and the 

number of units subject to each limit, as discussed above.
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Table 1: Representative Opacity Limits for 151 Recovery Furnaces 

Group Representative Limit No. of 

Furnaces

35 

percent

35% (6-min avg) 59

35% (6-min avg) not to exceed more than 6% of operating time 8

35% (6-min avg) - not to exceed 87% for more than 1 6-min avg/hr and 4 in 24 

hr 1

35% (6-min avg) can exceed 1 6-min average in 60 min period 1

35% (6-min avg) can exceed for 1 6-min avg/hr and no more than 4/24 hr 3

35% (6-min avg) up to 40% for 3 min in any hour 1

35% (6-min avg), not to exceed more than 4 hours per SU/SD event 1

Total furnaces with 35 percent limit (NSPS limit)1 74

35 

percent 

with 20 

percent 

corrective 

action 

level

20% (10 consecutive 6-min avg) and 35% (6-min avg) 8

20% (10 consecutive 6-min avg) and 35% (6-min avg) not to exceed more than 

6% of operating time up to 40% 6

20% (10 consecutive 6-min avg) and 35% (6-min avg) not to exceed more than 

6% of operating time 1

20% (1-hour avg) and 35% (6-min avg) 3

Total furnaces with 35 percent limit and 20 percent action level (NESHAP 

limit for existing sources)

18

20 

percent

20% (6-min avg) 37

20% (6-min avg) can exceed for one 6-min avg per hour, up to 30% 1

20% (6-min avg) can exceed 2% of 6-min avg/quarter and 1% for 4 consecutive 

quarters 1

20% (6-min avg) can exceed one 6-min period per hour 1

Total furnaces with 20 percent (NESHAP limit for new sources) 40

Different 

limits for 

liquor 

and fuel 

oil

20% (10 consecutive 6-min avg) and 35% (6-min avg) not to exceed more than 

6% of operating time and 20% (6-min avg) allowed to exceed up to 27% for 1 6-

min avg/hour while firing fuel oil

2

35% (6-min avg) - 40% for startup for up to 15 minutes (not to exceed 3 SU/24 

hr) - 20% when burning fuel oil alone 1

35% (6-min avg) and 20% (6-min avg) - not to exceed 27% for more than one 6-

min avg/hr when burning fuel oil 2

35% (6-min avg) and 20% (6-min avg) when firing fuel oil 3

Total furnaces with different limits for liquor and fuel oil 8

Unique 

limits

20% (10 consecutive 6-min avg and can exceed for no more than 3 min/hour), 

35% (6-min avg), and 60% (1-min avg) 1

20% (3-min avg) not to exceed 35% 1

20% (6-min avg) and 80% (6-min avg) during startup or cleaning (not more than 

6 min in any hour) 2

20% (6-min avg), up to 35% during SU and SD, not to exceed 4 hours per 

SU/SD event 2

25% (1-hr avg) and 35% (6-min avg) 1

30% (6-min avg) 1

30% (6-min avg) not to exceed for more than one 6-min avg in 3 hour-period 1

40% (6-min avg) 1

40% (6-min avg) up to 90% for one 6-min avg/hr and no more than 4/24 hr 1

Total furnaces with unique limits 11

1. Existing recovery furnaces are also required to meet the NESHAP opacity 20 percent corrective action level. 
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2. Recovery Furnace Particulate Matter

The NSPS and the subpart MM NESHAP for existing sources require units to meet a filterable 

PM limit of 0.044 grains per dry standard cubic foot (gr/dscf). The PM bubble in the subpart 

MM NESHAP allows facilities to determine facility-specific PM emission limits for their 

existing recovery furnaces, SDTs, and lime kilns, the sum of which must be no higher than the 

combination of the promulgated PM limits for these emission units. The facility can trade 

emissions amongst these units to derive this sum. The NSPS does not have this provision;

therefore, units that are subject to the NSPS must meet the NSPS limits. All of the recovery 

furnaces, except for three, were permitted for the NSPS limit or lower; these three units were not 

subject to the NSPS and were located at facilities that participate in the PM bubble compliance 

alternative.

The subpart MM NESHAP also requires that new and reconstructed units meet a filterable 

PM limit of 0.015 gr/dscf. Three furnaces were permitted to meet the new source limit, one as a 

filterable PM limit and two as a PM10 limit. One of these furnaces was not a new unit (modified 

in 2005), but had a more stringent limit because it was a credit source for the facility’s PM 

bubble compliance alternative.

Forty-one units were permitted to meet PM limits between 0.02 gr/dscf and 0.03 gr/dscf, and 

12 of these units are located at facilities that utilize the PM bubble compliance alternative. Two 

units were permitted for an annual average of 0.02 gr/dscf, but were required to meet a 3-hour 

average of 0.044 gr/dscf for stack tests. It is thought that compliance with the annual average is 

based on parametric monitoring. Two units had filterable PM limits of 0.021 gr/dscf, but were 

also required to meet separate total PM limits (0.0238 and 0.0298 gr/dscf). Two units were

permitted for 0.027 gr/dscf on an hourly basis and both have an additional annual PM limit (0.02 

gr/dscf and 0.021 gr/dscf). One unit had a filterable PM limit of 0.027 gr/dscf and an additional 

total PM limit of 0.034 gr/dscf. One unit was also permitted for 0.029 gr/dscf on an annual basis.

Thirty units were permitted to meet PM limits between 0.03 gr/dscf and 0.043 gr/dscf, and 18 of 

these units are located at facilities that utilize the PM bubble compliance alternative. Two units 

had separate PM and PM10 limits, and two units had limits specified based on a 1-hour average. 

The remaining 74 units were permitted to meet the NSPS and existing source NESHAP limit 

of 0.044 gr/dscf. The permit for one unit specified a limit based on a 1-hour average. One permit 

specified a daily average as determined by an opacity correlation. One permit specified a 3-hour 

average and had an additional 1-hour average requirement of 0.05 gr/dscf. Finally, one unit was 

permitted to meet 0.044 gr/dscf based on a daily average and also had a separate 3-hour average 

limit of 0.033 gr/dscf. For this unit, it is believed that compliance with the daily average is based 

on parametric monitoring and compliance with the 3-hour average is based on a stack test. 

Table 2 below summarizes the representative PM limits for recovery furnaces and the number 

of units subject to each limit, as described above. Total PM and PM/PM10 limits are 

distinguished with asterisks (** and *, respectively) in this table and in Table B-1 in the 

appendix. Filterable PM limits do not include an asterisk.
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Table 2: Representative PM Limits for 151 Recovery Furnaces

Group Representative Limit No. of 

Furnaces

PM 

Bubble 

Furnaces

0.015 

gr/dscf 

0.015 gr/dscf or 0.015 gr/dscf* 3 1

Total furnaces at 0.015 gr/dscf (NESHAP new source limit) 3 1

Between 

0.015 and 

0.044 

gr/dscf

0.02 gr/dscf (annual) and 0.044 gr/dscf (3-hour) 2 0

0.02 gr/dscf* 2 1

0.021 gr/dscf and 0.0238 gr/dscf** 1 1

0.021 gr/dscf and 0.0298 gr/dscf** 1 0

0.021 gr/dscf or 0.021 gr/dscf* 8 2

0.023 gr/dscf or 0.023 gr/dscf* 2 1

0.024 gr/dscf 4 3

0.025 gr/dscf or 0.025 gr/dscf* 6 1

0.027 gr/dscf or 0.027 gr/dscf* 8 2

0.027 gr/dscf (1-hour)* and 0.02 gr/dscf (annually)* 1 0

0.027 gr/dscf (1-hour)* and 0.021 gr/dscf (rolling annual)* 1 0

0.027 gr/dscf and 0.034 gr/dscf** 1 0

0.028 gr/dscf or 0.028 gr/dscf* 2 1

0.029 gr/dscf (annual)* 1 1

0.0294 gr/dscf* 1 0

0.03 gr/dscf or 0.03 gr/dscf* 9 5

0.0303 gr/dscf 1 1

0.032 gr/dscf 2 2

0.033 gr/dscf (1-hour) 1 0

0.033 gr/dscf and 0.0257 gr/dscf* 1 1

0.033 gr/dscf* 1 1

0.035 gr/dscf* 3 3

0.036 gr/dscf 3 3

0.038 gr/dscf 1 1

0.039 gr/dscf and 0.0287 gr/dscf* 1 1

0.04 gr/dscf 1 0

0.04 gr/dscf (1-hour)* 1 0

0.041 gr/dscf 1 1

0.042 gr/dscf 2 0

0.043 gr/dscf 2 1

Total furnaces between 0.015 gr/dscf and 0.044 gr/dscf 71 33

0.044 

gr/dscf

0.044 gr/dscf or 0.044 gr/dscf* 69 17***

0.044 gr/dscf (1-hour)* 1 0

0.044 gr/dscf (3-hour) and 0.05 gr/dscf (1-hour) 1 0

0.044 gr/dscf (daily as determined by opacity correlation)* 1 0

0.044 gr/dscf (daily)* and 0.033 gr/dscf (3-hour)* 2 2***

Total furnaces at 0.044 gr/dscf (NESHAP existing source and 

NSPS limit) 74 19

Above 

0.044 

gr/dscf

0.051 gr/dscf 1 1

0.055 gr/dscf 1 1

0.057 gr/dscf 1 1

Total furnaces above 0.044 gr/dscf 3 3

*PM/PM10 limit and **total PM limit

***These units are located at facilities that participate in the PM bubble. They are not likely to be credited or debited 

sources because they are permitted for the NESHAP limit; however, further review of the PM bubble compliance 

calculations would be required to confirm this assumption.
10

3. Recovery Furnace Total Reduced Sulfur

The NSPS require that DCE and NDCE recovery furnaces constructed, reconstructed, or 

modified after 1976 limit their TRS emissions to 5 parts per million (ppm). The regulation 

requires continuous TRS monitoring with a 12-hour averaging period for reporting, and also 

contains a 1 percent monitoring allowance that allows 1 percent of the 12-hour averages in a 

quarter to exceed the 5 ppm limit. The monitoring allowance was not included in the 

representative limit unless it varied from the current allowance of 1 percent. The TRS emission 

guideline limits of 20 ppm for DCE furnaces and 5 ppm for NDCE furnaces have generally been 

adopted for recovery furnaces that have not triggered NSPS to date. Of the 151 recovery 

furnaces, 101 were permitted to meet a limit similar to the NSPS, and 93 of these units were

permitted exactly as the NSPS reads (5 ppm based on 12-hour average).

Four units (all NDCEs) were permitted for a TRS value more stringent than the current NSPS. 

Two of these units had a TRS limit of 3 ppm; one unit was based on a 3-hour average, and one 

unit was based on a 12-hour average. Two units had a TRS limit of 4 ppm; the TRS limit for one 

unit was based on a 12-hour average, and the TRS limit for the other unit was based on a 24-hour 

average and was not allowed to exceed 8 ppm for more than 60 minutes per day. Two units were 

permitted at 5 ppm based on 12-hour averages and had additional requirements. One of these

units had a 4.3 ppm limit based on a 24-hour average, but was also required to meet the NSPS 

limit of 5 ppm based on 12-hour averages, as well as a 10 ppm 2-hour average limit. The other 

unit was permitted to meet the 5 ppm 12-hour average, but also had a separate 4 ppm H2S limit.

Three units showed compliance with 5 ppm using a 1-hour average, and three units showed 

compliance with the limit using a 24-hour average. 

There were 38 units permitted for TRS limits between (and including) 10 ppm and 20 ppm. 

One unit was permitted to meet a 10 ppm TRS limit and a 4 ppm H2S limit. This unit was an 

NDCE not subject to the NSPS. Four DCEs not subject to the NSPS were permitted to meet 10 

ppm based on a 24-hour average. One NDCE not subject to the NSPS was permitted to meet a 15 

ppm limit based on a 12-hour average, and another unit was permitted to meet 15 ppm based on 

a 24-hour average. One DCE not subject to the NSPS was permitted to meet a 15 ppm limit 

based on a 24-hour average with no more than 60 1-minute spikes above 40 ppm in a 24-hour 

period. Seven units (four NDCE and three DCE) were permitted to meet a 17.5 ppm limit based 

on 12-hour averages, and one of these units (a DCE subject to the NSPS) had a yearly TRS limit 

of 11.5 ppm. One additional DCE was required to meet a 17.5 ppm limit, but based on a 24-hour 

average. Seventeen units (including five NDCEs) were required to meet a 20 ppm TRS limit 

based on a 12-hour average. Three of these units had additional requirements including a 4.5 

ppm limit based on a 12-month rolling average for one unit and a 50 ppm 1-hour limit for two 

units. Five units (including one NDCE) were required to meet a 20 ppm limit based on a 24-hour 

averaging period. 

