# Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 international Parkway Suite 120 Atlanta Georgia 30354 

### 4041363-7000 Fax:

### 4041363-7100 Chris Clark, Commissioner

F. Allen Barnes, Director 

### November 19,201 0
Mr. Dick Schutt Chief, Air Planning Branch Air, Pesticides & 

### Toxics Management Division U.S. EPA, Region

### N 61 Forsyth Street, SW Atlanta, Georgia 30303-8909 Re: Permit Amendments Supporting Georgia's SIP for Regional Haze Dear Mr. Schutt: With this letter, the Georgia Environmental Protection Division (EPD) isproviding supplemental informationto Georgia's StateImplementation Plan (SIP )for Regional Haze, which was submitted to EPA Region IV on February 11,2010. At the time ofsubmittal, TitleV permit amendments were pending to support emissions reductions stipulated in the 

### SIP. The pending amendments were for three facilities : 

### Georgia-Pacific,Brunsick Cellulose International Paper, Savannah (permit renewal) Interstate Paper Requirements for these facilities were stipulated inboth thenarrative and Appendix 

### M of the SIP As of September 20,2010,permit amendments that include the appropriate conditions for visibility improvement had been issued for all ofthe facilities. Thistransmittal includes electronic and paper copies ofthe relevantpermits in their entirety. Someofthepermits contain conditions that address programs other than Regional Haze, soatable is attached that lists onlythe permit conditions that are relevant to Regional Haze. Onlythose conditions identified in the attached table are relevent to Georiga's Regional Haze SIP submittal and are being submital for incorporation into the previously submitted SIP. Final conditions are also attached for Georgia-Pacific's Cedar Springs Operation and are also included in the attached table. The conditions for Cedar Springs that were included with the SIP submittal were draft conditions, and these were revised in the course of thepublic notice and EPA review processes. Note that all ofthe permit renewals and amendments were prepared in accordance with Title

### V ofthe Clean Air Act and Georgia Rule 391-3-6-1 -.O3(lO), which incorporates the requirements of40 CFR Part 70. These requirements address permit applications, public participation, and reviewby EPA. The final permits/amendments are posted on the Georgia Department ofNatural Resources web at http://airpermit.dnr.state.ga.

### us/~aail~ermits/. Thepermit conditions reflect, in somecases, changed language dueto the permit application process andlor comment and review by the public and EPA. The language does not match word-for-word the language ofthe proposed conditions submitted with Appendix 

### M onFebruary 11,2010. However, these

### Mr. Dick Schutt (continued) conditions retain the samerestrictions. The attached permits are finaland 

### federally enforceable and therefore supersede those proposed conditionsfound in Appendix 

### M ofthe 

### SIP. Ifyou have further questions about this letter, contact me by

### phone at 404-363-7014

### orby 

### e-mail at jimmy.johnston@dnr.state.ga.us. 

### Sincerely,
Program Manager Planning and Support Program

c:MichelleNotariami, EPAUpdated11-4-2010Permit Amendments Supporting Georgia's RegionalHazeSIPGAPacificBrunswickCelluloseAIRSl27OOOO3GA PacificCedarSpringsAIRS09900001InterstatePaperAIRSl79OOOO1Internat. Paper-SavannahAlRS5IOOOO7Power BoilerNo. 4Power BoilerNos. 1and 2,Rec. Boiler 3Power BoilerPWO1Power Boiler13Permit amendment 263 1-127-0003-V-05-1502(b)(10)changeIssued3-26-20 10Effective3-26-10Permit amendment 263 1-099-0001-V-02-6Significant ModificationIssued 7-23-09Effective 7-23-09Permit amendment 263 1-179-000 1-v-02-1502(b)(10)changeIssued 9-20-10Effective9-20-10Pennitamendment 263 1-051-0007-v-02-0RenewalIssued4-20-2010Effective4-20-10Conditions-Emissionsloperatilrglimits.Conditions-Testing,Recordkeepingand-----Rcporting?lOther------FRegional HazeSIPConditions3.2.29and6.2.393.2.6(c),3.2.19(a)4.2,26,4.2.27,5.2.l(c),5.2.2(d),5.2.19,5.2.21,5.2.29,6.1.7(a)(xv)and(xvi),6.2.47, 7.12,7.14.16.1.7(b)(xxx)and(xxxi),6.2.42, 6.2.43

# State 

# ofGeorgia Department 

## of Natural Resources Environmental Protection Division Air Protection Branch 

# 502(b)(10) Permit for Part 

# 70 Source

Facility Name: 

### Brunswick Cellulose, Inc. 1400West Ninth Street Brunswick, Georgia 31521, Glynn County MailingAddress: P.O. 

### Box 1438 Brunswick, Georgia 31521 ParenffHolding 

### GP Cellulose, LLC Company: Facility AIRS Number: 04-1 3-1 27-00003 In accordance with the provisions of the Georgia Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the Georgia Rules for Air Quality Control, Chapter 391-3-1, adopted pursuant to or in effect under the Act, the Permittee described above is issued a SIP Constructionand Operattng Permitfor: The addition of SO2conditionsfor the Regional Haze Rule This modification qualifies as a Section 502(b)(IO) change to the Part 70 source in accordance with Georgia Air Quality Control Rule 391 -3-1-.03(1O)(b)(5). This Permit is conditioned upon compliance with all provisions of The Georgia Air Quality Act, O.C.G.A. Section 12- 9-1, et seq, the Rules, Chapter 391-3-1, adopted or in effect under that Act, or any other condition of this Permit and Permit No. 2631-127-0003-V-05-0. Unless modified or revoked, this Permit expires upon issuance of the next Part 70 Permitfor this source. This Permit may be subject to revocation, suspension, modification or amendment by the Director for cause including evidence of noncompliance with any of the above; or for any misrepresentation made in Application No. W-19281 dated March 5.2010; any other applications upon which this Permit or Permit No. 2631-127-0003-V-05-0 are based; supporting data entered therein or attached thereto; or any subsequent submittal or supporting data; or for any alterations affecting the emissions from this source. This Permit is further subject to and conditioned upon the terms, conditions, limitations, standards, or schedules contained in or specifiedon the attached3 page(s).

Environmental Protection Division502(b)(10) PERMIT FOR PART 70 SOURCE Brunswick Cellulose, Inc. Permit No.: 2631-127-0003-V-05-1 

### Table of Contents PART 

### 1.0 1.3 

### PART 3.0 3.1.1 3.2 

### PART 6.0 6.2 

### FACILITY DESCRIPTION

### .............................................................................................a...m. I Process Description ofModification


### ................................................................................................... 1 REQUIREMENTS FOR EMISSION UNITS

# ......................................................................... 2 

### Emission Units


### .................................................................................................................................. 2 Equipment Emission Caps and Operating Limits


### ................................................................................ 2 OTHER RECORD KEEPINGAND REPORTING REQUIREMENTS

# ..................................3 2 

### Specific Record Keeping and Reporting Requirements


### ................................................. . .. 

### . . .

### ......502(b)(10)PERMITFOR PART 70 SOURCE BrunswickCellulose,Inc. Permit No.: 2631-127-0003-V-05-1 

### PART 1.0 

### FACILITY DESCRIPTION 1.3 Process Description of Modification
The amendment is for the addition of SO2 

### conditions for the purpose of complying with the Regional Haze Rule.

Page 1 of 3502(b)(10)PERMITFOR PART70 SOURCE

. .. - Brunswick Cellulose, Inc. PermitNo.:2631-127-0003-V-05-1 

### PART3.0 

### REQUIREMENTSFOR EMISSIONUNITS Note: Except where an applicable requirement specifically states otherwise, the averaging times of any of the Emissions Limitations or Standards included in this permit are tied to or based on the run time(s) specified for the applicable reference test method(s) or procedures required for demonstrating compliance. 

### 3.1.1 

### Emission Units

40 CFR 61 SubpartE 391-3-1-.02(2)(b) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g) 3.2.29,3.3.7,3.3.33, 3.3.34,3.4.8,3.4.9, 3.4.10,4.2.1,4.2.2, 5.2.1,5.2.2,5.2.3, 5.2.20,5.2.14,6.1.7, 6.2.4,6.2.5,6.2.7 through 6.2.11. 6.2.39, 

## I 1 6.2.40 

### * Generally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable

requirements/standardsand correspondingpermit conditions are intended asacompliancetool and may not be definitive. Air PollutionControl Devices EmissionUnits



### 3.2 

### EquipmentEmission Caps and Operating Limits ID UEP4 Specific Limifatian~equirtmenb IDNo. U700



### 3.2.29 Effective January 1,201 

### 2, the Permittee shall not discharge, or cause the discharge, into the atmosphere from Power Boiler #4 

### (Source Code U700) sulkdioxide (SOz)emissions in excess of 568 tons during any twelve-consecutive month period. The first compliance period shallbe January through December, 2012. [40 

### CFR 51.308-

### Regional Haze] Dmcription power~oiler#4 ESP Applicsble ~equircmentslStnnditrds 40 CFR 52.21 Dtscription Poweroiler#4

Page 2 of3 Corr~ponding Permit Conditions - - 3.2.1through 3.2.6,502(b)(10)PERMITFORPART70 SOURCE Brunswick Cellulose,Inc. PermitNo.: 263 1-127-0003-V-05-1 

### PART 6.0 OTHER RECORD KEEPING AND REPORTING REQUIREMENTS 6.2 Specific Record Keeping and Reporting Requirements 6.2.39 The Permittee shall submit a plan for complying with the emission limits of Condition 3.2.29, including all required permit applications required under Georgia Air Quality Control Rules 391-3-1-.03 for any physical or operational changes required to meet the emissionlimit of Condition 3.2.29, onorbefore June 30,2010. [40 CFR 

### 51.308 -

### Regional Haze] 6.2.40 The Permittee shall submit a proposal to satisfy the periodic monitoring requirements of40 CFR 70.6(a)(3)(i)(B) or a Compliance Assurance Monitoring Plan as 

### required by 40 CFR Part 

### 64, whichever is applicable, in orderto ensure compliance with Condition 3.2.29, on or before June 30,2010. [40 CFR 

### 51.308 -

### Regional Haze]

Page 3 of3

# State 

# ofGeorgia Department 

## ofNatural Resources Environmental Protection Division Air Protection Branch 

# Part 

# 70 Operating Permit Amendment
Permit Amendment No.: 2631 -099-0001 -V-02-6 

### Effective Date: 

## JUL 

# fl 3 

## 2009 Facility Name: 

### Georgia-Pacific Corporation, Cedar Springs Operation Facility Address: Highway 273 West Cedar Springs, Georgia 39832 (Early County) Mailing Address: P. 

### 0.Box

### 44 Cedar Springs, Georgia 39832 (Early County) PareWHolding 

### Georgia-Pacific Corporation Company: FacilityAIRS Number: 04-13-099-00001 In accordance with the provisions of the Georgia Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the Georgia Rules for Air Quality Control, Chapter 391-3-1, adopted pursuant to and in effect under the Act, the Permittee described above is issueda construction permit for: Limit SO2emissions from Power Boilers No. 1and 2 to 135 Iblhr each and limit Recovery BoilerNo.3 SO2emissionsto 350 ppm on a dry basis correctedto 8 percent oxygen when firing black liquor to comply with BART regulations. This Permit Amendment shall also serve as a final amendmentto the Part 70 Permit unless objected to by the US. EPA or withdrawn by the Division. The Division will issue a letter when this Operating Permit amendment is finalized. This Permit Amendment is conditioned upon compliance with all provisions of The Georgia Air Quality Act, O.C.G.A. Section 12-9-1, et seq, the Rules, Chapter 391-3-1, adopted and in effect under that Act, or any other conditionof this PermitAmendment and Permit No. 2631-099-0001 -V-02-0 Unless modifiedor revoked, this Permit Amendment expires upon issuanceof the next Part 70 Permitfor this source. This Permit Amendment may be subject to revocation, suspension, modificationor amendment by the Director for cause includingevidence of noncompliance with any of the above; or for any misrepresentationmade inApplication No. 18385 dated August 1, 2008; any other applications upon which this Permit Amendment or Permit No. 2631- 099-0001-V-02-0 are based; supporting data entered therein or attached thereto; or any subsequent submittal or supporting data; or for any alterations affectingthe emissionsfrom this source. This Permit Amendment is further subject to and conditioned upon the terms, conditions, limitations, standards, or schedules contained in or specifiedon the attached 11 pages.