Two units were required to meet a 35 ppm limit based on a 12-hour average, and five units 

(including one NDCE) were required to meet a 40 ppm limit based on a 12-hour average. One

unit was required to meet a 100 ppm limit based on a 12-hour average. These eight limits are 

based on state codes from Mississippi and Arkansas. Table 3 below summarizes the 

representative TRS limits for recovery furnaces and the number of units subject to each limit.
11

Table 3: Representative TRS Limits for Recovery Furnaces

Group Representative Limit No. of 

DCEs

No. of 

NDCEs

Below 5 

ppm

3 ppm (3-hour) 0 1

3 ppm (12-hour) 0 1

4 ppm (12-hour) 0 1

4 ppm (24-hour), cannot exceed 8 ppm for more than 60 min/day 0 1

Total furnaces below 5 ppm 0 4

5 ppm

4.3 ppm (24-hour) / 10 ppm (2-hour) / 5 ppm (12-hour) 0 1

5 ppm (12-hour) / 4 ppm H2S 0 1

5 ppm (1-hour) 0 3

5 ppm (12-hour) 8 85

5 ppm (24-hour) 1 2

Total furnaces at 5 ppm (NSPS limit) 9 92

Between 5 

ppm and 20 

ppm

10 ppm (12-hour) / 4 ppm H2S 0 1

10 ppm (24-hour) 4 0

15 ppm (12-hour) 0 1

15 ppm (24-hour) 0 1

15 ppm (24-hour) and no more than 60 1-min spikes above 40 

ppm in 24 hr 1 0

17.5 ppm (12-hour) 2 4

17.5 ppm (12-hour) / 11.5 ppm (yearly) 1 0

17.5 ppm (24-hour) 1 0

Total furnaces between 5 and 20 ppm 9 7

20 ppm

20 ppm (12-hour) 10 4

20 ppm (12-hour) / 4.5 ppm (12 month rolling) 0 1

20 ppm (12-hour) / 50 ppm (1-hour) 2 0

20 ppm (24-hour) 4 1

Total furnaces at 20 ppm (DCE emission guideline limit) 16 6

Above

20 ppm

35 ppm (12-hour) 2 0

40 ppm (12-hour) 4 1

100 ppm (12-hour) 1 0

Total furnaces above 20 ppm or with other limits 7 1

B. Smelt Dissolving Tank Permits 

Permits for a total of 160 of 164 SDTs in the U.S. were compiled from the ICR responses and 

the permits from the state websites. Units and corresponding emission limits can be found in 

Table C-1 in Appendix C. 

1. SDT Opacity

Because SDTs use wet scrubbers to remove PM, continuous opacity monitoring is not 

appropriate due to moisture in the stack gas which interferes with opacity readings. Neither the 

NSPS nor the subpart MM NESHAP require opacity monitoring for SDTs; however, 99 units 

had opacity limits in their permits. The opacity limits found in the permits ranged from 5 percent 

to 40 percent and had various monitoring frequencies. It is thought that these requirements are 
12

overarching state-specific requirements broadly applicable to various industrial sources and are 

likely met using parametric monitoring or EPA Method 9 opacity testing. No opacity limits were 

required for 60 SDTs, consistent with the NSPS and subpart MM NESHAP.

The majority of the SDTs with an opacity limit had a numerical limit of 20 percent (73 out of 

99 units). Of these units, 24 were required to meet a 20 percent opacity based on a 6-minute 

average. Twelve additional units had a monitoring allowance specified, with some containing an 

upper opacity limit resulting in a violation if exceeded. The permit of one unit specified a 

measurement once per shift, and one unit specified an opacity test (assumed to be Method 9). 

Thirty additional units did not specify the frequency of the monitoring and only had a numerical 

limit of 20 percent.

Of the remaining 26 units, 2 units had an opacity limit lower than 20 percent. These two units 

had a limit based on 6-minute averages, with numerical values of 5 percent and 10 percent. Two 

units specified a 30 percent limit based on a 6-minute average, and five units specified a 35 

percent limit with no averaging time specified. Eighteen units had a numerical limit of 40 percent 

opacity. Table 4 below summarizes the representative opacity limits for SDTs and the number of 

units subject to each, as discussed above.

Table 4: Representative Opacity Limits for 160 SDTs

Representative Limit No. of 

SDTs

Below 20

percent

5% (6-min avg) 1

10% (6-min avg) 1

Total SDTs below 20 percent 2

20

percent

20% 30

20% (test) 1

20% (3 min in 60 min) 5

20% (6-min avg) 24

20% (6-min avg) up to 40% for one 6-min avg per hour 7

20% (6-min avg) up to 60% for one 6-min avg per hour 2

20% (6-min avg) except for one 6-min avg/hour and no more than 4/24 hours 1

20% (6-min avg) up to 87% for one 6-min avg per hour 1

20% (6-min avg) up to 87% for one 6-min avg /hr and no more than 4/24 hours 1

20% (once/shift) 1

Total SDTs at 20 percent 73

Above 20

percent

30% (6-min avg) 2

35% 5

40% 10

40% (6-min avg) 7

40% (6-min avg) except for one 6-min avg/hr and no more than 4/24 hours 1

Total SDTs above 20 percent 13

N/A

NA 1

NA/SCBR* 57

NA/INC_RF** 2

Total SDTs N/A 60

* SDT vented to wet scrubber

** SDT vented to recovery furnace
13

2. Smelt Dissolving Tank Particulate Matter

The NSPS currently requires SDTs that were constructed, reconstructed, or modified after 

1976 to meet a PM limit of 0.2 pound per ton of black liquor solids (lb/ton BLS). The subpart 

MM NESHAP requires existing SDTs to meet the same PM limit. Of the 160 units for which

permits were reviewed, 117 were permitted to meet 0.2 lb./ton BLS. The majority demonstrated 

compliance based on filterable PM (86 units), and several were indicated as PM10 (30). Since 

the PM10 method is not appropriate for wet stacks, it is believed that these limits are 

demonstrated using Method 5, and are labeled as PM10 due to state implementation plans for the 

NAAQS. One unit was permitted to meet a 0.2 lb/ton BLS 3-hour average and a 0.3 lb/ton BLS 

hourly average (e.g. each hourly test run). 

The PM bubble in the subpart MM NESHAP allows facilities to determine facility-specific 

PM emission limits for their existing recovery furnaces, SDTs, and lime kilns, the sum of which 

must be no higher than the combination of the promulgated PM limits for these emission units. 

The facility can trade emissions amongst these units to derive this sum. The NSPS does not have 

this provision, therefore, units that are subject to the NSPS must meet the NSPS limits. All of the 

SDTs for which permits were available except for 14 were permitted for the NSPS limit or 

lower; these units were not subject to the NSPS and were located at facilities that utilize the PM 

bubble compliance alternative.

The subpart MM NESHAP also requires that new and reconstructed SDTs associated with 

new and reconstructed recovery furnaces meet a filterable PM limit of 0.12 lb/ton BLS. A total 

of 19 units were permitted to meet this limit, 2 of which were units that were not characterized as 

new, and had lower limits because they were credits for the PM bubble compliance alternative at 

their facility. Three units were required to meet the limit based on a 1-hour average. Eight units 

were permitted to meet the limit based on filterable PM, and the remaining eight units were 

permitted to meet the limit based on PM10 tests. It is assumed that these units must meet the 

limit based on a 3-hour stack test, even though it was not specified. Ten units were permitted to 

meet PM limits (both filterable and PM10) between 0.12 and 0.2 lb/ton BLS, and three of these 

units were located at facilities that utilize the PM bubble compliance alternative. Table 5 

summarizes the representative PM limits for SDTs and the number of units subject to each limit, 

as discussed above.
14

Table 5: Representative PM Limits for 160 SDTs 

Group Representative Limit No. of 

SDTs

PM 

Bubble 

SDTs

0.12 lb/ton 

BLS

0.12 lb/ton BLS 8 0

0.12 lb/ton BLS (1-hour)* 3 0

0.12 lb/ton BLS* 8 2

Total SDTs at 0.12 lb/ton BLS 19 2

Between 

0.12 and 

0.2 lb/ton 

BLS

0.127 lb/ton BLS* 1 0

0.13 lb/ton BLS or 0.13 lb/ton BLS* 2 1

0.14 lb/ton BLS 1 1

0.15 lb/ton BLS 1 0

0.15 lb/ton BLS (monthly)* 1 0

0.18 lb/ton BLS 1 0

0.19 lb/ton BLS 1 1

0.192 lb/ton BLS and 0.19 lb/ton BLS* 1 0

0.199 lb/ton BLS* 1 0

Total SDTs between 0.12 and 0.2 lb/ton BLS 10 3

0.2 lb/ton 

BLS

0.2 lb/ton BLS 86 28***

0.2 lb/ton BLS* 30 10***

0.2 lb/ton BLS (3-hour) and 0.3 lb/ton BLS (1-hour) 1 0

Total SDTs at 0.2 lb/ton BLS 117 38

Above 0.2 

lb/ton BLS

0.23 lb/ton BLS* 1 1

0.246 lb/ton BLS 2 2

0.25 lb/ton BLS 2 2

0.26 lb/ton BLS* 1 1

0.3 lb/ton BLS 2 2

0.31 lb/ton BLS* 1 1

0.364 lb/ton BLS 1 1

0.46 lb/ton BLS 2 2

0.53 lb/ton BLS 1 1

0.585 lb/ton BLS 1 1

Total SDTs above 0.2 lb/ton BLS 14 14

*PM/PM10 limit

***These units are located at facilities that participate in the PM bubble. They are not likely to be credited or debited 

sources because they are permitted for the NESHAP limit; however, further review of the PM bubble compliance 

calculations would be required to confirm this assumption.

3. Smelt Dissolving Tank Total Reduced Sulfur

The original NSPS (promulgated in 1978) required SDTs to meet a TRS limit of 0.0168 

lb/ton BLS. Emission guidelines were also published in 1979 with a limit of 0.0168 lb/ton BLS 

for existing SDTs. Current permits for 34 SDTs contain a limit of 0.0168 lb/ton BLS. A review 

of the NSPS in 1986 revealed that units could not always meet 0.0168 lb/ton BLS even if they 

were using best demonstrated technology. As a result, the 1986 NSPS review revised the limit to

0.033 lb/ton BLS. Today, approximately half of SDTs (82 units) are permitted to meet 0.033 

lb/ton BLS.
15

Twenty units were permitted between limits of 0.0168 and 0.033 lb/ton BLS, with the 

majority (15) permitted at 0.032 lb/ton BLS. Five units were permitted to meet limits higher than 

the NSPS limit and range between 0.0336 lb/ton BLS and 0.066 lb/ton BLS. Twelve units had no 

apparent TRS limit specified in their permit, and seven units had a site-specific concentration or 

a mass limit specified. Table 6 summarizes the representative TRS limits for SDTs and the 

number of units subject to each limit.

Table 6: Representative TRS Limits for 160 SDTs 

Group Representative Limit No. of SDTs

0.0168

lb/ton BLS

0.0168 lb/ton BLS 32

0.0168 lb/ton BLS (12-hour) 1

0.0168 lb/ton BLS (24-hour) 1

Total SDTs at 0.0168 lb/ton BLS (original NSPS limit) 34

Between

0.0168 and

0.033 lb/ton

BLS

0.019 lb/ton BLS 2

0.0266 lb/ton BLS 1

0.03 lb/ton BLS 1

0.031 lb/ton BLS 1

0.032 lb/ton BLS 15

Total SDTs between 0.0168 and 0.033 lb/ton BLS 20

0.033 lb/ton

BLS

0.033 lb/ton BLS 71

0.033 lb/ton BLS (12-hour) 7

0.033 lb/ton BLS (24-hour) 3

0.033 lb/ton BLS (month) 1

Total SDTs at 0.033 lb/ton BLS (current NSPS limit) 82

Above

0.033 lb/ton

BLS

0.0336 lb/ton BLS 2

0.035 lb/ton BLS (12-hour) 1

0.066 lb/ton BLS (daily avg, quarterly stack test) 2

Total SDTs above 0.033 lb/ton BLS 5

Site specific

or no limits

No limit 12

Pound per hour provided 4

ppm limit provided 1

Ton per year provided 2

Total SDTs with no limit or site specific limits 19

C. Lime Kiln Permits

Permits for a total of 130 of the 131 lime kilns in the U.S. were compiled from the ICR 

responses and the permits from the state websites. Units and corresponding emission limits can 

be found in Table D-1 in Appendix D.

1. Lime Kiln Opacity

The NSPS does not currently require opacity monitoring for lime kilns because scrubbers 

were the best demonstrated technology during promulgation and during the 1986 review. 