### Environmental Protection Divisioni



## I I 

### Title

### V Permit Amendment Georgia-Pacific Corporation- Cedar SpringsOperation PermitNo


### .

# .263 1-099-0001 -V-02-6



### PART 1.0 

### 1.3 

### PART 2.0 

### 2.1 2.2 2.3 2.4 

### PART 3.0 

### 3.1.1 3.2 

### PART 4.0 

### 4.2 

### PART 5.0 

### 5.2 

### PART 6.0 

### 6.1 6.2 

### PART 7.0 

### 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8 7.9 7.12 7.13 7.14 

### Table of Contents FACILITY DESCRIPTION

# ................................................................................................... I Process Description ofModification


### ................................................................................................... 1 

### REQUIREMENTS PERTAININGTO THE ENTIRE FACILITY 

# ........................................... I Facility Wide Emission Caps and Operating Limits


### ............................................................................ 1 Facility Wide Federal Rule Standards


### ................................................................................................1 Facility Wide SIP Rule Standards


### ......................................................................................................1 Facility Wide Standards Not Coveredby a Federal or SIP Rule and Not Instituted as anEmission



### ........................................................................................................................ Cap or Operating Limit I 

### REQUIREMENTS FOR EMISSION UNITS

# ........................................................................ 2 Additional Emission Units


### ................................................................................................................... 2 Equipment Emission Caps and Operating Limits


### ................................................................................ 3 

### REQUIREMENTS FOR TESTING

# ....................................................................................... 4 Specific Testing Requirements


### ............................................................................................................ 4 

### REQUIREMENTS FOR MONITORING (Relatedto Data Collection)

# ............................... 5 Specific Monitoring Requirements


### .................................................................................................... 5 

### OTHER RECORD KEEPINGAND REPORTING REQUIREMENTS

# .................................. 7 General Record Keeping and Reporting Requirements


### .......................................................................7 Specific Record Keeping and Reporting Requirements


### ...................................................................... 8 

### OTHER SPECIFIC REQUIREMENTS

# ...............................................................................10 Operational Flexibility Associated with this Amendment


### ................................................................ 10 Off-Permit Changes Associated with this Amendment


### ..................................................................... 10 Alternative Requirements Associated with this Amendment


### ............................................................10 Insignificant Activities Associated with this Amendment


### ................................................................. 10 Temporary Sources Associated with this Amendment


### ...................................................................... 10 Short-term Activities Associated with this Amendment


### ................................................................... 10 Compliance Schedule/Progress Reports Associated with this Amendment


### ......................................10 Emissions Trading Associated with this Amendment


### ....................................................................... 10 Acid Rain Requirements Associated with this Amendment


### .............................................................. 10 Revocation of Existing Permits and Amendments


### ............................................................................ 10 Pollution Prevention Associated with this Amendment


### ................................................................... 11 Specific Conditions Associated with this Amendment


### ...................................................................... 11

### Title 

### V PermitAmendment Georgia-Pacific Corporation- Cedar SpringsOperation Permit No.: 2631-099-0001 -V-02-6 

### PART 1.0 FACILITY DESCRIPTION 1.3 Process Description ofModification Georgia-Pacific Corporation-Cedar Springs operation is making the following changes at the facility to comply with BART regulations. Limit SO2emissions from Power Boilers No. 

### 1 and 2 to 

### 135 lbsh each for a block 24-hour averaging period. Emission will be reduced by scrubbant addition to the existing wet scrubbers, limestone addition to the boilers, or the equivalent. Limit the SO2emissions from the recovery boiler to 

### 350 ppmv on a drybasis correctedto 

### 8 percent oxygen when firing black liquor for the complete 24-hour block period. Install CEMS on Recovery Boiler No. 

### 3 to monitor SOzemissions. As needed, repair concentrator sets, install a new caustic day 

### tank or other scrubbant receiving, handling and injection system and a new lift station to connect power boiler scrubberblowdown to the waste water treatment system.


### PART 2.0 2.1 

### REQUIREMENTS PERTAINING TOTHEENTIRE FACILITY Facility Wide Emission Caps and Operating Limits None Applicable. 

### FacilityWide Federal Rule Standards None Applicable. 

### FacilityWide SIPRule Standards None Applicable. 

### Facility Wide StandardsNot Covered by 

### a Federal or SIPRule andNot Instituted as an Emission Cap or OperatingLimit None Applicable

Page 1of I I

### Title 

### V Permit Amendment Georgia-Pacific Corporation-Cedar SpringsOperation PermitNo.: 2631-099-0001 -V-02-6 

### PART3.0 REQUIREMENTS FOR EMISSION UNITS Note: Except where 

### an applicable requirement specifically states otherwise, the averaging times of 

### any of the Emissions Limitations or Standards included inthis permit are tied to orbased onthe 

### run time(s) specified forthe applicable reference test method(s) or procedures required for demonstrating compliance. 

### 3.1.1 Additional Emission Units



### m No. - u500

U501

R402

Genera Description 

## -- Power Boiler No. I

Power Boiler No. 2

Recovery BoilerNo. 3 - Specific Umiiationsi&qui~~ents Andicsble 

## I Corresponding Permit ~epire&nts/~tandards - ----- 40 CFR 61 SubpartE 40 CFR 63 subpart DDDDD 40 CFR 64 391-3-1-.02(2)(b) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g) 40 CFR Part 51AppendixY

40 CFR 61 SubpartE 40 CFR 63 Subpart DDDDD 40 CFR 64 391-3-1-.02(2)(b) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g) 40 CFR Part 5 1Appendix Y

40 CFR 63 SubpartMM 40 CFR 64 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(g) 391-3-I-.02(2)(gg)l(i) 40 CFR Part 51 Appendix Y Condjtions 3.2.8 through 3.2.12, 3.2.19,3.3.4 through 3.3.6, 3.3.9, 3.3.16, 3.4.13 through 3.4.16, 3.3.19, 3.5.1,4.2.1,4.2.2, 4.2.4 through4.2.6, 4.2.12, 4.2.26, 5.2.1 through 5.2.3, 5.2.8, 5.2.19, 5.2.21, 6.1.7, 6.2.14 through 6.2.16, 6.2.18 through 6.2.21, and 6.2.23 through 6.2.25, 6.2.47 and 6.2.48* 3.2.8 through 3.2.12, 3.2.19. 3.3.4 through 3.3.6, 3.3.9, 3.3.16,3.4.13 through 3.4.16, 3.3.19, 3.5.1,4.2.1, 4.2.2, 4.2.4 through4.2.6,4.2.12. 4.2.26, 5.2.1 through 5.2.3, 5.2.8,5.2.19,5.2.21, 6.1.7,6.2.14 through 6.2.16, 6.2.18 through 6.2.21, and 6.2.23 through 6.2.25,6.2.47 and 6.2.&3* 3.2.5, 3.2.6, 3.2.12, 3.3.6, 3.3.8, 3.3.14, 3.4.7 through 3.4.9, 4.2.1, 4.2.8 through4.2.11,4.2.27, 5.2.1 through 5.2.3,5.2.5, 5.2.13, 5.2.19, 5.2.23, 5.2.28, 5.2.29,h. 1.7,6.2.3, 6.2.4, 6.2.7through 6.2.13,6.2.23 through 6.2.25,6.2.39and 7.14.1* I I 1 applicable requirements contained in thispermit may also apply to emission units list Air ID No. C500 S500

C501 S501

C402



### ' above. 

### elution Control Devices Description 

### ---- Multicyclone Venturi Scrubberwith Caustic solutionas scrubbing media or limestone injection system

Multicyclone Venturi Scrubberwith Caustic solution as scrubbing media or limestone injection system

Dry Bottom Electrostatic Precipitator

Page 2 of 11

### Title 

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation PermitNo.: 2631 -099-0001-V-02-6


### 3.2 Equipment Emission Caps and Operating Limits [Modified Permit Condition] Recovery Boiler No. 3 3.2.6 Upon completion of the BART Exemption Project, the Permittee shall not discharge or cause the discharge into the atmosphere from Recovery Boiler No, 3 (Source Code R402) any gases which contain: c. When firing black liquor solids Sulfur dioxide emissions in excess of 350ppm on a dry basis corrected to 8 percent oxygen as a block 24-hour period beginning each calendar day at 12midnight or other appropriate starting times asmay be specified or approvedby the Division [40 CFR Part 

### 51 Appendix Y-BART] 

### [Modified Permit Condition] 3.2.8 The Permittee shall burn no more than 10,000 pounds per hour and 120tons per day oftire derived fuel (TDF) in Power Boilers No. 1 and No. 2 combined (Source Codes U500 and U501). The permittee is also allowed to bum peanut hull or whole peanuts in the Power Boilers 1 and 2. [Avoidance of40 

### CFR 52.211



### [New Permit Condition] Power Boilers No. 

### 1 and No. 2 3.2.19 Upon completion of the BART Exemption Project, the Permittee shall abide by the following emission limits: [40 CFR 51.308(e)]

a. The Permittee shall not discharge or cause the discharge into the atmosphere from Power Boiler No. 1 and Power Boiler No. 2 any gases that contain sulfur dioxide 

### (SO2) exceeding 135 pound per hour each averaged over a block 24-hour period beginning at midnight or other appropriate starting times as may be specified or approved by the Division.
3.2.8 The Permittee shall burn no more than 10,000 pounds per hour and 120tons per day of tire derived fuel 

### (TDF) in Power Boilers No. 1 and No. 2 combined (Source Codes U500 and USOl). [Avoidance of40 CFR 52.21)

Page 3 of 11

### Title

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 2631-099-000 1-V-02-6 

### PART 4.0 

### REQUIREMENTS 

### FOR TESTING 4.2 

### Specific TestingRequirements [New Permit Conditions] 4.2.26 Within 90 days of the completion of the BART Exemption Project, the Permittee shall perform an initial compliance test on Power Boilers No. 1 and 2 to determine compliance with the limits specified in Condition 3.2.19 to meet the limits specified in Condition 3.2.19. The RATA test and the performance test shall be performed simultaneously. The compliance with the emission limits 

### in condition 3.2.19 will be demonstrated using continuous 

### 24 hour of CEMS data, the first hour starting with the first hour of RATA testing. [GeorgiaRule 391-3-1 -.O2(6)(b)11 4.2.27 Within 90 days of the completion of the BART Exemption Project, the Permittee shall perform an initial compliance test on Recovery Boiler No. 3 (Source Code R402) to determine compliance with the limits specified in Condition 3.2.6. The RATA test and the performance test shall be performed simultaneously. The compliance with the emission limits in condition 3.2.6 will be demonstrated using continuous 24 hour of CEMS data, the first hour starting with the first hour of

### RATAtesting. [GeorgiaRule 391-3-1-.02(6)(b)l]

### Title

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation PermitNo.: 263 1-099-0001-V-02-6 

### PART 

### 5.0 REQUIREMENTS FOR MONITORING (Relatedto Data Collection) 

### 5.2 Specific MonitoringRequirements [ModifiedPermit Condition] 5.2.1 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor andrecord the indicated pollutants onthe following equipment. Each system shall meet the applicable performance specification(s)of the Division's monitoring requirements. [391-3-1 -.O2(6)(b)l and 40 CFR 70.6(a)(3)(i)]
c. Opacity, TRS, sulfur dioxide and oxygen from Recovery Boiler No. 3 (Source Code R402). The requirement for the installation of a continuousmonitor for sulfur dioxide will be effective on the date of the completionofthe BART ExemptionPro-iect [40 CFR 

### Part 51,

### 40 CFR 63 Subpart MM; 40 CFR 63.864(d);Georgia Rules 391-3-I-. 02(2)(b)and 39 1 -3-2-.02(2)(gg)] [Modified Permit Condition] 5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated parameters on the following equipment. Where such performance specification(s) exist, each system shall meet the applicable performance specification(s)ofthe Division'smonitoring requirements. [Georgia Rule 391-3-1 -.O2(6)(b)

### 1 and40 CFR 70.6(a)(3)(i)] d. Pressure drop and scrubbant flow rate from the scrubbers on Power Boiler No. 1 

### and No. 2 

### (Source Codes U500 and U501). [ModifiedPermit Condition] 5.2.19 The following pollutant specific emission units (PSEUs) are subject to the Compliance Assurance Monitoring (CAM)Rule in 40 CFR 64.