Opacity monitoring for scrubber stacks is not appropriate because the stack gas contains 

moisture, which interferes with the opacity readings. The subpart MM NESHAP, however, 

requires opacity monitoring on units equipped with ESPs. Of the 130 permits reviewed, 38 lime 
16

kilns with ESPs were identified, including ESP-scrubber combination controls. Under the 

NESHAP, the ESP-controlled lime kiln opacity limit is 20 percent based on 6-minute averages. 

Similar to the monitoring allowance for recovery furnaces, lime kilns with ESPs are allowed to 

exceed 20 percent opacity for 6 percent of the 6-minute averages in a quarter without being 

considered in violation. 

The majority of the lime kilns (102 of 130) were permitted to meet an opacity limit, 

regardless of APCD, and 76 of these units were permitted to meet a 20 percent limit. Twenty 

seven of these units utilized ESPs as their APCD, 11 utilized a SCBR/ESP combination, and the 

remainder (38) utilized scrubbers. It is thought that the units with opacity limits that do not 

utilize an ESP show compliance through a visual opacity test (EPA Method 9) or through 

parametric monitoring. Twelve units specified an upper limit on the times during which the 

monitoring allowance was used, ranging from 27 percent to 87 percent.

Twenty-six units were permitted to meet an opacity limit greater than 20 percent. Two of 

these units used ESPs with state permitted limits of 40 percent and 25 percent. The remaining 

units utilized scrubbers, and it is thought that the opacity limits for these units are general state 

requirements broadly applicable for industrial equipment for which compliance is demonstrated 

through parametric monitoring or through visual opacity testing (i.e., there is no continuous 

opacity monitoring). Table 7 below summarizes the representative opacity limits for lime kilns 

and the number of units subject to each limit, as discussed above.
17

Table 7: Representative Opacity Limits for 130 Lime Kilns 

Group Representative Limit

No. of 

Kilns 

w/ESP

No. of 

Kilns 

w/ESPSCBR

No. of 

Kilns 

w/SCBR

20 percent

20% 0 0 11

20% (24-hour) 1 0 0

20% (3-min avg), cannot exceed more than 3-min per 60 

min period 1 0 0

20% (6-min avg) 19 5 21

20% (6-min avg) except for 1 6-min avg per hour, not to 

exceed 30% 0 1 0

20% (6-min avg) except for 1 6-min avg per hour, not to 

exceed 40% 1 0 0

20% (6-min avg) not to exceed 25% in any 6-min period 1 0 0

20% (6-min avg) not to exceed 27% for more than one 6-

min avg per hour) 1 0 0

20% (6-min avg) not to exceed 40% in 1- 6-min period/hr 0 1 3

20% (6-min avg) not to exceed 40% in any 6-min period 2 0 0

20% (6-min avg) not to exceed 60% in any 6-min period 0 1 0

20% (6-min avg) not to exceed 80% in any 6-min period 0 1 0

20% (average of 10 consecutive 6-min avgs), may exceed 

20% for no more than one 3-min period/hr 0 1 0

20% (average of 10 consecutive 6-min avgs), may exceed 

25% for no more than one 3-min period/hr 1 0 0

20% (not to exceed for more than 3 min in any 60 min 

period) 0 1 0

20% (parameter monitoring) 0 0 2

20% opacity (6-min avg) can be exceeded for 1 6-min 

avg/hour up to 87% 0 0 1

Total kilns at 20 percent (NESHAP limit) 27 11 38

Above 20

percent

25% 0 0 2

25% (6-min avg) 1 0 0

30% (6-min avg) 0 0 1

35% 0 0 4

35% (not to exceed for more than 6 min in any 60 min 

period) 0 0 1

40% 0 0 12

40% (6-min avg) 1 0 2

40% (6-min avg), can exceed for 1 6-min period per hour 

with no more than 4/24 hour (no upper limit) 0 0 2

Total kilns above 20 percent 2 0 24

N/A N/A (SCBR) 0 0 28

Total kilns N/A 0 0 28
18

2. Lime Kiln Particulate Matter

The NSPS currently requires lime kilns burning gas to meet a 0.066 gr/dscf filterable PM 

limit, and kilns burning liquid fuel oil to meet a 0.13 gr/dscf filterable PM limit. The subpart MM 

NESHAP requires existing kilns, regardless of fuel type, to meet a limit of 0.064 gr/dscf, and 

new kilns to meet 0.01 gr/dscf. The PM bubble in the subpart MM NESHAP allows facilities to 

determine facility-specific PM emission limits for their existing recovery furnaces, SDTs, and 

lime kilns, the sum of which must be no higher than the combination of the promulgated PM 

limits for these emission units. The facility can trade emissions amongst these units to derive this 

sum. The NSPS does not have this provision; therefore, units that are subject to the NSPS must 

meet the NSPS limits. All of the lime kilns for which permits were available except for five were 

permitted for the NSPS limit or lower. These units were not subject to the NSPS, and four were 

located at facilities that utilize the PM bubble compliance alternative. The remaining unit 

specified a 24-hour average PM limit of 0.2 gr/dscf. It is assumed that compliance for this unit is 

demonstrated using parametric monitoring on a daily basis.

Even though the subpart MM NESHAP removed the distinction between kiln fuel types, 18 

kilns were permitted with separate limits for periods of gas-fired and liquid fuel-fired burning. 

The gas-fired kiln limits ranged from 0.035 gr/dscf to 0.067 gr/dscf, with seven units permitted 

to meet 0.064 gr/dscf while burning gas and 0.13 gr/dscf while burning fuel oil (a combination of 

the NESHAP and the NSPS limits). Four units were permitted to be more stringent than both 

standards, while maintaining different limits for gas- and liquid fuel-fired periods, and two of 

these units were located at facilities participating in the PM bubble compliance alternative. One 

unit had a less stringent limit for periods of burning fuel oil (0.2 gr/dscf), and six units had a less 

stringent limit for periods of burning gas. These six units were subject to the PM bubble.

A total of 17 units were permitted below 0.064 gr/dscf with no fuel distinctions. Two units 

were permitted to meet the new source NESHAP limit of 0.01 gr/dscf. The remaining 15 units 

had permitted values between 0.0125 and 0.056 gr/dscf, with three located at facilities that utilize 

the PM bubble compliance alternative. 

Over half of the kilns (72) were permitted to meet the NESHAP limit of 0.064 gr/dscf, and 8 

were permitted to meet the liquid fuel-fired NSPS limit of 0.13 gr/dscf. The remaining 10 units 

were permitted between 0.065 and 0.12 gr/dscf, with 9 being located at facilities that participate 

in the PM bubble compliance alternative. Table 8 summarizes the representative PM limits for 

lime kilns and the number of units subject to each limit, as discussed above.
19

Table 8: Representative PM Limits for 130 Lime Kilns 

Group Representative Limit No. of 

Kilns 

PM 

Bubble 

Kilns

0.01

gr/dscf

0.01 gr/dscf 2 0

Total kilns at 0.01 gr/dscf (NESHAP new source limit) 2 0

Below 

0.064 

gr/dscf

0.0125 gr/dscf 1 1

0.016 gr/dscf 1 0

0.02 gr/dscf (3-hour), 0.015 gr/dscf (annual) and 0.018 

gr/dscf (3-hour)*, and 0.013 gr/dscf (annual)* 1 0

0.03 gr/dscf and 0.03 gr/dscf* 5 0

0.033 gr/dscf* 1 0

0.034 gr/dscf* 1 0

0.035 gr/dscf and 0.035 gr/dscf* 2 1

0.0451 gr/dscf 1 0

0.05 gr/dscf 1 0

0.056 gr/dscf 1 1

Total kilns below 0.064 gr/dscf 15 3

0.064 

gr/dscf

0.064 gr/dscf 46 10***

0.064 gr/dscf* 26 8***

Total kilns at 0.064 gr/dscf 72 18

Between 

0.065 and 

0.13 

gr/dscf

0.065 gr/dscf 1 0

0.066 gr/dscf and 0.066 gr/dscf* 2 2

0.067 gr/dscf 1 1

0.1 gr/dscf 3 3

0.12 gr/dscf* 3 3

Total kilns between 0.065 and 0.13 gr/dscf 10 9

0.13 

gr/dscf

0.13 gr/dscf 5 4

0.13 gr/dscf* 3 2

Total kilns at 0.13 gr/dscf 8 6

Separate 

limits for 

fuel type

0.035 gr/dscf (NG), 0.064 gr/dscf (fuel oil) 2 1

0.035 gr/dscf (NG), 0.13 gr/dscf (fuel oil) 1 0

0.04 gr/dscf (NG), 0.064 gr/dscf (fuel oil) 1 1

0.064 gr/dscf (NG), 0.13 gr/dscf (fuel oil) 7 5

0.064 gr/dscf (NG), 0.2 gr/dscf (fuel oil) 1 1

0.067 gr/dscf (NG)*, 0.13 gr/dscf (fuel oil)* 1 1

0.067 gr/dscf (NG), 0.106 gr/dscf (fuel oil) 2 2

0.067 gr/dscf (NG), 0.13 gr/dscf (fuel oil) 3 3

Total kilns with separate limits for fuel type 18 14

Above 

0.13 

gr/dscf

0.15 gr/dscf 1 1

0.176 gr/dscf 1 1

0.192 gr/dscf 1 1

0.2 gr/dscf (24-hour)* 1 0

0.24 gr/dscf* 1 1

Total kilns above 0.13 gr/dscf 5 4

*PM/PM10 limit

***These units are located at facilities that participate in the PM bubble. They are not likely to be credited or debited 

sources because they are permitted for the NESHAP limit; however, further review of the PM bubble compliance 

calculations would be required to confirm this assumption.
20

3. Lime Kiln Total Reduced Sulfur

The NSPS requires that lime kilns constructed, reconstructed, or modified after 1976 limit 

their TRS emissions to 8 ppm. The regulation requires continuous TRS monitoring with a 12-

hour averaging period for reporting. Of the 130 lime kilns for which permits were available, 57 

were permitted to meet 8 ppm. Three of these units also had a 2-hour maximum limit of 80 ppm. 

Four kilns were permitted at a more stringent limit. Two of these units were required to meet a 5 

ppm limit, two were required to meet a 7 ppm limit (all based on 12-hour averages). One kiln 

was required to meet a 7.5 ppm limit based on a 24-hour average with a 10 ppm hourly average 

limit. 

The emission guidelines require existing lime kilns to limit their TRS emissions to 20 ppm. 

There were 50 units permitted to meet this limit. Six of these units demonstrate compliance on a 

24-hour basis, and five additional units must not exceed 80 ppm for more than 2 hours. One unit 

has a 12-hour 20 ppm limit as well as a 50 ppm 1-hour limit. State regulations in three states

(Georgia, Ohio, and Arkansas) specify higher TRS limits of 40 ppm and 50 ppm, and 12 units 

were permitted to meet these limits. Five units had no apparent TRS limits in their permits, and 

one unit had a mass-based limit (tons per year) instead of concentration. Table 9 summarizes the 

representative TRS limits for lime kilns and the number of units subject to each limit, as 

discussed above.

 

Table 9: Representative TRS Limits for 130 Lime Kilns 

Group Representative Limit* No. of 

Kilns

Below 8

ppm

5 ppm (12-hour) 2

7 ppm (12-hour) 2

7.5 ppm (24-hour) and 10 ppm (1-hour) 1

Total kilns below 8 ppm 5

8 ppm

8 ppm (12-hour) 53

8 ppm (12-hour) when used as LVHC control, 40 ppm other 1

8 ppm (12 hour) and 80 ppm (2 hour max) 3

Total kilns at 8 ppm (NSPS limit) 57

20 ppm

20 ppm (24-hour) 6

20 ppm (12-hour) 38

20 ppm (24-hour) with max 80 ppm for 2 hours 5

20 ppm (12-hour), 50 ppm (1-hour) 1

Total kilns at 20 ppm (Emission guidelines limit) 50

Above 20

ppm

40 ppm (12-hour) 6

40 ppm (24-hour) 5

50 ppm (12-hour) 1

Total kilns above 20 ppm 12

Other

Tons per year limit provided 1

No limit 5

Total kilns with no limit or site-specific limit 6
21

D. NCG Source Permits

Non-condensable gas source permits for 97 kraft pulp mills were reviewed and tabulated to 

determine which regulatory option each mill uses to comply with the NSPS limit for TRS from

condensate strippers, digesters, evaporators, and brown stock washers. The NSPS requires that 

any gases from these systems that contain more than 5 ppm, corrected to 10 percent oxygen be 

treated using one of the following methods:

1. Combust gases in a lime kiln subject to subpart BB; or

2. Combust gases in a recovery furnace subject to BB; or

3. Combust gases in an incinerator or other device and are subjected to a minimum 

temperature of 1200°F for at least 0.5 second; or

4. Demonstrate to the Administrator that combustion of gases from brown stock washer 

systems is technologically or economically unfeasible; or

5. Control gases by a means other than combustion (with a limit of 5 ppm, uncorrected 

for oxygen content).