Permit conditions in this permit for the PSEU(s) listed above with regulatory citation 40 CFR 70.6(a)(3)(i)are included for the purpose of complyingwith 40 CFR 64. In addition, the Permittee shallmeet the requirements, as applicable,of40 CFR 64.7, 64.8, and 

### 64.9. [40 CFR 641 - EcissionUnit Lime Handling System (Group Code LEG2) Power Boiler Nos. 1 and 2 (Source CodesU500 and U501) Lime Kiln Nos. I and 2 (Source CodesL600 and L601) Recovery BoilerNos. 1and 2 (Source CodesR400 and R401) Recovery Boiler No. 3 (Source Codes R402) Smelt Dissolving Tank Nos. 1, 2, and 3 (Source CodesR404, R405, and R406) Incinerator I Scrubber System (Source Code R425)

Page 5 of 1l Pollutant PM PM, SO2 PM PM PM PM PM, SO2

### Title 

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -V-02-6 

### [ModifiedPermit Condition] 5.2.21 The Permittee shall comply with the performance criteria listed in the table below for the particulate matter and sulfur dioxide emissions from Power Boiler Nos. 1 and 2 (Source CodesU500 and U501): [40 CFR 64.6(c)(l)(iii)]
indicator No, 2 PressureDrop Across Scrubber A. Data The flow rate is The differential pressure across Representativeness measured using standard the scrubber will be measured [64.3(b)(111 instrumentation provided using standard instrumentation for this purpose. provided for this purpose. B. Verification of NIA NIA Operational Status (newlmodified monitoring equipment only)[64.3(b)(2)] C. QA/QC Practices and Annual Calibration. Annual Calibration. Criteria [64.3(b)(3)] D. Monitoring Frequency Continuous. Continuous. [64.3(b)(4)] E. Data Collection Recorded by themill Recorded by the mill data Procedures data collection system. collection system. [64.3(b)(4)] F. Averaging Period 3-hour average. 3-hour average. [64.3(b)(4)] 

### [NewPermit Condition] 5.2.29 For the sulfur dioxide CEMS installed on Recovery Boiler No.3 (Source Code R402) the Permittee shall perform annual RATA tests, quarterly accuracy determinations, and daily CEMS drift checks in accordance with the following procedures and requirements: [Georgia Rule 39 1-3- 1 -.02(6)(b) (vi)]

a. A Relative Accuracy Test Audit (RATA) shall be conducted on the CEMS at least once every four successive operating quarters. The procedures of Appendix F of 40 CFR Part 60 shall be used to conduct the RATA. The results of a RATA shall be submitted to the Division within 60 days ofcompletion of the RATA. b. A cylinder gas audit shall be conducted at least once every quarter in accordance with Appendix 

### F of40 CFR 60.

c. 

### CEMS drift checks shall be conducted daily in accordance with 40 CFR 6O.l3(d). Page 6 of 11

### Title

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -V-02-6 

### PART 6.0 

### OTHER RECORD KEEPING AND REPORTING REQUIREMENTS 6.1 

### General Record Keeping and Reporting Requirements [ModifiedPermit Condition] 6.1.7 For the purpose of reporting excess emissions, exceedances or excursions in the report required in Condition 6.1.4, the following excess emissions, exceedances, and excursions shallbe reported: [391-3-1 -.O2(6)(b)1and 40 CFR 70,6(a)(3)(i)]

a. Excess emissions: (meansforthe purpose ofthis Condition and Condition 6.1.4, any condition that is detected by monitoring or record keeping which is specifically defined, or stated to be, excess emissionsby an applicable requirement) Recovery Boilers No. 3

xv. Upon completion of the BART Exemption Project, the Permittee shall abide by the following: For Recovery Boiler No. 3 (Source Codes R402), any block 24-hour period beginning at midnight during which the SO;! emissions, expressed as the arithmetic average of 24 contiguous 1-hour periods, measured and recorded in accordancewith 5.2.1.cis 

### in excess of 350ppm on a drybasis corrected to 

### 8 percent oxygen when firing black liquor only for the complete 24-hour period. [40 CFR 51.308(e)]
Power Boilers No. 1and 2 xvi. Upon completion of the BART Exemption Project, the Permittee shall abide by the following:

For Power Boiler No. 1 and 2 (Source Codes U500 and U501), any 24-hour period duringwhich the SO2concentration, expressed as the arithmetic average of 24 contiguous 1-hour periods, measured and recorded in accordance with 5.2.1.b and calculated in accordance with Conditions 6.2.18 exceed 135Ibs per hour. [40 CFR 

### 51.308(e)]

Page 7 of l 1

### Title 

### V Permit Amendment Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-0001 -V-02-6


### 6.2 SpecificRecord Keeping and Reporting Requirements Modified Permit Condition Power Boilers No. 1and No. 2 6.2.18 For each calendar day 

### and while Power Boiler No. 

### 1 (Source Code U500) is subject to Condition 3.5.1, the Permittee shall calculate the tons of sulfuric acid mist (SPLM), particulate matter (PM), sulfurdioxide (SO2),nitrogen oxides (NOx), 

### and carbon monoxide (CO) emitted from the boiler. All hourly averaged data necessary to perform these calculations shall be maintained. The calculations for each calendar day must be complete with 72hours following the end of that calendar day. The equations to be used for each calculation follow. [Avoidanceof 40 

### CFR 52.211 a. SAM Emissions:
SAM,

### 2 =T[(SAM EmissionPactor,- Ibhr SAM SO2Emission Rate,, - day ,=I IblhrSO, 

# 1
b. PM Emissions:

Total He. Inpul,,=k Emission hr



### c. NOx Emissions:

DSCF NO .% =

# r?-; [(F - Factor 

### ,,-)( 20.9% Ib 7 48 gal MMBtu I ton NO day MMB~U 20.9% -o2 % 

# 1 Gas Dens, -XT)(Hea gal in..

# -)( hr 2,000 lb

# I]
d. 

### COEmissions:

e. SO2Emissions:

Ib "

# i 20 9% 1- hour averageSOZ Conc, , - - SO - =

# z(A~flow DSCFh,( 

# I[ 20 9%-O,% hr ,=, 10"

Page 8 of I 1

### Title

### V PermitAmendment Georgia-Pacific Corporation- Cedar SpringsOperation Permit No.: 2631-099-0001 -V-02-6 

### For the purposes of this condition, the variable i 

### represents hour i 

### of the calendar day and' any emission factors, airflow or F-factors used 

### in the above calculationswill be established upon the most recent Division-approved performance testing. 

### [New Permit Conditions1 The Permittee shall submit the actual date of the completion of the BART Exemption Project. This submittal shall include certification that a final inspection has shown that the 

### BART Exemption Project was completed in accordance with Application No.18385. This notification shall be submitted within 15 days following the completion of the 

### BART Exemption Project. [Georgia Rule 391-3-1-.02(6)(b)l and 40 CFR 70.6(a)(3)(i)] At the end of each calendar month and while Power Boiler No. 1 and Power Boiler No. 2 (Source Code U500 and 501) is subject to Condition 3.3.19, the Permittee shall calculate and record both monthly emission totals and twelve-monthrolling emission totals for sulfur dioxide (SO2) using the daily results of Condition 6.2.18. When a monthly emission total exceeds 49.27 tons for SO2for any of the Power Boilers, the Permiftee shall submit a statement indicating how the Permittee intends to meet the applicable limit(s) specified in Condition 3.3.19; this statement shallbe submittedby the 3oth day ofthe followingcalendar month. Records of all monthly and twelve-month rolling emission totals, records of demonstration calculations, records of any factors used in the calculation of criteria pollutant emissions, and other supporting documentation shall be maintained. These records shall be kept available for inspectionby or submittal to the Division for a period of fiveyears following the date ofrecord. [Avoidanceof40 

### CFR 52.21,40

### CFR 51.308(e)]

Page 9 of 11i 

### TitleV PermitAmendment Georgia-Pacific Corporation- Cedar Springs Operation Pennit No.: 263 1-099-000 1 -V-02-6



### 7.1 OperationalFlexibility Associated with this Amendment 7.2 Off-Permit ChangesAssociated with this Amendment 7.3 Alternative RequirementsAssociated with this Amendment [White Paper #2] Not Applicable 7.4 InsignificantActivities Associated with this Amendment (see Attachment 

### I3 for the list of Insignificant Activities in existence at the facility at the time of permit issuance) 7.5 Temporary SourcesAssociated with thisAmendment [391-3-1-.03(1O)(d)5

### and 40 CFR 70.6(e)] Not Applicable 7.6 Short-term Activities Associated with this Amendment (see Form D5 "Short Term Activities" of the Permit application and White Paper #1) Not Applicable. 7.7 

### ComplianceSchedule/ProgressReports Associated with this Amendment [391-3-l-.O3(lO)(d)3 and 40 CFR 70.6(~)(4)] None applicable. 7.8 EmissionsTradingAssociated with this Amendment 

### [391-3-1-.03(10)(d)l(ii) and 40 CFR 70.6(a)(10)] Not Applicable 7.9 Acid Rain RequirementsAssociated with this Amendment Not Applicable. 7.12 Revocation ofExistingPermits and Amendments The following Air Quality Permits and Amendments are subsumed by this pennit and are hereby revoked:

Page 10of 11

Air QualityPermitNumber@) 

### 263 1-099-000 1 -V-02-5 Dates ofOriginal Permit IssuanceorAmendment 

### Feb 24,2009

### Title

### V Permit Amendment d Georgia-Pacific Corporation- Cedar Springs Operation PermitNo.: 2631-099-0001-V-02-6 

### 7.13 

### Pollution Prevention Associated with this Amendment Not Applicable 7.14 

### Specific ConditionsAssociated with this Amendment [New Permit Condition] 7.14.1 The 

### BART Exemption Project including changes identified in Condition 1.3 to comply with BART exemption shallbe completedby July 30,201 

### 1.

Page 1I of 11

# State ofGeorgia Department of

## Natural Resources Environmental Protection Division Air Protection Branch 

# 502(b)(lO) Permit for Part 

# 70 Source

Facility Name: 

## Interstate Paper,LLC 2366 lnterstate Paper Road Riceboro, Georgia 31 323, Liberty County Mailing Address: 2366 Interstate Paper Road Riceboro, Georgia 31323 ParentlHolding Interstate Resources Incorporated Company: Facility AIRS Number: 04-13-179-00001 In accordance with the provisions of the Georg~a Air Quality Act, O.C.G.A. Section 12-9-1, et seq and the Georgia Rules for Air Quality Control, Chapter 391-3-1, adopted pursuant to or in effect under the Act, the Permittee described above is issued a SIP Construction and Operating Permit for: Modifications to the Paper Machine and Recovery Furnace and establishment of fuel oil and natural gas limits for the Power Boiler to keep the net increase below the 40 CFR 52.21 (PSD) major modification threshold. Addition of 40 CFR 52 -308 Regional Haze limits for the Power Boiler. This modification qualifies as a Section 502(b)(10) change to the Part 70 source in accordance with Georgia Air Quality Control Rule 391-3-1-.O3(lO)(b)(5). This Permit is conditioned upon compliance with all provisions of The Georgia Air Quality Act, O.C.G.A.Section 12- 9-1, et seq, the Rules, Chapter 391-3-1, adopted or in effect under that Act, or any other tcondition of this Permit and Permit No. 2631-179-0001-V-02-0. Unless modified or revoked, this Permit expires upon issuance c.; the next Part 70 Permit for this source. This Permit may be subject to revocation, suspension, modification or amendment by the Director for cause including evidence of noncompliance with any of the above; or for any misrepresentation made in Application No. N-19720dated May 27, 2010; Application No. TV-19766 dated June 21, 2010; any other applications upon which this Permit or Permit No. 2631-179-0001-V-02-0 are based; supporting data entered therein or attached thereto; or any subsequent submittal or supporting data; or for any alterations affecting the emissions from this source. This Permit is further subject to and conditioned upon the terms, conditions, limitations, standards, or schedules contained in or specified on the attached 6 page(s).

Director Environmental Protection Division

### . Interstate Paper. LLC

.- 502(b)(10) PERMIT FOR PART 70 SOURCE Pennit No

..2631-179-0001-V-02-1



### PART I


### . 0 1.3 

### PART 3.0 3.1.1 3.2 

### PART 5.0 5.2 

### PART 6.0 6.1 6.2 

### Table of Contents



## ................................................................................................... FACILITY DESCRIPTION 

### I

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

### Process Description ofModification 1 

### REQUIREMENTS FOR EMISSION UNITS 

## ......................................................................... 2 

### Emission Units

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

### 2

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

### Equipment Emission Caps and Operating Limits 2 

### REQUIREMENTS FOR MONITORING (Related to Data Collection)

## ................................ 4



### ...................................................................................................... Specific Monitoring Requirements 4 

### OTHER RECORD KEEPING AND REPORTING REQUIREMENTS

## ..................................4 General Record Keeping and Reporting Requirements

....................................................................... 4 

### Specific Record Keeping and Reporting Requirements

....................................................................... 5502(b)(10)PERMIT FOR PART 70 SOURCE Interstate Paper, LLC Permit No.263 1-179-0001 -V-02-1 

### PART 1.0 

### FACILITY DESCRIPTION 1.3 Process Description ofModification Interstate Paper, LLC is planning on conducting modifications to the Recovery Furnace (Emission Unit 

### ID. No. PW02) and Paper Machine (Emission Unit 

### ID NO. PMOI). The Paper Machine modifications will increase production capacity of the machine and improve the quality of the linerboard produced. The Recovery Furnace modifications will increase the firing of Black Liquor Solids (BLS) to support the increased steam demand for more linerboard production. Modifications to the Recovery Furnace will include replacement of the superheater section and the generating bank sidewall tubes. The modifications will also include waterside modifications including the addition of additional steam separating cyclones, 2 down comers, supply tubes to sidewall headers, riser tubes from sidewall headers, 2 upgraded black liquor pumps, secondary black liquor heater and spout hoods with shatter jets. The BLS firing rate will be limited to 309,316 tons during any consecutive 12-monthperiod. TRS (Total reduced sulfur) emissions will be limited to 

### 18 tons during anyconsecutive 12-month period. The Paper Machine will be modified to upgrade the machine Quality Control System (QCS). Replacement equipment will include 

### a new steam box and steam control unit, as well as press modifications to accommodate the steam box. Additional potential modifications to the paper machine includes 1) pocket ventilation systems upgrade, 2) up to four additional dryer cans, and 3) miscellaneous improvements to equipment such asthe trim squirts and table showers. The Power Boiler (Emission Unit 

### ID No. 

### PWO1) is not being modified. The Power Boiler will be limited to burning only natural gas, except during periods of natural gas curtailment. This limit is being established under the Regional Haze Rule (40 

### CFR 51.308). Natural Gas Combustion in the Power Boiler will also be limited to 1,100 MMCF during any consecutive 12-month period. Both limits on the Power Boiler, in addition to the Recovery Furnace limits will be established now to ensure the project isnot considered a major modification for PSD.