 Condensate strippers were located at 56 of the 97 kraft pulp mills for which we have permit 

data, and all of the stripper off-gases (SOGs) were treated by combustion. The majority of the 

mills (33) were permitted to treat SOGs using a standalone incinerator or a boiler. Other mills

(14) were permitted to treat SOGs by combustion in a lime kiln or a recovery furnace subject to 

subpart BB. These facilities were permitted to use either a lime kiln or a recovery furnace as the 

main control device, with the other unit as the backup control device. Two additional strippers

were permitted at 5 ppm based on combustion control (assumed to be either a recovery furnace 

or boiler). Six strippers were permitted to use a thermal oxidizer for treatment, and one 

additional stripper was permitted to route SOGs to a methanol rectifier system, followed by 

combustion at 1450°F for 0.15 seconds. 

Digester systems at all of the facilities were permitted to treat gases using incineration. The 

majority of the systems (56) were permitted to treat the gases using a standalone incinerator or a 

boiler. Other digesters (32) were permitted to treat the gases by combustion in a lime kiln or a 

recovery furnace, and 5 additional units were permitted at 5 ppm or 8 ppm based on combustion 

control in a recovery furnace or a lime kiln, respectively. Four units were permitted to use a 

thermal oxidizer for treatment.

Similar to digester systems, all of the evaporator systems were permitted for incineration

control. The majority of the systems (57) were permitted to treat gases using a standalone 

incinerator or boiler. Other units (31) were permitted to treat the gases by combustion in a lime 

kiln or a recovery furnace, and 4 additional units were permitted at 5 ppm or 8 ppm based on 

combustion control in a recovery furnace or a lime kiln, respectively. Four units were permitted 

to use a thermal oxidizer for treatment, and one additional unit was permitted to route SOGs to a 

methanol rectifier system followed by combustion at 1450°F for 0.15 seconds. 

Many brown stock washer systems (at 36 facilities) achieve compliance with subpart S 

through the CCA or were exempt from the NSPS because of the diffusion washer exemption. 

Three facilities used controls other than combustion to reduce the TRS emissions to below 5 
22

ppm, but the majority (58) were permitted to treat gases through combustion, either by a 

recovery furnace or lime kiln (18), or by an incinerator or boiler (40).

A summary of the TRS limits found in permits for condensate strippers, digesters,

evaporators, and brown stock washers is provided in Table E-1 of Appendix E. 

E. Incinerator Control Device Permits

Kraft mills use incineration control devices (e.g, thermal oxidizers) as primary or backup 

controls to (1) oxidize malodorous TRS emissions from NCG sources to SO2 under the NSPS (or 

state limits derived from the emission guidelines), and (2) destroy organic HAP emissions under 

the subpart S NEHSAP. Because they target different pollutants, the subpart BB NSPS and 

subpart S NESHAP each specify a different minimum temperature and retention time for 

incineration control devices. Subpart BB specifies a minimum temperature of 1200o

F for TRS 

control, while subpart S specifies a higher temperature of 1600o

F for HAP control. Neither rule 

prescribes a specific averaging time or recording frequency for temperature, though subpart BB 

specifies excess emissions periods in excess of 5 minutes when the minimum temperature is not 

achieved. (Retention time is an incinerator design value that is not monitored.) The NCG source 

permits involving incineration controls were reviewed for information on retention times, 

minimum temperature limits (including any site-specific temperature limits), temperature 

recording frequency, and temperature averaging times. The incinerator parameters for 23 

incinerators (at 20 facilities) were tabulated. It was observed that many of the permits did not 

indicate a temperature averaging time. Varying averaging times from 5 minutes to 24 hours were 

indicated for those with permits that specified them. Of these units, five were permitted based on 

3-hour averages, two were permitted based on 5-minute averages, one was permitted based on a 

24-hour average, and one was permitted based on a 1-hour average. The majority (16 units) 

recorded temperature continuously and reported the time during which the incineration 

temperature was below the minimum temperature based on 5-minute intervals. Additionally, 

three units recorded temperature once per shift, and two units recorded temperature every 15 

minutes. Because the temperature requirement for subpart S is 1600oF and facilities can 

demonstrate compliance at a lower temperature, many site-specific minimum temperatures were 

determined for the incinerators, ranging from 1200°F to 1500°F. Table F-1 in Appendix F shows 

a summary of the reviewed incinerator permits.
A-1

APPENDIX A: Websites with Air Permit Information
A-2

Table A-1: Websites for Air Permits

EPA Found

Region State/territory permits? Permits

I Connecticut Yes http://www.ct.gov/dep/cwp/view.asp?a=2684&q=322176&depNav_GID=1619

Massachusetts Yes http://www.mass.gov/dep/public/publiche.htm

Maine Yes http://www.maine.gov/dep/air/permits/index.html

New Hampshire Yes http://des.nh.gov/organization/divisions/air/pehb/tvs/table.htm

Rhode Island Yes http://www.dem.ri.gov/programs/benviron/air/opperms.htm

Vermont Yes http://www.anr.state.vt.us/air/Permitting/htm/OperatePermits.htm

II New Jersey Yes http://www.nj.gov/dep/aqpp/onlinehelp.html

http://www.nj.gov/dep/aqpp/publicnotices.htm

New York Yes http://www.dec.ny.gov/chemical/32249.html

Puerto Rico No None

Virgin Islands No None

III Delaware No None

Dist. of Columbia No None

Maryland No None

Pennsylvania No http://www.ahs2.dep.state.pa.us/eFactsWeb/default.aspx

Virginia Yes http://www.deq.state.va.us/Programs/Air/PermittingCompliance/Permitting/IssuedTitleVPermits.aspx

West Virginia Yes http://www.dep.wv.gov/daq/permitting/titlevpermits/Pages/default.aspx

IV Alabama Yes http://www.adem.state.al.us/newsEvents/publicNotices.cnt

Florida Yes http://www.dep.state.fl.us/air/emission/permitting.htm

Georgia Yes http://www.georgiaair.org/

Kentucky Yes http://air.ky.gov/Pages/AirPermits.aspx

Yes http://www.kdheks.gov/bar/publicnotice.html

Louisville, KY Yes http://www.louisvilleky.gov/APCD/PermitsAndCompliance/TitleVStatus.htm

Mississippi Yes http://opc.deq.state.ms.us/default.aspx

North Carolina Yes http://daq.state.nc.us/permits/TV_permits/

Yes http://daq.state.nc.us/cgi-bin/perm_draftrev.cgi

Mecklenburg Co., NC Yes http://ntplanweb.co.mecklenburg.nc.us/epic+/reportenvpermits.asp

Forsyth Co., NC Yes http://www.co.forsyth.nc.us/EAP/public-notices.aspx

South Carolina No http://www.scdhec.gov/environment/baq/PublicNotice.asp

Tennessee Yes http://www.tn.gov/environment/apc/ppo/

Nashville-Davidson Co., 

TN

Yes https://permits.nashville.gov/kivanet/citizen/index.cfm
A-3

EPA Found

Region State/territory permits? Permits

V Illinois Yes http://www.epa.gov/region5/air/permits/ilonline.html

Indiana Yes http://www.in.gov/ai/appfiles/idem-caats/

Yes http://www.epa.gov/region5/air/permits/inonline.html

Michigan Yes http://www.deq.state.mi.us/aps/

Yes http://www.epa.gov/region5/air/permits/mionline.html

Minnesota Yes http://www.pca.state.mn.us/index.php/air/air-permits-and-rules/air-permits-and-forms/air-permitsissued-in-minnesota/air-permits-issued-in-minnesota.html?menuid=&redirect=1

Ohio Yes http://www.epa.state.oh.us/dapc/newpermits/issued.aspx

http://extapex.epa.state.oh.us/epaxp/f?p=840:10:4107357843794407

Wisconsin Yes http://dnr.wi.gov/airpermits/search.html

Tribal Areas Yes http://yosemite.epa.gov/r5/r5ard.nsf/Tribal+Permits!OpenView

VI Arkansas Yes http://www.adeq.state.ar.us/compsvs/webmaster/databases.htm

Yes http://www.adeq.state.ar.us/air/branch_permits/default.htm

Louisiana Yes http://edms.deq.louisiana.gov/app/Doc/QueryDef.aspx

New Mexico Yes http://www.nmenv.state.nm.us/aqb/permit/aqb_draft_permits.html

Oklahoma Yes http://www.deq.state.ok.us/AQDNew/permitting/pubreview.htm

Texas Yes http://webmail.tceq.state.tx.us/gw/webpub

VII Iowa Yes http://www.iowadnr.gov/InsideDNR/RegulatoryAir/OperatingPermits.aspx

Kansas Yes http://www.kdheks.gov/bar/publicnotice.html

Wyandotte Co., KS Yes http://www.wycokck.org/dept.aspx?id=5296&menu_id=942&banner=15284

Missouri Yes http://www.dnr.mo.gov/env/apcp/air_permits.htm

Nebraska No None

Lincoln-Lancaster Co., NE Yes http://www.lincoln.ne.gov/city/health/environ/pollu/pn/index.htm

VIII Colorado Yes http://www.cdphe.state.co.us/ap/titlev.html

Montana Yes http://www.deq.mt.gov/AirQuality/ARMpermits/AWM_final_permit.mcpx

Yes http://www.deq.mt.gov/AirQuality/ARMpermits/AirQuality.mcpx

North Dakota Yes http://www.health.state.nd.us/EHS/PublicNotices.aspx

South Dakota Yes http://denr.sd.gov/des/aq/aatitleV_f.aspx

Yes http://denr.sd.gov/des/aq/aapubnot.aspx

Utah Yes http://www.airquality.utah.gov/Permits/Permitting_Reports.htm

Wyoming Yes http://deq.state.wy.us/aqd/TitleVOperatingPermitProgram.asp
A-4

EPA Found

Region State/territory permits? Permits

IX Arizona Yes http://www.azdeq.gov/environ/air/permits/title_v/index.html

http://www.azdeq.gov/cgi-bin/vertical.pl?t=search&kewerd=air%20permit

Yes http://www.epa.gov/region09/air/permit/index.html

California Yes http://www.epa.gov/region09/air/permit/index.html

South Coast AQMD Yes http://www.aqmd.gov/webappl/publicnotices/

Bay Area AQMD Yes http://www.baaqmd.gov/Divisions/Engineering/Title-V-Permit-Programs/Title-V-Permits.aspx

Guam and Pacific Islands Yes http://www.epa.gov/region09/air/permit/index.html

Hawaii Yes http://www.epa.gov/region09/air/permit/index.html

Nevada Yes http://www.epa.gov/region09/air/permit/index.html

X Alaska Yes http://www.state.ak.us/dec/air/ap/mainair.htm

Idaho Yes http://www.deq.idaho.gov/permitting/issued-permits.aspx

Oregon Yes http://www.deq.state.or.us/aq/permit/alphalist.htm

Yes http://www.deq.state.or.us/news/publicnotices/PN.asp

Lane Co., OR Yes http://www.lrapa.org/air_quality_permits/title_v_operating_permits.php

Washington Yes http://apps.ecy.wa.gov/industrial/

Spokane Co., WA Yes http://www.spokanecleanair.net/air_operating_permits.asp?template=false

Olympic Region CAA Yes http://www.orcaa.org/services/air-operating-permits/

Pugent Sound CAA Yes http://www.pscleanair.org/announce/permits/default.aspx

Southwest CAA Yes http://www.swapca.org/permitsAOPfinals.asp
B-1

APPENDIX B: Recovery Furnace Permit Limits
B-2

Table B-1: Representative Permit Limits for Recovery Furnaces

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

100.037A NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.027 gr/dscf

102.RB10 NDCE DBESP-WPR No No

20% (6-min avg) can exceed 1 6 

min period per hour 5 ppm (12-hour)

0.027 gr/dscf (1-hour)* and 

0.02 gr/dscf (annually)*

103.G-158 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

104.EUG D6 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.015 gr/dscf*

105.EU445A DCE WBESP No No

35% (6-min avg) can exceed for 30 

min in 180 min or 60 min in 24 hr 10 ppm (24-hour) 0.044 gr/dscf*

105.EU445C NDCE DBESP-WPR Yes No

35% (6-min avg) can exceed for 30 

min in 180 min or 60 min in 24 hr 5 ppm (24-hour) 0.044 gr/dscf*

107.08-P1 NDCE DBESP Yes No 20% (6-min avg) 4 ppm (12-hour) 0.021 gr/dscf*

108.RB3 NDCE DBESP Yes No

35% (6-min avg) can exceed 1 6-

min average in 60 min period 3 ppm (3-hour) 0.015 gr/dscf*

109.RB3 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.025 gr/dscf*

109.RB4 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

111.G-44 NDCE DBESP-WPR Yes No

35% (6-min avg) - not to exceed 

87% for more than 1 6-min avg/hr 

and 4 in 24 hr 5 ppm (12-hour) 0.044 gr/dscf

112.AA-100 NDCE DBESP Yes No

35% (6-min avg) - 40% for startup 

for up to 15 minutes (not to exceed 

3 SU/24 hr) - 20% when burning 

fuel oil alone 5 ppm (12-hour) 0.023 gr/dscf*

114.U500 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour)