Page 1 of 6502(b)(10) PERMITFOR PART 70 SOURCE Interstate Paper, LLC Permit No.:263 1-1 79-000 1-V-02-1 

### PART 3.8 

### REQUIREMENTS FOR EMISSION UNITS Note: Except where an applicable requirement specifically states otherwise, the averaging times of any of the Emissions Limitations or Standards included in this permit are tied to or based on the run time(s) specified for the applicable reference test method(s) or procedures required for demonstrating compliance. 3.1.1 Emission Units

3.2 Equipment Emission Caps and Operating Limits 

### 3.2.4 The Permittee shall not discharge or cause the discharge into the atmosphere from the Recovery Furnace (Emission Unit 

### ID No. PW02) any gases which contain TRS (Total reduced sulfur) emissions in excess of 18.0 tons during any consecutive 

### I,-month period. [Avoidance of40 CFR 52.211 lDNo. PW02

-- -- -.

PWUI

PMOl



### 3.2.5 The Permittee shall not fire greater than 309,316 tons Black Liquor Solids (BLS) in the Recovery Furnace (Emission Unit 

### ID No. PW02) during any consecutive 12-month period. [Avoidanceof40 CFR 52.2

### 11 (2enerally applicable requirements contained in this permit may also apply to emission units listed above. The lists of applicable requirements/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. Emission Units Description Recovery Furnace

Power Boiler

Fourdrinier Paper Machine Specific Appticabk RequirementsfStandarcls 391-3-1-.02(2)(b) 391 -3-1-.02(2)(e) 391-3-1-.02(2)(g) 391-3-1-.02(2)(gg) 40 CFR 63 Subpart MM 40 CFR 64 (CAM)

pp 391-3-1-.02(2)(b) 391-3-1-.02(2)(d) 391-3-1-.02(2)(g)

391 -3-1-.02(2)(b) 391 -3-1-.02(2)(e)



### 3.2.6 The Permittee shall not bum greater than 1,100 MMCF of natural gas in the Power Boiler (Emission Unit 

### ID No. PWOI) during any consecutive 12-monthperiod. [Avoidance of40 CFR 52.2 1]

Page 2 of 6 LimitationsfRequirements CorrespondingPermit Conditions 3.2.4,3.2.5,3.3.10, 3.3.12. 3.4.1,3.4.2, 3.4.3, 3.4.4,3.5.1,4.2.1, 4.2.2, 4.2.6, 5.2.1.a, 5.2.2, 5.2.3, 5.2.5, 6.1.7.a, 6.1.7.b, 6.1.7.c, 6.2.1, 6.2.15,6.2.16, 6.2.17 ,6.2.29 through 6.2.31, 6.2.35, 6.2.36 through 6.2.40 3.2.1.3.2.6,3.2.7,3.3.2, 3.4.16,3.4.17,3.4.18, 3.4.19. 4.2.1,4.2.2, 5.2.2.q 5.2.21, 5.2.14, 6.1.7, 6.2.1, 6.2.2,6.2.3, 6.2.4,6.2.6,6.2.15, 6.2.41 through 6.2.43 3.4.20and 3.4.21 

## I Air IDNo, CDOI

None

None - - ~- Pollution Control Devices_ Description Venturi Scrubber System

None

None502(b)(10)PERMITFOR PART70 SOURCE Interstate Paper, LLC Permit No.:2631-179-0001-V-02-1


### 3.2.7 

### Effective prior to the startup of the Recovery Furnace (Emission Unit 

### ID No. PW02) or Paper Machine (Emission Unit ID No. PMOI) after making the modifications associated with Permit No. 263

### 1-179-0001-V-02-1, the Permittee shall only burn Natural Gas in the Power Boiler (Emission Unit 

### ID No. Source Code PWO1) except during periods of curtailment. The Permitee shall bum Non Condensable Gases (NCGs) in the Power Boiler (Emission Unit ID No. PW01) only duringperiods when both the Lime Kiln (primary NCG control device) and the Multi-fuel Boiler (secondary NCG control device) are out of service. This condition shall become effective not later than January 1,2011. 

### [40CFR 51.308; Avoidance of40 

### CFR 52.211

Page 3 of 6502(b)(10) PERMIT FOR PART 70 SOURCE Interstate Paper, LLC Permit No.2631-179-0001-V-02-1


### PART 5.0 

### REQUIREMENTS FOR MONITORING (Related to Data Collection) 5.2 

### Specific Monitoring Requirements 5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated parameters on the following equipment. Where such perfonnance specification(s) exist, each system shall meet the applicable performance specification(s) ofthe Division's monitoring requirements. [39 1-3-1-.O2(6)(b)

### 1 and 40 CFR 70.6(a)(3)(i)] 

### 1. Thenatural gas usage of the Power Boiler (Emission Unit 

### ID NO. PWOI). 

### PART 6.0 

### OTHER RECORD KEEPING AND REPORTING REQUIREMENTS 6.1 

### General Record Keeping and Reporting Requirements
6.1.7 For the purpose of reporting excess emissions, exceedances or excursions in the report required in Condition 6.1.4, the following excess emissions, exceedances, and excursions shall be reported: 1391-3-

### 1-.O2(6)(b)1 and 40 CFR 70.6(a)(3)(i)] b. Exceedances: (means for the purpose of this Condition and Condition 6.1.4, any condition that is detected by monitoring or record keeping that provides data in tenns of an emission limitation or standard and that indicates that emissions (or opacity) do not meet the applicable emission limitation or standard consistent with the averaging period specified for averaging the results ofthe monitoring) xxviii. Any use of natural gas in the Power Boiler (Emission Unit 

### ID NO. PWOI) exceeding 1,100 MCF during any consecutive 12-monthperiod. xxix. Any firing of Black Liquor Solids (BLS) in the Recovery Furnace (Emission Unit 

### ID NO. PWO2) exceeding 309,316 during any consecutive 12-month period.

xxx. Any use of fuel oil in the Power Boiler (Emission Unit 

### ID No. PWOI), except during natural gas curtailment. xxxi. Any combustion of NCGs in the Power Boiler (Emission Unit 

### ID No. PWOI) when either the Lime Kiln or Multi-he1Boiler are operational. xxxii. Any emissions from the Recovery Funlace (Emission Unit 

### ID NO. PWO2) scrubber of TRS (Total reduced sulhr) in excess of 

### 18 tons during any consecutive 12-monthperiod.

Page 4 of 6502(b)(10) PERMITFOR PART 70 SOURCE InterstatePaper,LLC Permit No.:2631-179-0001-V-02-1


### 6.2 Specific Record Keeping and Reporting Requirements 

### The Permittee shall submit cost data to verify expenses did not exceed the capital expenditure threshold defined by 40 CFR 60.2 within 30 days of startup of the Recovery Furnace (Emission Unit ID NO. PW02) after modifications associated with Permit No. 2631- 

### 179-0001 -V-02-1. [40CFR 60.14(e)(2)] 

# I

The Permittee shall use the records required by Condition 6.2.31.a. to determine the monthly Black Liquor Solids (BLS) firing rate in the Recovery Furnace (Emission Unit ID No. PW02). The Permittee shall notify the Division in writing when the BLS firing rate exceeds 25,800 tons per month. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to maintain compliance with the emission limit in Condition No. 

### 3.2.5. Theserecords shall be available for inspection or submittal to the Division upon request. [391-3-1

### -.02(6)(b)(l) and 40 CFR 70.6(a)(3)(i)] The Permittee shall use the records required by Condition No. 6.2.37. to determine the 12- month rolling total Black Liquor Solids (BLS) firing rate in the Recovery Furnace (Emission Unit ID No. PW02). The Permittee shall notify the Division in writing when the BLS firing rate in the Recovery Furnace (Emission Unit ID 

### No. PW02) exceeds 309,316 tons during any consecutive 12-month period. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to attain compliance with the emission limits in Condition No. 3.2.5. Theserecords shall be available for inspection or submittal to the Division upon request. [391-3-

### 1-.02(6)(b)(l) and 40 CFR 70.6(a)(3)(i)] The Permittee shall maintain records of the hours of operation of the Recovery Furnace (Emission Unit ID No. PW02). [391-3-1

### -.02(6)(b)(l) and 40 CFR 70.6(a)(3)(i)]

Page 5 of6

# .Interstate Paper,LLC 502(b)(10)PERMIT FOR PART 70 SOURCE PennitNo.:263 1-179-0001-V-02- 1
At the end of each calendar month for the Recovery Furnace (Emission Unit ID No. PW02), the Permittee shall calculate and record both monthly emission totals and twelvemonth rolling emission totals for TRS (Total Reduced Sulfur Compounds). The Permittee shall use themonitoring data recorded per Condition 5.2.1.a and the hours of operation data recorded in Condition 6.2.39 to calculate mass emission rates on a monthly basis. This information shall be recorded in a permanent form suitable and available for inspection. Theserecords shall be retained for at least five years following date of entry. If the TRS emissions during any one calendar month exceed 1.S tons then the Permittee shall notify the Division in writing, within 

### 15 days of the end of the month, as to how the Permittee intends to maintain compliance with the emissions limitation in Condition No. 3.2.4. If the rolling 12-month total TRS emissions during any calendar month exceed 18.0 tons then the Permittee shall notify the Division in writing, within 

### 15 days of the end ofthe month, asto how the Permittee intends to attain compliance with the emissions limitation in Condition No. 3.2.4. [391-3-l-.O2(6)(b)(l) and 40 CFR 70.6(a)(3)(i)] The Permittee shall record the natural gas usage in the Power Boiler (Emission Unit 

### ID No. PWOI) during each month and calculate the 12month rolling total during each month. Tl~e Permittee shall notify the Division in writing when the natural gas usage in the Power Boiler (Emission Unit ID No. PWOI) exceeds 92 MMCF per month. This notification shall be postmarked by the fifteenth day ofthe following month and shall include an explanation of how the Permittee intends to maintain compliance with the emission limit in Condition Nos. 3.2.6. ThePermittee shall notify the Division in writing when the natural gas usage in the Power Boiler (Emission Unit 

### ID No. PWOI) exceeds 1,100 MMCF during any consecutive 12-month period. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation ofhow the Pennittee intends to attain compliance with the emission limit in Condition Nos. 3.2.7. These records shall be available for inspection or submittal to the Division upon request. [391-3-1-.02(6)(b)(l)and 40 CFR 70.6(a)(3)(i)] The Permittee shall record any instance of Non Condensable Gases (NCGs) being burned in the Power Boiler (Emission Unit 

### ID No. PWOI). The date, time, and duration of each instance ofNCG burning in the Power Boiler shall be recorded. [391-3-1-.02(6)(b)(I) and 40 CFR 70.6(a)(3)(i)] ThePermittee shall maintain records of each instance of Natural Gas Curtailment, including start and finish dates, amount of fuel oil burned in the Power Boiler (Emission Unit ID No. PWOI) during Natural Gas Curtailment, and documentation from the Natural Gas supplier ofits curtailment. [391-3-1-.02(6)(b)(l)and 40 CFR 70.6(a)(3)(i)]

Page 6 of 6

### Permit 

### Number: Facility Name: FacilityAddress: 

### MailingAddress: ParentrHolding Company: 

# Stateof

# Georgia Department

## ofNatural 

## Resources

Environmental Protection Division Air Protection 

### Branch 

# Part 70 

# Operating Permit 2631-051

### -0007-V-02-0 Effective 

### Date: 

# APR 2O2010 

## International Paper

# -Savannah West 

### Lathrop Avenue Savannah, Georgia 

### 31408, Chatham 

### County 

### P.O. Box 

### 570 Savannah, 

### Georgia 31402 

### International PaperCompany FacilityAIRS Number: 

### 04-13-051-00007 In accordancewith the provisionsofthe 

### Georgia Air QualityAct. O.C.G.A. Section 12-9-1. et seq and the Georgia Rules for Air 

### QuaMy Control, Chapter 391-3-1, adopted pursuant to and in effect under the Act. the Permitteedescribedabove is issueda Part 

### 70 Pemitfor: The operation 

### of a Krafl Pulp, Paper, and Paperboard Mill and a Corrugated Paperboard Container productionfacility. This Pemit is conditioned upon compliance with all provisionsof The Georgia Air QualityAct. O.C.G.A. Section 12-9-1, et 

### sq,the 

### Rules, Chapter 391-3-1. adopted and in effect under that Act, or any other condition of this Pemit. 

### Unless modified or 

### revoked, this Permit expires five years after the effective date indicatedabove. This Permit 

### may be 

### subject to revocation, suspension. 

### modification. or amendment by the Director for cause including evidence of 

### noncompliance with 

### any of the above, for any misrepresentation made in Title 

### V Application Nos. 

### W-16986and TV-19282, signed on October 3, 2006, and November 16, 

### 2009, 

### any other applications upon which this Permit is based, supporting data entered therein 

### or attached thereto, or any subsequent submittal of supporting 

### data. or for any alterations affecting the emissions from this source. This Pemit 

### is 

### further subject to and conditioned upon the terms, conditions, limitations, standards, or schedules contained in or 

### specified on the 

### attached 72 pages.

Director Environmental Protection Division

### Title V 

### Permit International Paper

. Savannah Pennit No

.

# .263 1-051-0007-V-02-0



### PART 1.0 1.1 1.2 1.3 

### PART 2.0 2.1 2.2 2.3 2.4 

### PART 3.0 3.1 3.2 3.3 3.4 3.5 

### PART 4.0 4.1 4.2 PART 

### 5.0 5.1 5.2 PART 

### 6.0 6


### .i 6.2 

### YAR'I' 7.0 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8

, 

### ..'1 7.10 7.1 1 7.12 7.13 7.14 

### PART 8.0 8.1 8.2 8.3 

### 8.4 

### Table of Contents FACILITY DESCRIPTION 

# .............................................................................................................1 Site Determination



### ............................................................................................................................ 1

.............................................................................................................. Previous and/or Other Names 1



### .................................................................................................... Overall Facility Process Description 1 

### REQUIREMENTS PERTAINING TO THE ENTIRE FACILITY

## .............................................3

............................................................................ Facility Wide Emission Caps and Operating Limits 3

................................................................................................. Facility Wide Federal Rule Standards 3

........................................................................................................ Facility Wide SIP Rule Standards 3 Facility Wide StandardsNot Covered by a Federal or SIP Rule and Not Instituted as an Emission Cap or Operating Limit

........................................................................................................................ 3



## ................................................................................. REQUIREMENTS FOR EMISSION UNITS 4 Emission Units



### ..................................................................................................................................... 4

................................................................................ Equipment Emission Caps and Operating Limits 5 Equipment Federal Rule Standards

...................................................................................................... 6 Equipment SIP Rule Standards

..................................................................................................... 14 Equipment Standards Not Covered by a Federal or SIP Rule and Not Instituted as an Emission Cap or Operating Limit

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

### 16



# ............................. REQUIREMENTS FOR TESTING 

## ............................................................ 17 General Testing Requirements

........................................................................................................... 17

.......................................................................................................... SpecificTestingRequirements 20 

### REQUIREMENTS FOR MONITORING (Related to Data 

### Collection)

## ....................................23 General Monitoring Requirements

..................................................................................................... 23 Specific Monitoring Requirements

.................................................................................................... 23 

### RECORD KEEPING AND 

### REPORTING REQUIREMENTS 

## ..................................................31 General Record Keeping and Reporting Requirements

.....................................................................31

.................................................................... Specific Record Keeping and Reporting Requirements 42



## ........................................................................................ OTHER SPECIFIC REQUIREMENTS 54 Operational Flexibility

....................................................................................................................... 54 Off-Permit Changes

........................................................................................................................... 54 Alternative Requirements

.................................................................................................................. 55 Insignificant Activities

....................................................................................................................... 55 Temporary Sources

............................................................................................................................ 55 Short-term Activities

.......................................................................................................................... 55 Compliance Schedule/Progress Reports

............................................................................................ 55



### . . Emissions Trading

.............................................................................................................................. 55 Acid Rain Requirements

.................................................................................................................... 55 Prevention ofAccidental Releases (Section 112(r)ofthe 1990CAAA)

..........................................55

.............................. Stratospheric Ozone Protection Requirements (Title VI ofthe CAAA of 1990) 57

............................................................................ Revocation ofExisting Permits and Amendments 58 Pollution Prevention

........................................................................................................................... 58 Specific Conditions

............................................................................................................................ 58



## .............................................................................................................. GENERAL PROVISIONS 59 Terns and References

........................................................................................................................ 59 EPA Authorities

................................................................................................................................. 59 Duty to Comply

.................................................................................................................................. 59 Fee Assessment and Payment

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

### 60
1

### Title V 

### Permit International Paper

. Savannah Permit No

.

# .2631-051-0007-V-02-0



### ......................................................................................................... Permit Renewal and Expiration 60



### .................................................................................................. Transfer of Ownership or Operation 60



### ................................................................................................................................. Property Rights -60



### ...................................................................................................................................... Submissions -61



### ............................................................................................................. Duty to Provide Information -61

..................................................................................................................................... Modificatiolls 62

............................................................... Permit Revision, Revocation, Reopening and Termination 

### 62

........................................................................................................................................ Severability 63 Excess Emissions Due to an Emergency
........................................................................................... 63

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

### Compliance Requirements 64

.................................................................................................................................... Circumvention 66 Permit Shield

...................................................................................................................................... 66

......................................................................................................................... Operational Practices 67

............................................................................................................................... Visible Emissions 67

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

### Fuel-burning Equipment 67 SulfurDioxide

.................................................................................................................................... 68

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

### Particulate Emissions 68



### ...................................................................................................................................... Fugitive Dust 69 

### Solvent Metal Cleaning

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

### 69

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

### Incinerators 70

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

### Volatile Organic Liquid Handling and Storage 71

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

### Use ofAny Credible Evidence or Information 71

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

### Diesel-Fired Internal Combustion Engines 71
CI? Attachments

## .............................................................................................................................................................. IL 

### A



### .List of Standard Abbreviations and List ofPermit Specific Abbreviations 

### B

. InsibmificantActivities Checklist. Insignificant Activities Based on Emission Levels and Generic Emission Groups C


### . List ofReferencesInternational Pauer - Savannah Title V Permit Pem~it No.: 263 1-051-0007-V-02-0 PART 

### I.O 1.1

1.2

1.3 FACILITY DESCRIPTION Site Determination The Past 70 Site consists solely of International Paper - Savannah (AIRS No. 051-00007). There are no other facilities which could possibly be contiguous or adjacent and under colnlnon control. On March 1,2007, Arizona Chemical Company, Savannah Plant (AIRS No. 

### 051-00148) was sold to Rhone Capital 111. Ownership of International Paper - Savarlnah (the pulp and paper facility) was retained by International Paper Company. Prior to the March 1, 2007, transaction, International Paper - Savannah and the adjacent Arizona Chemical Company, Savannah Plant were both parts of the same Part 70 Site under the common control of International Paper Company although each facility operated under a separate Part 70 Operating Permit. International Paper - Savannah (AIRS No. 05 1-00007) and Arizona Chemical Company, Savannah Plant (AIRSNo. 051-001 

### 48) now operate as two autonomous Part 70 Sites. This Part 70 Operating Pesmit will cover only International Paper - Savannah. Previous and/or Other Names Union Camp Corporation Overall Facility Process Description International Paper - Savannah has a rated production capacity of 1.2 million tons annually. The output ofproducts ranges from the lightest weight unbleached paper used in the manufacture ofpaper bags to heavy-duty linerboard used in the manufacture of cormgated boxes. One machine is dedicated to the production of saturating kraft, the core stock for plastic laminates used in kitchen and bath cabinets and countertops. Thekraft (sulfate) process at Intemational Paper - Savannah produces pulp from wood chips. Sulfate turpentine and wood fat soaps are by-products of this process. 

### In addition, waste paper is converted to pulp, and the pulp is then converted to paper and linerboard on a series of paper machines. Linerboard produced by International Paper - Savannah is used to manufacture boxes in the corrugated box plant. Theinitial step in the manufacturing process involves receipt of logs by truck or railcar. The logs are then washed, debarked, and chipped. The wood chips are conveyed to the pulp mill digesters. In the digesters, white liquor, a hot mixture of chemicals including sodium hydroxide and sodium sulfide, is used to cook the wood chips. The cooking dissolves the lignin, the material that binds the wood fibers,and i'onns a chemical solution called black liquor. Thepulplblack liquor mixture ispumped to pulp washers where the spent black liquor is washed from the pulp. The dilute black liquor fi-omthe pulp washers isthen pumped to the weak liquor tanks for storage, and the clean pulp is pumped to the paper mill where it is converted to paper and board products.Title 

### V Permit International Paper - Savannah Permit No.: 2631-051 -0007-V-02-0 

### Theblack liquor contains a variety of dissolved organic materials from the wood that can be burned. Because the black liquor coming from the pulp washers has a high water content, it must be concentrated in the evaporators before it can be bumed in the recovery furnace. Black liquor containing about 16

### percent dissolved solids ispumped from the weak liquor tanks to the evaporators. The black liquor leaving the evaporators contains about 

### 50 percent solids. The black liquor then flows to the cascade evaporators or the concentrator where the black liquor is concentrated and the solids content increases to between 60 

### and 

### 85 percent prior to being sprayed into the recovery furnace. The remainder of the water in the black liquor is evaporated inside the recovery furnace by the heat generated during burning. The dry black liquor falls to the bottom of the recovery furnace to fonn a char bed, a combination of melted sodium and sulfur compounds and burning organic compounds from the dissolved wood. Theburning ofthe combustible wood products forms gases that are further burned higher up in the recovery furnace. The smelt, the melted mixture of sodium and sulfur compounds, flows through spouts arranged in the bottom of the recovery furnace and is then dissolved in a smelt dissolving tank to fonn green liquor. The green liquor is then pumped to the caustic room where it is combined with lime to form a mixture ofwhite liquor and lime mud, which is then separated in the white liquor clarifier. The lime mud is heated in the lime kiln to produce rebumed lime. Completingthe chemical recoveryprocess, the white liquor is then used in the digesters to convert wood chips to pulp. Washed pulp from the pulping process is stored in large tanks before being used in the paper mill. Various grades of pulp made from both pine chips and hardwoods chips are stored. Different pulps may be combined in the blend chest of an individual paper machine. This pulp is then fed to the paper machine where it 

### is dewatered and dried to form paper. International Paper - 

### Savannah produces various grades of kraft paper, linerboard, and saturating kraft on six operating machines. Some products are single-ply while others have a top sheet and a bottom sheet bound together for strength. Paper can be converted to bags, corrugated boxes, and laminates. The box plant manufactures, prints, and ships corrugated paperboard containers. The primary raw materials for the box plant include paperboard medium and linerboard, adhesive made with cornstarch and sodium hydroxide, flexographic printing inks, and a food-grade wax. Although the tall oil collection facilities are located at International Paper - 

### Savannah, the tall oil collection operations at the mill are conducted by Arizona Chemical. Tall oil recovered at International Paper - 

### Savannah is transported by railcar to the adjacent Arizona Chemical plant. No. 13 Power Boiler Bark Burning Project 

### The 

### No. 13 Power Boiler Bark Burning Project includes the following modifications to improve the reliability of the boiler and associated systems when firing bark and, thus, to allow for an increase in the annual and hourlybark firing rates: Upgrading the existing overfire air (OFA) system for improved combustion efficiency; Modifying bark bins to reduce pluggage; Upgrading the ash system, including replacing the primary and secondary collectors, rerouting the air heater hopper ash, and reconfiguring the ash system under theprecipitator; Adding a magnet and metal detector in the bark lines; Recommissioning the second side ofthe Wennburgbark screw and hog; and Reconfiguring the bark feeders to reduce housekeeping issues. Page 2 of 72International Paver - Savannah Title 

### V Permit Permit No.: 263 1-051-0007-V-02-0 REQUIREMENTS PERTAINING TO THE ENTIRE FACILITY Facility Wide Emission Caps and Operating Limits 2.1.1 