0.021 gr/dscf and 0.0298 

gr/dscf**

115.RE01 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

116.003 NDCE WBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

117.B21 NDCE DBESP No No 20% (6-min avg) 5 ppm (12-hour)

0.027 gr/dscf and 0.034 

gr/dscf** 

119.EQT008 DCE DBESP No Yes 40% (6-min avg) 20 ppm (12-hour) 0.02 gr/dscf*

119.EQT010 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.029 gr/dscf (annual)*
B-3

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

120.F7 NDCE DBESP Yes Yes

35% (6-min avg) and 20% (6-min 

avg) - not to exceed 27% for more 

than one 6-min avg/hr when 

burning fuel oil 5 ppm (12-hour)

0.021 gr/dscf and 0.0238 

gr/dscf** 

121.000013 DCE DBESP No No 20% (6-min avg)

20 ppm (12-hour) / 50 ppm 

(1-hour) 0.044 gr/dscf*

121.000014 DCE DBESP No No 20% (6-min avg)

20 ppm (12-hour) / 50 ppm 

(1-hour) 0.044 gr/dscf*

124.001 DCE DBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 17.5 ppm (12-hour) 0.044 gr/dscf

124.019 DCE WBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 17.5 ppm (12-hour) 0.044 gr/dscf

126.RECOV NDCE WBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

127.REC1 NDCE WBESP Yes No

20% (1 hour avg) and 35% (6-min 

avg) 5 ppm (12-hour) 0.044 gr/dscf

130.1 DCE WBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

130.2 DCE WBESP No Yes 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

130.3 NDCE DBESP No Yes 35% (6-min avg) 20 ppm (12-hour) 0.025 gr/dscf

131.5 DCE DBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.035 gr/dscf*

131.6 NDCE DBESP Yes Yes

20% (6-min avg) - 30% for one 6-

min period/hr 5 ppm (12-hour) 0.03 gr/dscf*

132.4RB NDCE DBESP-WPR No No

20% (1 hour avg) and 35% (6-min 

avg) 5 ppm (12-hour) 0.044 gr/dscf

132.5RB NDCE DBESP-WPR Yes No

20% (1 hour avg) and 35% (6-min 

avg) 5 ppm (12-hour) 0.044 gr/dscf

133.10 NDCE DBESP Yes Yes

35% (6-min avg) and 20% (6-min 

avg) when firing fuel oil 5 ppm (12-hour) 0.044 gr/dscf

135.003-1 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.038 gr/dscf
B-4

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

136.EU 005 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.025 gr/dscf*

137.189 NDCE DBESP-WPR No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) 15 ppm (24-hour) 0.04 gr/dscf

137.721 NDCE DBESP-WPR Yes No

35% (6-min avg) up to 40% for 3 

min in any hour 5 ppm (12-hour) 0.044 gr/dscf

138.002 NDCE DBESP-WPR Yes No 20% (6-min avg) 5 ppm (12-hour) 0.0294 gr/dscf*

139.02 NDCE

DBESP-WPR/ 

DBESP/DBESP No No 35% (6-min avg) 5 ppm (12-hour)

0.044 gr/dscf (3-hour) and 

0.05 gr/dscf (1-hour)

140.55 NDCE DBESP No No 35% (6-min avg) 5 ppm (1-hour) 0.044 gr/dscf

142.CU7214 DCE DBESP No No 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

142.CU7215 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

142.CU7216 DCE WBESP No No 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

143.7000 DCE** WBESP No No 35% (6-min avg) 20 ppm (24-hour) 0.044 gr/dscf

143.7010 DCE** WBESP No No 35% (6-min avg) 20 ppm (24-hour) 0.044 gr/dscf

143.7020 DCE** WBESP No No 35% (6-min avg) 20 ppm (24-hour) 0.044 gr/dscf

145.54 DCE WBESP No No 20% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

145.55 DCE WBESP No No 20% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

146.8 DCE WBESP No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) 5 ppm (24-hour) 0.044 gr/dscf*

147.5 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

147.14 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

146.16 NDCE DBESP-WPR Yes No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) 5 ppm (12-hour) 0.027 gr/dscf*

148.001 NDCE DBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.036 gr/dscf

148.007 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.028 gr/dscf

149.B011 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.021 gr/dscf
B-5

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

150.CREC-1 NDCE DBESP Yes No

30% (6-min avg) not to exceed for 

more than 1 6-min avg in 3 hour 

period 5 ppm (12-hour) 0.044 gr/dscf

151.REC004 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.027 gr/dscf

151.REC007 DCE DBESP No Yes

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 20 ppm (12-hour) 0.057 gr/dscf

152.03 DCE WBESP/SCBR No Yes 35% (6-min avg)

15 ppm (24-hour) and no 

more than 60 1-min spikes 

above 40 ppm in 24 hr 0.044 gr/dscf

153.EQT 0065 NDCE SCBR No No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

154.P36 DCE WBESP No Yes

20% (6-min avg) and 80% (6-min 

avg) during startup or cleaning (not 

more than 6 min in any hour) 17.5 ppm (12-hour)

0.039 gr/dscf and 0.0287 

gr/dscf* 

154.P37 DCE WBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour)

0.033 gr/dscf and 0.0257 

gr/dscf*

154.P39 DCE WBESP No Yes

20% (6-min avg) and 80% (6-min 

avg) during startup or cleaning (not 

more than 6 min in any hour) 17.5 ppm (12-hour) 0.0303 gr/dscf

155.RECOVERY 

FURNACE NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.033 gr/dscf (1-hour)

156.RF18 DCE WBESP No No 35% (6-min avg) 17.5 ppm (24-hour) 0.044 gr/dscf (1-hour)*

156.RF19 DCE WBESP No No 30% (6-min avg) 10 ppm (24-hour) 0.04 gr/dscf (1-hour)*

156.RF22 NDCE DBESP Yes No 20% (6-min avg) 3 ppm (12-hour) 0.027 gr/dscf*

157.RB2 NDCE WBESP No No 20% (6-min avg) 15 ppm (12-hour) 0.044 gr/dscf

159.F3 NDCE SCBR No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 20 ppm (24-hour) 0.044 gr/dscf

162.381A NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

162.382A NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.03 gr/dscf
B-6

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

163.RF1901 DCE WBESP No Yes

35% (6-min avg) not to exceed 

more than 6% of operating time 20 ppm (12-hour) 0.023 gr/dscf

163.RF2904 NDCE WBESP Yes Yes

35% (6-min avg) not to exceed 

more than 6% of operating time 5 ppm (12-hour) 0.024 gr/dscf

164.B08 NDCE DBESP No Yes 20% (6-min avg) 17.5 ppm (12-hour) 0.036 gr/dscf

164.B10 NDCE DBESP No Yes 20% (6-min avg) 17.5 ppm (12-hour) 0.036 gr/dscf

165.000006 NDCE DBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

165.000013 NDCE DBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

166.RB01 DCE WBESP No Yes

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

167.005RB DCE WBESP No Yes 35% (6-min avg) 40 ppm (12-hour) 0.041 gr/dscf

166.RB02 DCE WBESP/SCBR Yes No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg)

17.5 ppm (12-hour) / 11.5 

ppm (yearly) 0.043 gr/dscf

169.04 NDCE WBESP Yes No 20% (6-min avg) 5 ppm (1-hour)

0.02 gr/dscf (annual) and 

0.044 gr/dscf (3-hour)

169.05 NDCE WBESP Yes No 20% (6-min avg) 5 ppm (1-hour)

0.02 gr/dscf (annual) and 

0.044 gr/dscf (3-hour)

171.002 DCE DBESP-WPR No Yes

35% (6-min avg) and 20% for 10 

consecutive 6-min avgs 40 ppm (12-hour) 0.044 gr/dscf*

171.003 DCE DBESP-WPR No Yes

35% (6-min avg) and 20% for 10 

consecutive 6-min avgs 40 ppm (12-hour) 0.044 gr/dscf*

171.004 DCE DBESP-WPR No Yes

35% (6-min avg) and 20% for 10 

consecutive 6-min avgs 40 ppm (12-hour) 0.044 gr/dscf*

172.RB01 NDCE WBESP No Yes 35% (6-min avg)

20 ppm (12-hour) / 4.5 ppm 

(12 month rolling) 0.024 gr/dscf

172.RB02 NDCE WBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

173.RECOVB NDCE DBESP No Yes 20% (6-min avg)

4 ppm (24-hour), can not 

exceed 8 ppm for more than 

60 min/day 0.03 gr/dscf

174.G-32 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.043 gr/dscf

174.G-92 DCE WBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.051 gr/dscf
B-7

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

175.RB2A DCE WBESP No Yes

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time 20 ppm (24-hour) 0.055 gr/dscf

175.RB3A NDCE DBESP Yes Yes

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time 

and 20% (6-min avg) allowed to 

exceed up to 27% for 1 6-min 

avg/hour while firing fuel oil 5 ppm (12-hour) 0.021 gr/dscf

176.RB7 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.021 gr/dscf

177.EU0804 NDCE DBESP Yes No 35% (6-min avg)

4.3 ppm (24-hour) / 10 ppm 

(2-hour) / 5 ppm (12-hour) 0.027 gr/dscf*

178.08P012 NDCE DBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 5 ppm (12-hour) 0.042 gr/dscf

178.08P013 NDCE DBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 5 ppm (12-hour) 0.042 gr/dscf

179.RF3 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.021 gr/dscf

180.D001 NDCE DBESP Yes Yes

35% (6-min avg) and 20% not to 

exceed for more than 1 6-min 

period per hour up to 27% when 

burning fuel oil 5 ppm (12-hour) 0.027 gr/dscf

181.10 NDCE WBESP No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 20 ppm (12-hour) 0.044 gr/dscf

181.49/50 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

182.037 NDCE DBESP Yes No

20% (3-min avg) not to exceed 

35% 5 ppm (12-hour) 0.027 gr/dscf

183.002 NDCE DBESP No No

20% (6-min avg) can exceed 2% of 

6-min avg/quarter and 1% for 4 

consecutive quarters 5 ppm (12-hour) 0.028 gr/dscf*

184.72 NDCE DBESP-WPR Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf
B-8

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

184.73 NDCE DBESP-WPR Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

185.02 NDCE DBESP/SCBR No Yes 20% (6-min avg) 5 ppm (12-hour) 0.033 gr/dscf*

186.RB15 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.024 gr/dscf

188.014RB1 DCE WBESP No Yes 35% (6-min avg) 10 ppm (24-hour)

0.044 gr/dscf (daily)* and 

0.033 gr/dscf (3-hour)*

188.016RB2 DCE WBESP No Yes 35% (6-min avg) 10 ppm (24-hour)

0.044 gr/dscf (daily)* and 

0.033 gr/dscf (3-hour)*

189.SN26 NDCE WBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.02 gr/dscf*

190.R400 NDCE DBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.03 gr/dscf

190.R401 NDCE DBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.03 gr/dscf

190.R402 NDCE DBESP No Yes

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 5 ppm (12-hour) 0.024 gr/dscf

195.003 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.021 gr/dscf*

196.SN-06 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

196.SN-14 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

197.2 DCE DBESP/SCBR No No 20% (6-min avg) 100 ppm (12-hour) 0.044 gr/dscf*

198.019 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.027 gr/dscf

199.002 NDCE DBESP No No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

200.007RF2 NDCE DBESP No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 20 ppm (12-hour) 0.044 gr/dscf

200.007RF3 NDCE

DB-WBESP [2-

sided dry and 

wet] Yes No 35% (6-min avg) 5 ppm (12-hour) 0.025 gr/dscf*

201.SR0001 NDCE DBESP No No 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

202.Recovery 

Furnace EU320 NDCE DBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*
B-9

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

203.RF#2 NDCE DBESP Yes No

35% (6-min avg) and 20% (6-min 

avg) when firing fuel oil 5 ppm (12-hour) 0.044 gr/dscf*

203.RF#3 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour)

0.027 gr/dscf (1-hour)* and 

0.021 gr/dscf (rolling 

annual)*

205.009 DCE WBESP No No 35% (6-min avg) 20 ppm (12-hour) 0.044 gr/dscf

206.G-31 DCE WBESP No Yes

40% (6-min avg) up to 90% for 

one 6-min avg/hr and no more than 

4/24 hr 5 ppm (12-hour) 0.032 gr/dscf

206.G-32 DCE WBESP No Yes

35% (6-min avg) can exceed for 1 

6-min avg/hr and no more than 

4/24 hour 5 ppm (12-hour) 0.032 gr/dscf

207.038 NDCE DBESP Yes Yes

20% (10 consecutive 6-min avgs 

and can exceed for no more than 3 

min/hour) , 35% (6-min avg), and 

60% (1-min avg) 5 ppm (12-hour) 0.044 gr/dscf

226.RECB1 NDCE WBESP No No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

226.RECB2 NDCE WBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

240.RF01 NDCE DBESP No No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time up 

to 40% 5 ppm (24-hour) 0.044 gr/dscf

240.RF04 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

242.AA-011 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf*

243.R401 NDCE DBESP No No 35% (6-min avg)

10 ppm (12-hour) / 4 ppm 

H2S 0.021 gr/dscf

243.R407 NDCE DBESP Yes No

35% (6-min avg) and 20% (6-min 

avg) when firing fuel oil

5 ppm (12-hour) / 4 ppm 

H2S 0.021 gr/dscf

340.005 NDCE DBESP No Yes 35% (6-min avg) 40 ppm (12-hour) 0.044 gr/dscf*

525.EU18 NDCE DBESP-WPR No No 20% (6-min avg) 5 ppm (12-hour) 0.03 gr/dscf
B-10

RTI + Emission 

Unit ID

DCE or 

NDCE APCD Type

Subject 

to NSPS

PM 

Bubble Opacity Limit TRS Limit PM Limit

531.RF15 NDCE DBESP Yes No

20% (10 consecutive 6-min avg) 

and 35% (6-min avg) not to exceed 

more than 6% of operating time 

and 20% (6-min avg) allowed to 

exceed up to 27% for 1 6-min 

avg/hour while firing fuel oil 5 ppm (12-hour) 0.044 gr/dscf

600.G0803 DCE WBESP Yes Yes 20% (6-min avg) 5 ppm (12-hour) 0.044 gr/dscf

600.G0806 NDCE DBESP Yes Yes 35% (6-min avg) 5 ppm (12-hour) 0.015 gr/dscf

606.RB2 NDCE DBESP No No

20% (6-min avg), up to 35% 

during SU and SD, not to exceed 4 

hours per SU/SD event 5 ppm (12-hour) 0.03 gr/dscf

606.RB3 DCEa DBESP No No

20% (6-min avg), up to 35% 

during SU and SD, not to exceed 4 

hours per SU/SD event 5 ppm (12-hour) 0.03 gr/dscf

606.RB4 NDCE DBESP No No

35% (6-min avg), EE not to exceed 

more than 4 hours per SU/SD 

event 5 ppm (12-hour) 0.044 gr/dscf

610.4 NDCE DBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.035 gr/dscf*

610.5 NDCE DBESP No Yes 35% (6-min avg) 5 ppm (12-hour) 0.035 gr/dscf*

613.001 DCE DBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 35 ppm (12-hour) 0.044 gr/dscf*

613.002 DCE DBESP No No

35% (6-min avg) not to exceed 

more than 6% of operating time 35 ppm (12-hour) 0.044 gr/dscf*

615.24 NDCE DBESP Yes No

25% (1-hr avg) and 35% (6-min 

avg) 5 ppm (12-hour)

0.044 gr/dscf (daily as 

determined by opacity 

correlation)*

617.B14 NDCE DBESP Yes No 20% (6-min avg) 5 ppm (12-hour) 0.03 gr/dscf

208228535.001 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.025 gr/dscf

208228535.007 NDCE DBESP Yes No 35% (6-min avg) 5 ppm (12-hour) 0.025 gr/dscf

*PM/PM10 limit and **total PM limit. EE = excess emissions, SU = startup, SD = shutdown a Converted to NDCE is 2011.
C-1

APPENDIX C: Smelt Dissolving Tank Permit Limits
C-2

Table C-1: Representative Permit Limits for SDTs

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

100.109 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

102.SDTV10 SCBR No No 0.0168 lb/ton BLS 20% (6-min avg) 0.12 lb/ton BLS*

103.G-225 SCBR No Yes 0.032 lb/ton BLS 20% (6-min avg) up to 87% 

for 1 6-min period per hour 0.2 lb/ton BLS

104.EUG E4b INC_RF Yes No 0.033 lb/ton BLS NA/INC_RF 0.2 lb/ton BLS

105.EU445BEastWest SCBR No No 0.066 lb/ton BLS (daily avg, 

quarterly stack test) 20% (3 min in 60 min) 0.2 lb/ton BLS*

105.EU445D SCBR No No 0.066 lb/ton BLS (daily avg, 

quarterly stack test) 20% (3 min in 60 min) 0.2 lb/ton BLS*

107.09-P2 SCBR Yes No 0.03 lb/ton BLS 20% 0.199 lb/ton BLS*

108.SDT3 PBSCBR/INC_

RF Yes No 0.033 lb/ton BLS (12-hour) NA/INC_RF 0.12 lb/ton BLS*

109.SDT3 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.12 lb/ton BLS*

109.SDT4 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

111.G-127 SCBR/INC_RF Yes No 0.033 lb/ton BLS

20% (6-min avg) up to 87% 

for 1 6-min period per hour 

and no more than 4/24-hour

0.2 lb/ton BLS

112.AA-101a SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.12 lb/ton BLS*

114.U508 SCBR Yes No 0.0168 lb/ton BLS 40% (6-min avg) 0.2 lb/ton BLS

115.SM01 SCBR Yes No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

116.004 SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.2 lb/ton BLS

117.P30 SCBR No No pound per hour provided NA/SCBR 0.18 lb/ton BLS

119.EQT005 SCBR No Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

119.EQT011 SCBR Yes Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

120.M3 SCBR Yes Yes 0.0168 lb/ton BLS 40% 0.14 lb/ton BLS

121.000009 SCBR No No 0.033 lb/ton BLS 30% (6-min avg) 0.2 lb/ton BLS*
C-3

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

121.000010 SCBR No No 0.033 lb/ton BLS 30% (6-min avg) 0.2 lb/ton BLS*

124.020 SCBR No No 0.032 lb/ton BLS 20% 0.2 lb/ton BLS

124.021 SCBR No No 0.032 lb/ton BLS 20% 0.2 lb/ton BLS

126.SDT SCBR Yes No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

127.SDT1 SCBR Yes No 0.033 lb/ton BLS 20% (once/shift) 0.2 lb/ton BLS

130.6 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

130.7 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

130.11 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

131.SDT4N/4S SCBR No Yes 0.033 lb/ton BLS 20% up to 60% in 1 6-min 

period/hour 0.2 lb/ton BLS*

131.SDT5 SCBR Yes Yes 0.0168 lb/ton BLS 20% 0.2 lb/ton BLS*

132.4SDT SCBR Yes No 0.032 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

132.5SDT SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

133.12a SCBR No Yes no limit 35% 0.3 lb/ton BLS

133.12b SCBR No Yes no limit 35% 0.3 lb/ton BLS

135.007-1 SCBR No Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

135.007-2 SCBR No Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

136.EU 031 SCBR Yes No 0.0168 lb/ton BLS NA/SCBR 0.12 lb/ton BLS*

137.157 SCBR No No no limit NA/SCBR 0.2 lb/ton BLS

137.204 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

138.003 PBSCBR No No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

139.03 SCBR No No no limit 35%

0.2 lb/ton BLS (3-

hour) and 0.3 lb/ton 

BLS (1-hour)

140.57 PBSCBR No No 0.033 lb/ton BLS 20% (3 min in 60 min) 0.2 lb/ton BLS

142.P7236 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

142.P7413 SCBR No No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

143.7005 SCBR No No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS
C-4

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

143.7015 SCBR No No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

143.7025 SCBR No No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

145.56 OTH No No no limit 20% 0.2 lb/ton BLS

145.57 SCBR No No ppm limit provided 20% 0.2 lb/ton BLS

146.10 SCBR No No 0.033 lb/ton BLS (month) 20% up to 60% in 1 6-min 

period/hour 0.2 lb/ton BLS*

146.17 SCBR Yes No 0.0168 lb/ton BLS 10% (6-min avg) 0.15 lb/ton BLS 

(monthly)*

147.161 SCBR No No pound per hour provided 5% (6-min avg) 0.2 lb/ton BLS

147.243 SCBR Yes No pound per hour provided NA/SCBR 0.2 lb/ton BLS

147.244 SCBR Yes No pound per hour provided NA/SCBR 0.2 lb/ton BLS

148.002 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

148.008 SCBR Yes Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

149.P005 SCBR Yes No 0.0168 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

150.CREC-2a/2b SCBR Yes No 0.033 lb/ton BLS NA/SCBR

0.192 lb/ton BLS 

and 0.19 lb/ton 

BLS*

151.REC005/006 SCBR/STRIP Yes Yes 0.0168 lb/ton BLS 20% 0.2 lb/ton BLS

151.REC008 SCBR/STRIP No Yes 0.0336 lb/ton BLS 20% 0.2 lb/ton BLS

151.REC009 SCBR/STRIP No Yes 0.0336 lb/ton BLS 20% 0.2 lb/ton BLS

152.04 SCBR No Yes no limit 40% 0.2 lb/ton BLS

153.EQT 0066 SCBR No No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

154.P32 SCBR No Yes no limit NA/SCBR 0.46 lb/ton BLS

154.P35 SCBR No Yes no limit NA/SCBR 0.46 lb/ton BLS

154.P38 PBSCBR Yes Yes 0.0168 lb/ton BLS 20% 0.12 lb/ton BLS

155.SDT PBSCBR Yes No 0.0168 lb/ton BLS (12-hour) NA/SCBR 0.2 lb/ton BLS

156.SMEL18 PBSCBR No No ton per year provided 20% 0.12 lb/ton BLS (1-

hour)*

156.SMEL19 PBSCBR No No ton per year provided 20% 0.12 lb/ton BLS (1-
C-5

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

hour)*

156.SMEL22 PBSCBR Yes No 0.0168 lb/ton BLS (24-hour) 20% 0.12 lb/ton BLS (1-

hour)*

157.SDT OTH No No 0.033 lb/ton BLS NA 0.2 lb/ton BLS

159.

PW04 SCBR No No 0.0168 lb/ton BLS 40% 0.2 lb/ton BLS

162.381C SCBR Yes Yes 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

162.382B SCBR Yes Yes 0.0168 lbs/ton BLS 20% 0.2 lb/ton BLS

163.SD1902 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.25 lb/ton BLS

163.SD1903 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.25 lb/ton BLS

163.SD2906 SCBR Yes Yes 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.19 lb/ton BLS

164.P08 SCBR No Yes no limit 20% 0.246 lb/ton BLS

164.P10 SCBR No Yes no limit 20% 0.246 lb/ton BLS

165.000008 SCBR Yes Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS*

165.000014 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS*

166.ST01 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

166.ST02 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

167.007SDT SCBR No Yes 0.0266 lb/ton BLS 40% 0.364 lb/ton BLS

169.06 PBSCBR Yes No 0.019 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

169.07 PBSCBR Yes No 0.019 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

171.006 OTH No Yes 0.033 lb/ton BLS (12-hour) 40% 0.2 lb/ton BLS*

171.007 SCBR No Yes 0.033 lb/ton BLS 40% 0.2 lb/ton BLS*

171.008 SCBR No Yes 0.033 lb/ton BLS 40% 0.2 lb/ton BLS*

172.ST01 SCBR No Yes 0.033 lb/ton BLS (12-hour) 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.2 lb/ton BLS
C-6

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

172.ST02 SCBR Yes Yes 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.2 lb/ton BLS

173.SDT SCBR No Yes no limit NA/SCBR 0.2 lb/ton BLS

174.G-63B SCBR No Yes 0.032 lb/ton BLS 20% 0.2 lb/ton BLS

174.G-63C SCBR Yes Yes 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

175.ST2A SCBR No Yes 0.0168 lb/ton BLS 40% (6-min avg) 0.585 lb/ton BLS

175.ST3A SCBR Yes Yes 0.0168 lb/ton BLS 40% (6-min avg) 0.2 lb/ton BLS

176.G-37 SCBR No Yes 0.032 lb/ton BLS 20% 0.2 lb/ton BLS

177.EU0805 SCBR Yes No 0.031 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

178.08T014 SCBR No No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

178.08T015 SCBR No No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

179.SDT SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) up to 40% 

for 1 6-min average per hour 0.12 lb/ton BLS

180.D002 SCBR Yes Yes 0.0168 lb/ton BLS NA/SCBR 0.12 lb/ton BLS

181.11 SCBR No No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

181.51 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

182.110 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

183.003 SCBR No No 0.0168 lb/ton BLS NA/SCBR 0.12 lb/ton BLS*

184.SDT1 SCBR No No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

184.SDT2a SCBR No No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

184.SDT2b SCBR No No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

185.05 PBSCBR No Yes 0.0168 lb/ton BLS 20% (6-min avg) 0.12 lb/ton BLS*

186.RB17 SCBR Yes No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS

188.015SD1 SCBR No Yes 0.033 lb/ton BLS (24-hour) 20% (3 min in 60 min) 0.23 lb/ton BLS*