### The Permittee shall limit the fiber production to less than 1,222,750 air-dried tons 

### of virgin pulp fiber per year. [Avoidance of40 

### CFR 52.211 Facility Wide Federal Rule Standards 

### None applicable. Facility Wide SIPRule Standards 

### None applicable. Facility Wide Standards Not Covered 

### by a Federal or SIP Rule and Not Instituted as an Emission Cap or OperatingLimit None 

### applicable.

Page 3 of 72

### Title 

### V Permit International Paper -Savannah Permit No.: 2631-051-0007-V-02-0 

### PART 3.0 REQUIREMENTS FOR EMISSION UNITS Note: Except where an applicable requirement specifically states otherwise, the averaging times of any of the Emissions Limitations or Standards included in this permit are tied to or based on the run time(s) specified for the applicable reference test method(s) or procedures required for demonstrating compliance. 3.1 

### Emission Units

ID No. LK07

OPG8

LKI0 LKl l RF 15

RF 10

# IEmission Units Description \io. 7 Lime Kiln

limeConveyor System
North Slaker South Slaker No. 15 Recovery Furnact

No. 15 Recovery Fumact Smelt Dissolving Tank

No. 13 Power Boiler Specific Limitatio Applicable RequirementslStandards LO CFR 52.21 10CFR 60 Subpart A t0 CFR 50 Subpart BB LO CFR 63 Subpart A $0CFR 63 Suhpart MM 10 CFR Part 64 391-3-1-.02(2)(a)3(i) 191-3-1-.02(2)(b) 191-3-1-.02(2)(e) 191-3-1-.02(2)(g) 391-3-1-.02(2)(gg) 10CFR Part 04 39 1-3-1-.02(2)(b) 391-3-1-.02(2)(e) 191-3-1-.02(2)(b) 391-3-1-.02(2)(e) 39 1-3-1-.02(2)(b) 391-3-1-.02(2)(e) 10CFR 52.21 40 CFR 60 Subpart A 10CFR 60 Subpart Db 10CFR 60 Subpart BB 10CFR 63 Subpart A 10CFR 63 Subpart MM 40 CFR Part 64 39 1-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(~) 391-3-1-.02(2)(gg) 40 CFR 52.21 40 CFR 60 Subpart A 40 CFR 60 Subpart BB 40 CFR 63 Subpart A 40 CFR 63 Subpart MM 40 CFR Part 64 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-I -.02(2)(gg) 40 CFR 52.21 40 CFR 60 Subpart A 40 CFR 60 Subpart D 40 CFR 60 Subpart BB 40 CFR Part 64 391-3-I -.02(2)(a)3(i) 391 -3-1-.02(2)(d) 39 1-3-1-.02(2)(g) ~nslRequirements 

### -f Corresponding Permit 

## I , 

## 1 Conditions 

## 1 ' 13.3.1,3.3.10,3.3.12, Air I ID No. APOl

AP03
AP04 AP05 AP14

AP15 lllution Control Devices Description No. 7 Lime Kiln Electrostatic Precipitator

No. 7 Lime Kiln Dust Scrubber North Slaker Wetted Fan Scrubber South Slaket-Wetted Fan Scrubber No. 15 Recovery Furnace Electrostatic Precipitator

No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber

No. 13 Power Boiler Electrostatic Precipitator

Page 4 of 72International Paper - Savannah Title V Permit Pennit No.: 2631-051-0007-V-02-0 Emission Units 

# -r-----

LVH?

HVLC

PPCC

--A Sox Pla

B

P

-- - PL

--- -

PL', Description K2 Fines Cyclone LVHC Pulping Vents (Nos. 1 and 2 Kamyr Digester Systems, No. I Stripper Collection Tan1 Nos. 4 through 7 Evaporator Systems, Fo Condensate Collection Tank, Turpentine Systei LVHC Pulping Vents: Pre-Evaporator Island (Pre-Evaporator System No. 2 Stripper Feed Tar HVLC Pulping Vents (Nos. I and 2 Kamyr Washer Systems) Pulping Process Condensate Collection System SpecificEimitationslRequirements Applicable Corresponding Permit Requirements/Standards Conditions 391-3-1-.02(2)(b) 3.3.9, 3.4.12,3.4.13,5.2.9 391 -3-1-.02(2)(e) 6.1.7 40 CFR 60 SubpartA 3.3.10, 3.3.12, 3.3.23, 40 CFR 60 Subpart BB 3.3.26,3.3.27, 3.3.28, 40 CFR 63 Subpart A 5.2.2,5.2.7, 6.1.7, 6.2 17, 40 CFR 63Subpart S 6.2.18,6.2.20, 6.2.21 391 -3-1-.02(2)(gg)

40 CFR 60 Subpart A 3.2.1.3.3.10,3.3.12, 40 CFR 60 Subpart BB 3.3.23, 3.3.26, 3.3.27, 40 CFR 63 Subpart A 3.3.28,5.2.2, 5.2.7, 6.1.7, 40 CFR 63 Subpart S 6.2.17, 6.2.18, 6.2.20, 40 CFR 63 Subpart A 13.3.11,3.3.12, 3.3.27, 40 CFR 63 Subpart S 3.3.28, 5.2.2, 5.2.7, 6.1.7, 6.2.17, 6.2.18.6.2.20, 40 CFR 63 SubpartA 3.3.13, 3.3.14, 3.3.15. 40 CFR 63 Subpart S 3.3.16,3.3.17,3.3.18. 3.3.19, 3.3.27, 3.3.28, 4.2.3,4.2.4, 4.2.5,4.2.6, 4.2.7,5.2.2, 5.2.6, 5.2.8, 6.1.7,6.2.19,6.2.20, 6.2.21, 6.2.22, 6.2.23, 6.2.24 Air ID No.

PB13 LK07 WLSl
PB13 dlution Control Devices Description

No. 13 Power Boiler No. 7 Lirne Kiln

No. 13 Power Boiler No. 7 Lime Kiln White Liquor NCG Scrubber

No. 13 Power Boiler

Steam Stripper Biological Treatment System

Box Plant

--

Equipment Emission Caps and Operating Limits -.- Poultry Line No. 2 Poultry Line

-

.WhiteLiquor NCG Scrubber --- 40 CFR 63 Subpart A 40 CFR 63 Subpart KK


## I i / 6.2.32, 6.2.33

3.2.1 The Pesmittee shall operate the White Liquor NCG Scrubber (Source Code: WLS1) with a minimum removal efficiency for total reduced sulfur (TRS) compounds of 50 percent (by weight). [Avoidance of40 CFR 52.211 3.3.22, 3.3.27, 3.3.29, 3.4.14, 6.1.7, 6.2.34,

---

--- Generally applicable requirements contained in this pennit may also apply to emission units listed above.

Electric Output for Sale 3.2.2 ThePesmittee shall supply no more than one-third ofits potential electric output capacity or 219,000 megawatt-hours (MWe-hrs) of electrical output, whichever is less, to any utility power distribution system for sale from either the No. 15 Recovery Furnace (Source Code: RF15) or the No. 13 Power Boiler (Source Code: PB13) during any twelve consecutive months. [Avoidance of40CFR 60 Subpart Da and Avoidance of40 CFR 72 Subpart A] 6.2.35, 6.2.36, 6.2.37 3.3.20,6.1.7, 6.2.31, 6.2.32, 6.2.33 3.3.21,6.1.7, 6.2.31,

Page 5 of 72 -..

.-- ---

---

### Title V 

### Permit International Paper - Savannah Permit No.: 263 1-05I-0007-V-02-0 

### 3.3 

### Equipment Federal Rule Standards No. 

### 7 Lime Kiln 3.3.1 ThePermittee shall not discharge or cause the discharge into the atmosphere fiom the No. 7 

### Lime Kiln (SourceCode: LK07) any gases which:
a. Contain particulate matter (PM) emissions in excess of 0.064 grains per dry standard cubic foot(gr1dscf)(correctedto 10percent oxygen). [40CFR 63.862(a)(l)(i)(C) and 40 CFR 60.282(a)(3)(i)&(ii) (subsurned)] b. Contain total reduced sulfur (TRS) compound emissions in excess of 8 parts per million (ppm) by volume on a dry basis (corrected to 10percent oxygen). [40CFR 60.283(a)(5) and 391-3-1 -.02(2)(gg)1

### (iv) (subsumed)]
c. Contain sulfur dioxide (SO2)emissions in excess of 

### 719

### pounds per hour (lbhr). [40CFR 52.211 Lime Area 3.3.2 The Permittee shall not discharge or cause the discharge into the atmosphere from the Lime Conveyor System (Source Code: OPG8) any gases which contain particulate matter (PM) emissions in excess of 

### [Avoidance of40 CFR 52.2 1]
a. 7.9 pounds per hour (lbhr). b. 34.6tons during any twelve consecutive months. No. 15Recovery Furnace 3.3.3 The Permittee shall not discharge or cause the discharge into the atmosphere from the No. 1 

### 5 Recovery Furnace (Source Code: RF1

### 5)any gases which:
a. Exhibit an opacity greater than 20 percent (six-minute average), except for one six-minute period per hour ofnot more than 27 percent opacity. [40 CFR 60.43b(f), 40 CFR 60.282(a)(l)(ii) (subsumed), and 391-3-1-.02(2)(b)1 (subsumed)] b. Contain nitrogen oxide (NOx) emissions in excess of 100parts per million (ppm) by volume on a dry basis (corrected to 8 percent oxygen) when burning only black liquor. [40CFR 52.211

Page 6 of 72International Paper - Savannah Title V Permit Permit No.: 2631-051-0007-V-02-0
c. Contain total reduced sulfur (TRS) compound emissions in excess of 5 parts per million (ppm)by volume on 

### a dry basis (corrected to 8percent oxygen). [40CFR 60.283(a)(2) and 391-3-1-.02(2)(gg)1 (i)(II)] d. Contain sulfur dioxide (SO2)emissions in excess of 

### 319pounds per hour (Iblhr). [Avoidanceof40 CFR 52.211
e. Contain particulate matter 

### (PM) emissions in excess of 0.044 grains per 

### dry standard cubic foot (grldscf) (corrected to 8 percent oxygen). [40 CFR 63.862(a)(l)(i)(A) and 40 CFR 60.282(a)(l)(i)] 3.3.4 The Permittee shall fire only fuel oil meeting the definition of "very low sulfur oil" set forth in 40 CFR 60.41b in the No. 15Recovery Furnace (Source Code: RF15). [40CFR 60.42b(a)&Cj)and 391-3-1-.02(2)(g)2 (subsumed)] 3.3.5 The annual capacity factor for fuel oil and natural gas fired in the No. 15Recovery Furnace (Source Code: RF15) shall be 10 percent or less. The annual capacity factor is the ratio between the actual heat input to the boiler from fuel oil and natural gas during a calendar year and the potential heat input to the boiler had it been operated 8,760 hours during a calendar year at maximum steady statedesign heat input capacity. [40 CFR 60.44b(c)] No. 15 Recovery Furnace Smelt Dissolving Tank 3.3.6 The Permittee shall not discharge or cause the discharge into the atmosphere from the No. 15Recovery Furnace Smelt Dissolving Tank (Source Code: RFl0) any gases which:
a. Contain particulate matter 

### (PM) emissions in excess 

### of: i. 23.1 pounds per hour (lblhr). [40 CFR 52.211



### .. 11. 

### 0.15pounds per ton ofblack liquor solids (Iblton BLS). [40CFR 52.21,40 CFR 63.862(a)(l)(i)(B) (subsumed), and 40 CFR 60.282(a)(2) (subsumed)] b. Contain sulfur dioxide (S02) emissions in excess of 1 1.4pounds per hour (Ibhr). [40CFR 52.211 c. Contain total reduced sulfur (TRS) emissions in excess of2.6pounds per hour (Ibh). [Avoidance of40 CFR 52.211

Page 7 of 72International Pa~er - Savannah 

### Title 

### V Permit Permit No.: 2631-051-0007-V-02-0 

### No. 13Power Boiler 3.3.7 The Permittee shall not discharge or cause the discharge into the atmosphere from the No. 13Power Boiler (Source Code: PB 13) any gases which:
a. Coiltain particulate matter 

### (PM) emissions in excess of 0.075 pounds per million Btu (IbIMMBtu). [40 CFR 52.21, 40 CFR 60.42(a)(I) (subsumed), and 391-3-1-.02(2)(d)2(iii) (subsumed)] b. Contain sulfur dioxide (SO:,) 

### emissions in excess of i. 0.80 pounds per million Btu (IbIMMBtu) derived from liquid fossil fuel or liquid fossil fbel and wood residue. [40CFR 60.43(a)(I) and 391-3-1-.02(2)(g)l(i)] ii. 1.2 pounds per million Btu (IbIMMBtu) derived from solid fossiI fbel or solid fossil he1and wood residue. [40CFR 60.43(a)(2) and 391-3-1-.02(2)(g)l (ii)]

. . . 

### 111. When different fossil fuels are burned simultaneously in any combination, the applicable standard, in pounds per million Btu (IbIMMBtu), shall be determined by proration using the following formula: [40 CFR 60.43(b) and 

### 391-3-1-.02(2)(g)I(iii)]

where PSsor= The prorated standard for SO:, when burning different fuels simultaneously, in pounds per million Btu (IbIMMBtu), derived from all fossil fuels fired or from all fossil fuels and wood residue fired, 

### v = 

### Thepercentage oftotal heat input derived from liquid fossil fuel; and 

### - - A - 

### Thepercentage oftotal heat input derived from solid fossil fuel. iv. An average of 2822 pounds per hour (lblhr) during any continuous 24-hour period. [40CFR 52.211
v. An average of 4281 pounds per hour (lbhr) during any continuous three-hour period. [40CFR 52.211
c. Contain nitrogen oxides 

### (NOx), expressed as NO2,in excess oE i. 0.30 pounds per million Btu (lb/MMBtu) derived from liquid fossil fuel or liquid fossil fuel and wood residue. [40CFR 60.44(a)(2) and 391-3-1-.02(2)(d)4(i)] Page 8 of 72Title 

### V Permit International Paper -Savannah Permit No.: 263 1-051-0007-V-02-0 ii. 0.70 pounds per million Btu (IbIMMBtu) derived from solid fossil fuel or solid fossil fuel and wood residue. [40CFR 60.44(a)(3) and 391-3-1-.02(2)(d)4(ii)]

... 111. When different fossil fuels are burned simultaneously in any combination, the applicable standard, in pounds per million Btu (IbIMMBtu), shall be determined by proration using the following formula: [40 CFR 60.44(b) and 391-3-1-.02(2)(d)4(iv)]

where 

### P&, = The prorated standard for 

### NOx when burning different fuels simultaneously, in pounds per million Btu (IbIMMBtu), derived from all fossil fuels fired or from all fossil fuels and wood residue fired, .Y = Thepercentage oftotal heat input derived from liquid fossil fuel; and 

### - - L. - Thepercentage oftotal heat input derived from solid fossil fuel. 3.3.8 The Permittee shall not discharge or cause the discharge into the atmosphere from the No. 13 Power Boiler (Source Code: PB13) any gases which exhibit an opacity greater than 20 percent (six-minute average), except for one six-tninute period per hour ofnot more than 27 percent opacity. [40CFR 60.42(a)(2) and 391-3-1-.02(2)(d)3] Wood Chip Screening System 3.3.9 The Permittee shall not discharge or cause the discharge into the atmosphere from the K2 Fines Cyclone (Source Code: AP06) any gases which contain particulate matter (PM) emissions in excess of 5.71 pounds per hour (lblhr). [Avoidanceof40 CFR 52.211 Cluster Rule (Vents) 3.3.10 The Permittee shall control the total hazardous air pollutant (HAP) and total reduced sulfur (TRS) emissions from each LVHC (Low Volume, High Concentration) System in the following manner: a. When combusting HAP and TRS gas streams from Emission Groups LVHl and LVH2, the HAP and TRS gas streams shall be introduced with the primary fuel or into the flame zone of the No. 13 Power Boiler (Source Code: PB13) (primary) or the No. 7 Lime Kiln (Source Code: LK07) (backup). [40 CFR 63.443(a)(l)(i), 40 CFR 63.443(d)(4)(i)&(ii), 40 CFR 60.283(a)(l)(iii) and 391 -3-1-.03(2)(gg)l(ii)(lII)]

Page 9 of 72

### Title V 

### Permit International Paper -Savannah Permit No.: 2631-05 1 -0007-V-02-0 b. When combusting the TRS gas stream from Emission Group LVH2 in the No. 13 Power Boiler (Source Code: PB13), the gases shall be scrubbed in the White Liquor 

### NCG Scrubber (Source Code: WLSI) prior to combustion at least 90 percent of the facility operating time. [Avoidanceof40 CFR 52.2

### 11 3.3.11 The Permittee shall control the total hazardous air pollutant (HAP) emissions from the HVLC (High Volume, Low Concentration) system (Source Code: HVLC) using the No. 13 Power Boiler (Source Code: PB13) by introducing the HAP emissions stream with the primary fuel or into the flame zone. For the purposes of this Condition, an HVLC system means the collection of equipment that includes the knotter, screen, decker, and pulp washing systems as well as any other equipment serving the same function as those previously listed. [40CFR 63.443(a)(l)(ii) through (iv)] 3.3.12 Equipment listed in Condition Nos. 3.3.10 and 3.3.1 1 shall be enclosed and vented into a closed-vent system and routed to a cot~trol device. The enclosures and closed-vent system shall meet the requirements specified in 40 CFR 63.450. [40CFR 63.443(c)] Cluster Rule (Condensates) 3.3.13 The Permittee shall collect the Pulping Process Condensates (Source Code: PPCC) from any combination ofthe following sources to meet the requirements of Condition Nos. 3.3.14 and 3.3.17: [40CFR 63.446(b)] a. Each digester system; b. Each turpentine recovery system;
c. Each evaporator system condensate from: i. Thevapors from each stage where weak liquor isintroduced (feed stages); and

.. 11. Each evaporator vacuutn system for each stage where weak liquor is introduced (feed stages). d. Each HVLC collection system; and
e. Each LVHC collection system. Cluster Rule (Collection) 3.3.14 The Permittee shall collect the Pulping Process Condensates (Source Code: PPCC) from the equipment systems listed in Condition No. 3.3.13 that in total contain a total hazardous air pollutant (HAP)tnass of7.2 pounds per ton of oven-dried pulp (Man ODP). [40CFR 63.446(~)(3)]
Page 10of 72

### Title 

### V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 3.?.1 

### 5 The Pulping Process Condensates (Source Code: PPCC) collected in the system used to meet the requirements of Condition No. 3.3.14 shall be conveyed in a closed collection system that is designed and operated to meet the individual drain system requirements specified in 40 CFR 63.960,40 CFR 63.961, and 40 CFR 63.962 of Subpart RR, except for closed-vent systems and control devices shall be designed and operated in accordance with 40 CFR 63.443(d) and 40 CFR 63.450, instead of in accordance with 40 CFR 63.693. [40 CFR 63.446(d)(I)] 3.3.16 The condensate collection tank shall meet the following requirements: [40CFR 63.446(d)(2)]
a. The fixed roof and all openings shall be designed and operated with no detectable leaks as indicated by an instrument reading of less than 500 parts per million (ppm) above background as determined by the procedures of 40 CFR 63.457(d). The tank shall be vented into a closed-vent system that meets the requirements of 40 CFR 63.450 and routed to a control device that meets the requirements of Condition No. 3.3.10; and b. Each opening shall be maintained in a closed, sealed position at all times that the tank contains pulping process condensate stream except when it is necessary to use the opening for sampling, removal, or for equipment inspection, maintenance or repair.

The Permittee shall treat the Pulping Process Condensates (Source Code: PPCC), collected in accordance with Condition No. 3.3.14, to remove the total hazardous air pollutant (HAP) mass by at least 6.6pounds per ton of oven-dried pulp (lblton 

### ODP). [40CFR 63.446(e)(4)] The Permittee shall sum the amount of total hazardous air pollutant (HAP) mass removed from the Pulping Process Condensates (Source Code: PPCC), collected in accordance with Condition No. 3.3.14, by the Steam Stripper (Source Code: AP17) and the Biological Treatment System (Source Code: AP18) to determine compliance with 

### 40 CFR 63 Subpart S for the treatment of foul condensates. [40CFR 63.4541 The Permittee shall discharge those pulping process condensates to be treated biologically below the liquid surface ofthe Biological Treatment System (Source Code: AP18). [40 CFR 63.446(e)(2)] Poultry Lines 3.3.20 The Permittee shall not discharge or cause the discharge into the atmosphere from the Poultry Line (Source Code: PL) volatile organic compound (VOC) emissions in an amount equal to or exceeding 10tons during any twelve consecutive months. [Avoidance of40 CFR 52.211

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 

### 3.3.21 The Pennittee shall not discharge or cause the discharge into the atmosphere from the No. 2 Poultry Line (Source Code: PL2) volatile organic compound (VOC) emissions in an amount equal to or exceeding 10tons during any twelve consecutive months. [Avoidance of40 CFR 52.211 Box Plant 3.3.22

General 3.3.23

3.3.24

3.3.25

3.3.26

3.3.27 The Permittee shall apply no more than 400 kilograms (kg) per month, for every month, of organic hazardous air pollutants (HAP) on product and packaging rotogravure or wide-web flexographic printing presses in the Box PIant (Source Code: BP). The subject equipment includes the Flexo/Folder/Gluers as well as the Corrugators and any other stand-alone equipment included in accordance with 40 

### CFR 63.821

### (a)(2)&(3). [40 CFR 63.82 1 (b)(2) and 40 CFR 63.82 1 (a)(2)&(3)]

The Permittee shall comply with all applicable provisions of Federal Standard 40 

### CFR 60 Subpart A, "General Provisions". [40CFR 60 Subpart A] The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 60 Subpart D, "Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction Is Commenced After August 17, 1971

### ", for the operation of the No. 13 Power Boiler (SourceCode: PB 13). [40 CFR 60 Subpart Dl The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 60 Subpart Db, "Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units", for the operation of the No. 15Recovery Furnace (SourceCode: RF 15). [40CFR 60 Subpart Db] The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 60 Subpart BB, "Standards ofPerformance for Kraft Pulp Mills", for the operation ofthe No. 7 

### Lime Kiln, the No. 15 

### Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RF 10,respectively) as well as Ernission Groups LVH1 and LVH2. [40CFR 60 Subpart BB] The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 63 Subpart A, "General Provisions" as specified in Table 1to 40 CFR 63 Subpart S,Table 1 

### to 40 CFR 63 Subpart 

### KK, and Table 1to 40 CFR 63 Subpart 

### MM. [40CFR 63 Subpart A]

Page 12of 72

### Title V 

### Permit International Paper -Savannah Permit No.: 2631-051-0007-V-02-0 3.7 23 The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 63 Subpart S, "National Emission Standard for Hazardous Air Pollutants from the Pulp and Paper Industry", for the operation of the pulp mill. The Permittee is not permitted to operate equipment associated with the No. 

### 8 Washline, including the Batch Digesters. This equipment is permanently shutdown and abandoned for avoidance of the requirements of 40 CFR 52.21, "Prevention of Significant Deterioration". [40CFR 63 Subpart S and Avoidance of40 CFR 52.211 3.3.29 The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 63 Subpart 

### KK, "National Emission Standards for the Printing and Publishing Industry", for the operation of the Box Plant (Source Code: BP), including the Flexo/Folder/Gluers as well as the Cormgators and any other stand-alone equipment included in accordance with 40 CFR 63.821 (a)(2)&(3). [40CFR 63 Subpart KK] 3.3.30 The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 63 Subpart MM, "National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills", for the operation of the No. 

### 7 Lime Kiln, the No. 15 Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RFIO, respectively). [40CFR 63 Subpart MM] Regional Haze Effective January 1,2016, the Permittee shall not discharge, or cause the discharge, into the atmosphere from the No. 13 Power Boiler (Source Code: PB13) and from the combustion of low-volume high-concentration (LVHC) non-condensable gases, high-volume low-concentration (HVLC) non-condensable gases, and stripper off-gases (SOG) (excluding the combustion of any of these gases in the No. 7 Lime Kiln (Source Code: LK07)) sulfur dioxide (SO?) emissions in excess of 6578 tons respectively during any twelve consecutive month period. The first compliance period shall be January through December 2016. [40CFR 51.308 ] The Permittee shall submit a plan for complying with the emission limit of Condition No. 3.3.31, including all required pennit applications required under Georgia Air Quality Control Rules 391-3-1-.03 for any physical or operational changes required to meet the emission limit of Condition No. 3.3.3 1,on orbefore June 30,2014. [40CFR 51.3081 The Permittee shall submit a proposal to satisfy the period monitoring requirements of 40 CFR 70.6(a)(3)(i)(B) or a Compliance Assurance Monitoring Plan as required by 40 CFR Part 64, whichever is applicable, in order to ensure compliance with Condition No. 3.3.3 1 on or before June 30, 2014. [40CFR 51.3081

Page 13 of72Title V Permit International Paper - Savannah Permit No.: 263 1-05 1-0007-V-02-0 

### 3.4 Equipment SIPRule Standards No. 7 Lime Kiln The Permittee shall not cause, let, suffer, permit, or allow emissions from the No. 7 Lime Kiln (Source Code: LK07) the opacity of which is equal to or greater than 40 percent (six-minute average). [391-3-1-.02(2)(b)1] The Permittee shall not cause, let, permit, suffer, or allow the rate of emission ti-om the No. 7 Lime Kiln (Source Code: LK07) particulate matter (PM) in total quantities equal to or exceeding the allowable rate calculated using the following equations: [391-3-1-.02(2)(e)l(i)l 