188.017SD2 SCBR No Yes 0.033 lb/ton BLS (24-hour) 20% (3 min in 60 min) 0.26 lb/ton BLS*

189.SN27 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

189.SN28 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

190.R404 SCBR Yes Yes 0.0168 lb/ton BLS 40% 0.12 lb/ton BLS
C-7

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

190.R405 SCBR Yes Yes 0.0168 lb/ton BLS 40% 0.2 lb/ton BLS

190.R406 SCBR No Yes 0.0168 lb/ton BLS 40% 0.53 lb/ton BLS

195.007 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.127 lb/ton BLS*

196.SN-08North/South SCBR Yes No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS*

196.SN-15 SCBR Yes No 0.033 lb/ton BLS 20% 0.2 lb/ton BLS*

197.4 SCBR No No 0.035 lb/ton BLS (12-hour) 20% 0.2 lb/ton BLS*

198.020 SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) 0.12 lb/ton BLS

199.004 SCBR No No 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

200.007_8 SCBR No No 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

200.007_9 SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS*

201.SR0034 SCBR No No 0.033 lb/ton BLS (12-hour) 20% (6-min avg) 0.2 lb/ton BLS

202.Smelt Dissolving 

Tank EU322 SCBR Yes Yes 0.033 lb/ton BLS 20% 0.12 lb/ton BLS*

203.2DTScr SCBR Yes No 0.033 lb/ton BLS 35% 0.2 lb/ton BLS

203.3DTScr SCBR No No no limit 35% 0.2 lb/ton BLS

205.010 SCBR No No 0.033 lb/ton BLS 20% (6-min avg) 0.2 lb/ton BLS

206.G-35 OTH No Yes 0.032 lb/ton BLS

40% (6-min avg) except for 1 

6-min /hr and no more than 

4/24 hr

0.2 lb/ton BLS

206.G-36 OTH No Yes 0.032 lb/ton BLS

20% (6-min avg) except for 1 

6-min /hr and no more than 

4/24 hr

0.2 lb/ton BLS

207.108 PBSCBR Yes Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

226.SDT1N SCBR No No 0.033 lb/ton BLS (12-hour) NA/SCBR 0.2 lb/ton BLS

226.SDT2 SCBR Yes No 0.033 lb/ton BLS (12-hour) NA/SCBR 0.2 lb/ton BLS

240.RF02 SCBR No No 0.0168 lb/ton BLS 40% (6-min avg) 0.2 lb/ton BLS

240.RF05 SCBR Yes No 0.0168 lb/ton BLS 40% (6-min avg) 0.2 lb/ton BLS

240.RF06 SCBR Yes No 0.0168 lb/ton BLS 40% (6-min avg) 0.2 lb/ton BLS

242.AA-012 SCBR Yes No 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*
C-8

RTI&EUID APCD Type Subject to 

BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

243.R403 SCBR No No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

243.R408 SCBR Yes No 0.0168 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

340.007 SCBR No Yes 0.033 lb/ton BLS (12-hour) 20% 0.2 lb/ton BLS*

525.EU19North SCBR No No 0.033 lb/ton BLS NA/SCBR 0.12 lb/ton BLS

531.RF10 SCBR Yes No 0.0168 lb/ton BLS 40% (6-min avg) 0.15 lb/ton BLS

600.G0805 SCBR Yes Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

600.G0807 SCBR Yes Yes 0.033 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

606.SDT2 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

606.SDT3 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

606.SDT4 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS

610.9 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.31 lb/ton BLS*

610.10 SCBR No Yes 0.033 lb/ton BLS 20% (6-min avg) 0.13 lb/ton BLS*

613.005 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

613.006 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

613.007 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

613.008 SCBR No No 0.032 lb/ton BLS NA/SCBR 0.2 lb/ton BLS*

615.25 SCBR Yes No 0.033 lb/ton BLS (24-hour) 20% 0.2 lb/ton BLS*

617.P21 PBSCBR Yes No 0.0168 lb/ton BLS 20% (test) 0.13 lb/ton BLS

208228535.002 SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) 0.12 lb/ton BLS

208228535.008 SCBR Yes No 0.033 lb/ton BLS 20% (6-min avg) 0.12 lb/ton BLS

*PM/PM10 limit
D-1

APPENDIX D: Lime Kiln Permit Limits
D-2

Table D-1: Representative Permit Limits for Lime Kilns

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

100.115 ESP Yes No 8 ppm 20% (6-min avg) 0.016 gr/dscf

102.LK ESP Yes No

20 ppm (24-hour) 

with max 80 ppm 

for 2 hours

20% (6-min avg) not to 

exceed 25% in any 6-min 

period

0.03 gr/dscf*

103.G-165 SCBR Yes Yes 8 ppm

20% opacity (6-min avg) 

can be exceeded for 1 6-

min avg/hour up to 87%

0.13 gr/dscf

104.EUG E7 ESP Yes No

8 ppm when used as 

LVHC control, 40 

ppm other

20% (6-min avg) 0.064 gr/dscf*

105.EU455 ESP No No 20 ppm (24-hour)

20% (3-min avg), can not 

exceed more than 3-min per 

60 min period

0.064 gr/dscf*

107.11-P14 ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf*

108.LK1 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf*

109.LK1 ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf*

111.G-35 ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

112.AA-110 ESP Yes No 8 ppm 20% (6-min avg) 0.033 gr/dscf*

114.U800 ESP Yes No 8 ppm 20% (6-min avg) 0.01 gr/dscf

115.LK01 ESP Yes No No limit 20% (6-min avg) 0.064 gr/dscf

116.001 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

117.P36 SCBR No No no limit 20% 0.064 gr/dscf

119.EQT006 SCBR No Yes 20 ppm 20% (6-min avg) 0.24 gr/dscf*

120.M18 SCBR Yes Yes 8 ppm 40% 0.067 gr/dscf (NG), 0.106 

gr/dscf (fuel oil)
D-3

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

120.M19 SCBR No Yes 40 ppm (24-hour) 40% 0.067 gr/dscf (NG), 0.106 

gr/dscf (fuel oil)

121.000011 SCBR No No 20 ppm (12-hour), 

50 ppm (1-hour) 30% (6-min avg) 0.064 gr/dscf*

124.004-1 MC/SCBR Yes No 20 ppm 20% 0.064 gr/dscf

126.LK ESP/SCBR No No 20 ppm

20% (6-min avg) not to 

exceed 60% in any 6-min 

period

0.064 gr/dscf

127.LK1 ESP No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

127.LK2 ESP No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

130.4 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf

130.5 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf

131.16 CYC/SCBR No Yes No limit N/A (SCBR) 0.064 gr/dscf (NG), 0.2 

gr/dscf (fuel oil)

131.18 SCBR Yes Yes 8 ppm N/A (SCBR) 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

132.21LK4 ESP Yes No 8 ppm 20% (24-hour) 0.064 gr/dscf

133.14 SCBR No Yes 20 ppm (24-hour) 

and 80 ppm (2-hour) 35% 0.13 gr/dscf

133.15 SCBR No Yes 20 ppm (24-hour) 

and 80 ppm (2-hour) 35% 0.13 gr/dscf

135.004-1 CYC/SCBR No Yes 20 ppm N/A (SCBR) 0.064 gr/dscf

136.EU 033 ESP Yes No 8 ppm

20% (6-min avg) not to 

exceed 27% for more than 

one 6-min avg per hour)

0.035 gr/dscf*
D-4

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

137.511 ESP No No 40 ppm

20% (average of 10 

consecutive 6-min avgs), 

may exceed 25% for no 

more than one 3-min 

period/hr

0.064 gr/dscf*

137.512 ESP/PBSCBR No No 50 ppm

20% (average of 10 

consecutive 6-min avgs), 

may exceed 20% for no 

more than one 3-min 

period/hr

0.064 gr/dscf*

138.001 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf*

139.04 SCBR No No

8 ppm (12 hour) and 

80 ppm (2 hour 

max)

35% 0.064 gr/dscf

140.32 SCBR No No 20 ppm (24-hour) N/A (SCBR) 0.064 gr/dscf

142.P6009 SCBR No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

142.P6025 SCBR No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

143.6063 ESP Yes No 8 ppm

20% (6-min avg) except for 

1 6-min avg per hour, not to 

exceed 40%

0.064 gr/dscf*

145.001 SCBR No No No limit N/A (SCBR) 0.064 gr/dscf*

146.6 SCBR Yes No 8 ppm N/A (SCBR) 0.064 gr/dscf*

146.30 ESP/SCBR No No 8 ppm

20% (6-min avg) except for 

1 6-min avg per hour, not to 

exceed 30%

0.02 gr/dscf (3-hour), 0.015 

gr/dscf (annual) and 0.018 

gr/dscf (3-hour)*, and 

0.013 gr/dscf (annual)*

147.3 SCBR Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

147.55 CYC/ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

148.003 SCBR No Yes 20 ppm 20% (6-min avg) 0.192 gr/dscf
D-5

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

148.009 ESP Yes Yes 8 ppm 20% (6-min avg) 0.035 gr/dscf (NG), 0.064 

gr/dscf (fuel oil)

149.P001 CYC/SCBR No No 40 ppm 20% (6-min avg) 0.064 gr/dscf

150.CAU-12 SCBR Yes No 8 ppm N/A (SCBR) 0.064 gr/dscf

151.CP001 SCBR Yes Yes 8 ppm 20% (6-min avg) 0.064 gr/dscf

151.CP002 ESP Yes Yes 8 ppm 20% (6-min avg) 0.0125 gr/dscf

152.08 SCBR No Yes No limit 40% 0.064 gr/dscf

153.EQT 0053 SCBR Yes No 20 ppm 20% 0.064 gr/dscf

154.P30 ESP/SCBR Yes Yes 8 ppm

20% (6-min avg) not to 

exceed 80% in any 6-min 

period

0.04 gr/dscf (NG), 0.064 

gr/dscf (fuel oil)

155.LIME 

KILN SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

156.143100 SCBR Yes No 20 ppm (24-hour) 80 

ppm (2-hour) 25% 0.03 gr/dscf*

156.145000 SCBR Yes No 20 ppm (24-hour) 80 

ppm (2-hour) 25% 0.03 gr/dscf*

156.LK5 ESP Yes No 8 ppm 25% (6-min avg) 0.035 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

157.KILN SCBR No No 20 ppm N/A (SCBR) 0.13 gr/dscf

159.F4 SCBR No No 40 ppm (24-hour) 40% 0.064 gr/dscf

162.371A SCBR Yes Yes 8 ppm 20% 0.13 gr/dscf

162.372A ESP Yes Yes 8 ppm 20% (6-min avg) 0.1 gr/dscf

163.LK1501 SCBR No Yes 20 ppm

20% (6-min avg) not to 

exceed 40% in 1- 6-min 

period/hr

0.067 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)
D-6

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

163.LK2502 SCBR Yes Yes 8 ppm

20% (6-min avg) not to 

exceed 40% in 1- 6-min 

period/hr

0.067 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

164.P12 SCBR Yes Yes 8 ppm 20% 0.067 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

165.000002 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf*

165.000019 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf*

166.LK01 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf*

166.LK02 SCBR Yes Yes 8 ppm 20% (6-min avg) 0.13 gr/dscf*

167.004LK SCBR No Yes 20 ppm 40% 0.064 gr/dscf*

169.03 SCBR Yes No 8 ppm N/A (SCBR) 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

171.009 SCBR No Yes 40 ppm 40% 0.064 gr/dscf*

171.010 SCBR No Yes 40 ppm 40% 0.064 gr/dscf*

172.LK03 SCBR Yes Yes 8 ppm

20% (6-min avg) not to 

exceed 40% in 1- 6-min 

period/hr

0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

173.LK1 SCBR No Yes 7 ppm N/A (SCBR) 0.15 gr/dscf

174.G-18 ESP/SCBR Yes Yes 8 ppm 20% (6-min avg) 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

174.G-95 CYC/SCBR No Yes 20 ppm 20% 0.064 gr/dscf

175.LK1A SCBR No Yes 40 ppm (24-hour) 40% (6-min avg) 0.176 gr/dscf

175.LK2A SCBR Yes Yes 8 ppm 40% (6-min avg) 0.064 gr/dscf

176.G-5 SCBR No Yes 20 ppm 40% 0.064 gr/dscf

177.EU0905 SCBR No No 7.5 ppm (24-hour) 

and 10 ppm (1-hour) N/A (SCBR) 0.064 gr/dscf

178.09P037 ESP/SCBR No No 8 ppm 20% (6-min avg) 0.03 gr/dscf
D-7

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

179.LK3 ESP Yes No 8 ppm

20% (6-min avg) not to 

exceed 40% in any 6-min 

period

0.035 gr/dscf (NG), 0.064 

(fuel oil)

180.L001 SCBR Yes Yes 8 ppm 40% 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

180.L002 SCBR Yes Yes 8 ppm 40% 0.064 gr/dscf (NG), 0.13 

gr/dscf (fuel oil)

181.01 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

181.14 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

183.004 SCBR No No 20 ppm N/A (SCBR) 0.13 gr/dscf*

184.LK1 SCBR Yes No 8 ppm 20% 0.064 gr/dscf

184.LK2 ESP/SCBR Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

185.07 SCBR Yes Yes

8 ppm (12 hour) and 

80 ppm (2 hour 

max)

35% (not to exceed for 

more than 6 min in any 60 

min period)

0.067 gr/dscf (NG)*, 0.13 

gr/dscf (fuel oil)*

186.LK ESP/SCBR Yes No 8 ppm 20% (6-min avg) 0.065 gr/dscf

188.001LK1 SCBR No Yes 20 ppm (24-hour) 20% (parameter 

monitoring) 0.12 gr/dscf*

188.002LK2 SCBR No Yes 20 ppm (24-hour) 20% (parameter 

monitoring) 0.12 gr/dscf*

188.003LK3 SCBR No Yes 20 ppm (24-hour)

20% (not to exceed for 

more than 3 min in any 60 

min period)

0.12 gr/dscf*

189.SN25 SCBR Yes No 8 ppm N/A (SCBR) 0.064 gr/dscf*

190.L600 SCBR No Yes 40 ppm (24-hour) 40% 0.064 gr/dscf

190.L601 SCBR No Yes 40 ppm (24-hour) 40% 0.056 gr/dscf

195.002 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf*

196.SN-02 SCBR Yes No 8 ppm 20% 0.034 gr/dscf*

196.SN-09 ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf*
D-8

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

197.1 SCBR No No 40 ppm 20% 0.064 gr/dscf*

198.004 SCBR Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

199.011 SCBR No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

200.007_10 ESP Yes No 8 ppm 20% (6-min avg) 0.03 gr/dscf*

201.SR0003 SCBR No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

202.Lime Kiln 

EU340 CYC/SCBR Yes Yes 8 ppm 20% (6-min avg) 0.066 gr/dscf*

203.LKScr SCBR Yes No

8 ppm (12 hour) and 

80 ppm (2 hour 

max)

35% 0.064 gr/dscf

205.008 SCBR No No 20 ppm 20% (6-min avg) 0.064 gr/dscf

206.G-37 SCBR No Yes 5 ppm

40% (6-min avg), can 

exceed for 1 6-min period 

per hour with no more than 

4/24 hour (no upper limit)

0.1 gr/dscf

206.G-38 SCBR No Yes 5 ppm

40% (6-min avg), can 

exceed for 1 6-min period 

per hour with no more than 

4/24 hour (no upper limit)

0.1 gr/dscf

207.103A SCBR Yes Yes 20 ppm N/A (SCBR) 0.066 gr/dscf

226.LK1 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

226.LK2 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf

240.CA81 ESP Yes No 8 ppm 40% (6-min avg) 0.064 gr/dscf

242.AA-013 ESP/SCBR Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf*

243.LG07 ESP/SCBR Yes No 8 ppm

20% (6-min avg) not to 

exceed 40% in 1- 6-min 

period/hr

0.01 gr/dscf

340.008 SCBR No Yes 40 ppm 20% 0.064 gr/dscf*
D-9

RTI + 

Emission Unit 

ID

APCD Type Subject 

to BB

PM 

Bubble TRS Limit Opacity Limit PM Limit

525.EU17 SCBR No No tons per year 

provided N/A (SCBR) 0.064 gr/dscf

531.LK7 ESP Yes No 8 ppm

20% (6-min avg) not to 

exceed 40% in any 6-min 

period

0.064 gr/dscf

600.G0903 SCBR No Yes 20 ppm N/A (SCBR) 0.064 gr/dscf

600.G0905 SCBR Yes Yes 8 ppm N/A (SCBR) 0.067 gr/dscf

600.G0908 SCBR Yes Yes 8 ppm N/A (SCBR) 0.035 gr/dscf

606.LK4 ESP Yes No 7 ppm 20% (6-min avg) 0.0451 gr/dscf

610.7 SCBR No Yes 20 ppm 20% (6-min avg) 0.13 gr/dscf*

610.8 SCBR No Yes 20 ppm 20% (6-min avg) 0.064 gr/dscf*

613.009 SCBR No No 20 ppm N/A (SCBR) 0.064 gr/dscf*

615.21 SCBR No No 20 ppm (24-hour) 20% 0.2 gr/dscf (24-hour)*

617.P22 ESP Yes No 8 ppm 20% (6-min avg) 0.05 gr/dscf

208228535.003 SCBR Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

208228535.009 ESP Yes No 8 ppm 20% (6-min avg) 0.064 gr/dscf

*PM/PM10 limit
E-1

APPENDIX E: NCG Source Permit Limits
E-2

Table E-1 Representative Permit Limits for TRS from NCG Sources

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

100

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

102

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

103

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB Diffusion washer exemption

104

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Incinerating BSW gases not 

feasible

105 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB Utilizes CCA / Not subject to BB

107

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

108

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB Utilizes CCA / Not subject to BB

109

Reduce emissions using 

thermal oxidizer operating at 

greater than 1600oF and a 

residence time of greater than 

0.75 seconds

Reduce emissions using thermal 

oxidizer operating at greater than 

1600o

F and a residence time of 

greater than 0.75 seconds

Reduce emissions using thermal 

oxidizer operating at greater than 

1600oF and a residence time of 

greater than 0.75 seconds

Reduce emissions using thermal 

oxidizer operating at greater than 

1600oF and a residence time of 

greater than 0.75 seconds

111

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

112

Reduce emissions using 

thermal oxidizer

5 ppm @ 10% O2 (combustion 

control)

5 ppm @ 10% O2 (combustion 

control)

Combust gases at 1200o

F for at 

least 0.5 sec

114

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB
E-3

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

115

Combust gases at 1200oF for 

at least 0.5 sec

8 ppm @ 10% O2 (combustion 

control-lime kiln)

8 ppm @ 10% O2 (combustion 

control - lime kilns)

Combust gases in lime kiln or 

recovery furnace subject to BB

116

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

117 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

119 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

120

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

121 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

124

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

126 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

127

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

131 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

130 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

132 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

5 ppm, uncorrected for O2 

(control other than combustion)
E-4

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

133 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases in recovery 

furnace or lime kiln subject to BB

135

5 ppm @ 10% O2 

(combustion control)

Combust gases at 1200oF for at 

least 0.5 sec

5 ppm @ 10% O2 (combustion 

control)

Combust gases at 1200oF for at 

least 0.5 sec

136

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

137 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases in recovery 

furnace or lime kiln subject to BB

138 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

139 N/A

5 ppm @ 10% O2 (combustion 

control)

5 ppm @ 10% O2 (combustion 

control)

5 ppm @ 10% O2 (combustion 

control)

140 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to BB Utilizes CCA / Not subject to BB

142 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

143

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

145

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

146

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

147 N/A

5 ppm @ 10% O2 (combustion 

control)

Combust gases at 1200o

F for at 

least 0.5 sec Incineration not feasible
E-5

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

148

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Reduce emissions using thermal 

oxidizer operating at greater than 

1600oF and a residence time of 

greater than 0.75 seconds

Combust gases in lime kiln or 

recovery furnace subject to BB

149 Use thermal oxidizer Use thermal oxidizer

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

150

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

151

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

152 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gas at 1500oF for at least 

0.5 sec

153 N/A not surveyed not surveyed not surveyed

154

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gas at 1500oF for at least 

0.5 sec

155

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB

156

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

157 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to BB

Utilizes scrubber/Not subject to 

BB

159

Combust gases in lime kiln or 

recovery furnace subject to

BB

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to BB Utilizes CCA / Not subject to BB
E-6

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

162

Route gases to rectifier 

system, followed by 

combustion at 1450o

F for 0.15 

sec

Combust gases at 1200oF for at 

least 0.5 sec

Route gases to rectifier system, 

followed by combustion at 

1450oF for 0.15 sec

Combust gases at 1200oF for at 

least 0.5 sec

163

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

164 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

165 N/A

Combust gases at 1200oF for at

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

166

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Equivalency by permit / Not 

subject to BB

167 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

169

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

171 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

172 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB Incineration not feasible

173 N/A

Combust gases at 1200oF for at

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

174

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

175 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Equivalency by permit / Not 

subject to BB
E-7

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

176

5 ppm @ 10% O2 

(combustion control)

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

177

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

178

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Diffusion washer exemption

179 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

180

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB Incineration not feasible

181 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

182 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in recovery 

furnace or lime kiln subject to BB

183 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in recovery 

furnace or lime kiln subject to BB

184 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

185

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

186 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

5 ppm uncorrected for O2 (control 

other than combustion) [scrubber]

188 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB Utilizes CCA / Not subject to BB
E-8

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

189 Use thermal oxidizer

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

190

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

195

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

196

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB Utilizes CCA / Not subject to BB

197 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

198

Combust gases in lime kiln or 

recovery furnace subject to 

BB

5 ppm @ 10% O2 (combustion 

control)

Combust gases at 1200oF for at 

least 0.5 sec

5 ppm @ 10% O2 (combustion 

control)

199

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases in lime kiln or 

recovery furnace subject to BB

Wash system designed such that 

vacuum pump exhaust not 

required to be collected

200

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

201

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

202 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

203 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

205 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec
E-9

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

206

Combust gases in lime kiln or 

recovery furnace subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Equivalency by permit / Not 

subject to BB

207 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

226

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

240

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

242

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

5 ppm, uncorrected for O2

(control other than combustion)

243 Use thermal oxidizer Use thermal oxidizer Use thermal oxidizer

Combust gases in lime kiln or 

recovery furnace subject to BB

340 N/A

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

525 Use thermal oxidizer Use thermal oxidizer Use thermal oxidizer

Combust gases at 1200oF for at 

least 0.5 sec

531

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

600

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

606 N/A

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

610 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in recovery 

furnace or lime kiln subject to BB Utilizes CCA / Not subject to BB
E-10

RTI 

Facility ID Condensate Strippers Digesters Evaporators Brown Stock Washers

613

Combust gases at 1200oF for 

at least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec Utilizes CCA / Not subject to BB

615 N/A

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases in lime kiln or 

recovery furnace subject to BB

617

Combust gases at 1200o

F for 

at least 0.5 sec

Combust gases in recovery 

furnace or lime kiln subject to 

BB

Combust gases in lime kiln or 

recovery furnace subject to BB

Combust gases at 1200oF for at 

least 0.5 sec

208228535 N/A

Combust gases at 1200o

F for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec

Combust gases at 1200oF for at 

least 0.5 sec
F-1

APPENDIX F: Incinerator Permits 
F-2

Table F-1: Representative Permit Operating Parameters for Incinerators

RTI 

ID

No. of 

Incinerators

Burns 

NCGs

Burns 

SOGs

Temperature 

Averaging Time

Monitor recording 

frequency

Report Below 

Minimum 

Temperature

Minimum Temperature 

(

o

F)

100 1 Yes Yes None Continuous – 15 min 5 minutes 1500

107 1 Yes Yes None Continuous – shift 5 minutes 1300

109 1 Yes Yes 24 hours Continuous – shift 5 minutes 1200

116 1 Yes No 3 hour rolling Continuous 5 minutes 1200

137 1 Yes No None Continuous 5 minutes 1200

146 3 Yes Yes None Continuous 5 minutes 1479

149 1 Yes No 1 hour/15 min Continuous 5 minutes

155 1 Yes Yes 5 minutes Continuous 5 minutes 1360

162 1 Yes Yes None Continuous – 15 min 5 minutes 1450

165 1 Yes No 5 minutes Continuous – 1 min 5 minutes 1350

166 1 Yes Yes None Continuous – shift 5 minutes 1200

172 Standby Yes No Unspecified Unspecified Unspecified Unspecified

186 Standby Yes No Unspecified Unspecified Unspecified Unspecified

190 1 Yes Yes 3 hour block Continuous 5 minutes 1244

198 1 Backup Yes None Continuous 5 minutes 1473

207 1 Yes No Continuous 5 minutes 1200

226 1 Yes Yes None Continuous 5 minutes

240 1 Yes Yes 3 hour block Continuous 5 minutes 1250

243 2 Yes Yes 3 hour block Continuous 5 minutes 1355

610 1 Yes No Continuous NA (non-BB HVLC 

gas)