### E = 4.1~O~~, for process input weight rate up to and including 30tonsper hour (tph); 

### E = 55P0" -40, for process input weight rate above 30tons per hour (tph). where 

### E =emission rate in pounds per hour (lblhr), and 

### P =process input weight rate in tonsper hour (tph). The Permittee shall fire only fuels containing no more than three percent sulfur, by weight, in the No. 7 Lime Kiln (SourceCode: LK07). [391-3-1.02(2)(g)2] Lime Area 3.4.4 The Permittee shall not cause, let, suffer, permit, or allow emissions from the Lime Conveyor System (Source Code: 

### OPG8), the North Lime Slaker (Source Code: LKlO), or the South Lime Slaker (SourceCode: LKI 1)the opacityofwhich is equal to or greater than 40percent (six-minute average). [391-3-1-.02(2)(b)l] 3.4.5 The Permittee shall not cause, let, pennit, suffer, or allow the rate of emission from the Lime Conveyor System (Source Code: 

### OPG8), the North Lime Slaker (Source Code: LKIO), or the South Lime Slaker (Source Code: LK11) particulate matter (PM) in total quantities equal to or exceeding the allowable rate calculated using the following equations: [391-3-1-.02(2)(e)1(i)] 

### E =4.1

### P~).~~ , for process input weight rate up to and including 30 tons per hour (tph); 

### E =55P0." -40, for process input weight rate above 30tonsper hour (tph). where 

### E =emission rate in pounds per hour (lbihr), and 

### P =process input weight rate in tons per hour (tph).

Page 14of 72

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 

### No. 15 Recovery Furnace 3.4.6 The Permittee shall not cause, let, permit, suffer, or allow the rate of emission from the No. 15 Recovery Furnace (Source Code: RF15) particulate matter (PM) in total quantities equal to or exceeding the allowablerate calculated using the following equations: [391-3-1-.02(2)(e)l(i)] 

### E=4.1F'06', for process input weight rate up to and including 30 tons per hour (tph); 

### E = 55~O.l' -40, for process input weight rate above 30tons per hour (tph). where 

### E = emission rate in pounds per hour (Iblhr), and 

### P =process input weight rate in tons per hour (tph) No. 15Recovery Furnace Smelt Dissolving Tank 3.4.7 The Permittee shall not discharge or cause the discharge into the atmosphere from No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RFI0) any gases which contain total reduced sulfur (TRS) compound emissions in excess of 0.0168 pounds per ton dry black liquor solids (lb/ton dry BLS). [391-3-1-.02(2)(gg)l(iii) and 

### 40 CFR 60.283(a)(4)(subsumed)] 3.4.8 The Permittee shall not cause, let, suffer, permit, or allow emissions fi-om the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RFIO) the opacity of which is equal to or greater than 40 percent (six-minute average). [391-3-1-.02(2)(b)l] 3.4.9 The Permittee shall not cause, let, permit, suffer, or allow the rate of emission from the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RFI0) particulate matter 

### (PM) in total quantities equal to or exceeding the allowable rate calculated using the following equations: [391-3-1-.02(2)(e)l(i)] 

### E =4.1~('~', for process input weight rate up to and including 30 tonsper hour (tph); 

### E =55P0" -40, for process input weight rate above 30 tons per hour (tph). where 

### E =emission rate in pounds per hour (lb/hr), and 

### P =process input weight rate in tons per hour (tph). No. 13Power Boiler 3.4.10 The Pennittee shall fire only fuels containing no more than three percent sulhr,

### by weight, in the No. 13 Power Boiler (SourceCode: PB 13). [391-3-1-.02(2)(g)2]

Page 15of 72Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 Used Oil 3.4.1 1 The Permittee may bun1 on-specification used oil in the No. 7 Lime Kiln and the No. 13 Power Boiler (Source Codes: LK07 and PB13, respectively) provided that the used oil meets the fuel sulfur content limits set forth in Condition Nos. 3.4.3 and 3.4.10. [391-3-1-.02(2)(g)2 and 391-3-1-.02(2)(a)3(i)] Wood Chip Screening System 3.4.12 The Pennittee shall not cause, let, suffer, permit, or allow emissions from the 

### K2 Fines Cyclone (Source Code: AP06) the opacity of which is equal to or greater than 40 percent (six-minute average). [391-3-1-.02(2)(b)l] 3.4.13 The Permittee shall not cause, let, permit, suffer, or allow the rate of emission from the K2 Fines Cyclone (Source Code: AP06) particulate matter (PM) in total quantities equal to or exceeding the allowable rate calculated using the following equations: [391-3-1-.02(2)(e)l (i)] 

### E =4.1poh7, for process input weight rate up to and including 30tonsper hour (tph); 

### E =

### 55P" " -40, for process input weight rate above 30tons per hour (tph). where 

### E =emission rate in pounds per hour (lbh),and 

### P =process input weight rate in tonsper hour (tph). Box Plant 3.4.14 The Pennittee shall not discharge or cause the discharge into the at~nosphere from the Box Plant (Source Code: BP) volatile organic compound (VOC) emissions in an amount equal to or exceeding 100 tons during any twelve consecutive months. [Avoidance of 391-3-1-.02(2)(mm)]


### 3.5 Equipment Standards Not Covered by a Federal or SIP 

### Rule and Not Instituted as an Emission Cap or Operating Limit None applicable.

Page 16of 72International Paper - Savannah 

### Title 

### V Permit Pennit No.: 2631 -051-0007-V-02-0 

### kt% OiB 4-41 

### REQliIKEMENTS FOR TESTING 4.1 

### General Testing Requirements 4.1.1 The Permittee shall cause to be conducted a performance test at any specified emission unit when so directed by the Environmental Protection Division ("Division"). The test results shall be submitted to the Division within 60days ofthe completion ofthe testing. Any tests shall be performed and conducted using methods and procedures that have been previously specified or approvedby the Division. [391-3-1-.02(6)(b)1(i)] 4.1.2 The Permittee shall provide the Division thirty (30) days (or sixty (60) days for tests required by 40 

### CFR Part 63) prior written notice of the date of any performance test(s) to afford the Division the opportunity to witness and/or audit the test, and shall provide with the notification a test plan in accordance with Division guidelines. [391-3-1-.02(3)(a)] 4.1.3 Performance and compliance tests shall be conducted and data reduced in accordance with applicable procedures and methods specified in the Division's Procedures for Testing and Monitoring Sources of Air Pollutants. The methods for the determination of compliance with emission limits listed under Sections 3.2,3.3, 3.4 and 3.5 are as fbllows:
a. Method 1 for the selection of samplepoint location. b. Method 2 for the determination of stack gas velocity and volumetric flow rate.
c. Method 3 for the determination of dry molecular weight; Method 3B for the determination of emission rate correction factor or excess air. d. Method 4 for the determination ofmoisture content in stack gases.
e. Method 5 or Method 17, as applicable, for the determination of particulate matter (PM) emissions. f. Method 6 for the determination of sulfur dioxide (SO2)emissions. g. Method 7 for the determination ofnitrogen oxide (NOx) emissions. h. Method 

### 9 and the Procedures of Section 1.3 for the visual determination of the opacity ofemissiom. i. Method 10for the determination of carbon monoxide 

### (CO) emissions. 

### j. Method 16for the determination oftotal reduced sulfur (TRS) emissions.

Page 17of 72International Paver - Savannah 

### Title V 

### Permit Permit No.: 263 1-051-0007-V-02-0 

### k. Method 19 

### for the determination of sulfur dioxide (SO?) removal efficiency and particulate matter (PM), sulfur dioxide (SO2), and nitrogen oxide (NOx) emission rates. When applicable, Method 19 shall be used to convert the PM, SO2,and NOx concentrations (i.e. grainsldscf for PM, parts per million (ppm) for gaseous pollutants) determined using other methods specified in this section to emission rates (i.e. pounds per million Btu). 

### 1. Method 21 

### for the determination ofvolatile organic compound (VOC) leaks.
m. Method 25 for the determination of total gaseous nonmethane organic emissions as carbon to determine volatile organic compound (VOC) emissions. n. Method 305 or NCASI Method DIIMEOH-94.02, "Methanol in Process Liquids by GCIFID" (Gas ChromatographyIFlame Ionization Detection), for the determination of methanol content, or NCASI Method DIIHAPS-99.01, "Selected HAPS in Condensates by GCIFID", for the determination of methanol, acetaldehyde, methyl ethyl ketone, and propionaldehyde content.
o. Method 308 or NCASI Method CI/SG/PULP-94.03, "Chilled Impinger Test Method for Use on Pulp Mill Sources to Quantify Methanol Emissions", for the determination ofmethanol emissions. p. Method 405.1 of 40 CFR Part 136 

### to determine the soluble BODs in the effluent stream from an open biological treatment unit. q. 

### ASTM Method D4294, "Standard Test Method for Sulfur in Petroleum and Petroleum Products by Energy Dispersive X-Ray Fluorescence Spectrometry", for the determination oftall oil pitch sulfircontent. 40 CFR 63 Subpart MM
r. For the No. 7 

### Lime Kiln, the No. 15 

### Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RF10, respectively), Method 1 

### or 1A 

### for the selection of sampling port location and number oftraverse points. [40 CFR 63.865(b)(5)(i)]
s. For the No. 7 

### Lime Kiln, the No. 15 

### Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RFIO, respectively), Method 2, 2A, 2C, 2D, 2F, or 2G 

### for the determination of stack gas velocity and volumetric flow rate. [40CFR 63.865(b)(5)(ii)]

Page 18of 72International Paper - Savannah 

### Title V Permit PennitNo.: 263 1-051-0007-V-02-0 t. For the No. 7 Lime Kiln, the No. 15 Recovery Furnace, and the No. 

### 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RF10, respectively), Method 3, 3A, or 3B for the determination of oxygen concentration. The gas sample must be taken at the same time and at the same traverse points as the particulate matter (PM) sample. The voluntary consensus standard ANSIIASME PTC 19.10- 198

### 1 -Part 10may be used as an alternative to Method 3B. 140CFR 63.865(b)(3) and 40 CFR 63.865(b)(5)(iii)]

u. For the No. 7 Lime Kiln, the No. 15 Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RFIO, respectively), Method 4 for the determination ofmoisture content of stack gas. [40CFR 63.86S(b)(S)(iv)]
v. For the No. 7 Lime Kiln, the No. 15 Recovery Furnace, and the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Codes: LK07, RF15, and RFIO, respectively), Method 5 or 29 for the determination of the concentration or mass of particulate matter (PM) emitted. Method 17 may be used in lieu of Method 5 or Method 29 if a constant value of 0.009 grams per dscm (0.004 grains per dscf) is added to the results of Method 17 and the stack temperature is no greater than 205°C (400°F). For Methods 

### 5,29, and 17, the sampling time and sample volume for each run must be at least 60minutes and 0.90 dscm (3

### 1.8 dscf), and water must be used as the cleanup solvent instead of acetone in the samplerecovery procedure. [40CFR 63.865(b)(l)]


### w. For the No. 7 Lime Kiln and the No. 15 Recovery Furnace (Source Codes: LK07 and RF15, respectively), the particulate matter 

### (PM) concentration must be corrected to the appropriate oxygen concentration using the procedures of40 CFR 63.865(b)(2). [40 CFR 63.865(b)(2)] For Method 21 and pursuant to the leak checks of40 CFR 63.453(1), the Permittee shall use a span gas concentration of a mixture ofmethane in air at a concentration of approximately, but less than, 10,000 parts per million (ppm) by volume ofmethane. Minor changes in methodology may be specified or approved by the Director or his designee when necessitated by process variables, changes in facility design, or improvement or corrections that, in his opinion, render those methods or procedures, or portions thereof, more reliable. [391-3-1-.02(3)(a)] 4.1.4 Should production rates increase above the rates at which the acceptable performance tests were made, the Division may require that the source be tested for compliance at a higher production rate. [391-3-1-.02(3)(b)]

- -- - Page 19of72

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051 -0007-V-02-0 4.2 Specific 

### Testing Requirements 4.2.1 The Permittee shall conduct performance tests on the following equipment for the specified pollutants: [391-3-1-.02(6)(b)1]

----- --- - 

# 1

NO. 7 Lime Kiln (LK07) Eiculate Matter (PM)
, 

# / Particulate Matter (PM) No. 13 Power Boiler (PB 13) No. 1

### 5 Recovery Furnace (RF15)

4.2.2 

### The Pennittee shall conduct performance tests as specified by the following table and criteria unless otherwise specified by the Division: [391-3-1-.02(6)(b)l] SulfurDioxide (SO2) Nitrogen Oxides (NOx) Particulate Matter (PM) 

# I No. 

### 15 

### Recovery Furnace Smelt Dissolving Tank (RFI0)



### Equipment (Source Code(s)) 

### Particulate Matter 

### (PM) Total Reduced Sulfur(TRS)



### Pollutant -

### Tcsting Frequency

. - ..



### a. Where the results of a performance test which is required annually are less than or equal to 50 percent of the allowable limit, the Permittee may skip the next scheduled performance test; ---- --- i 

### No. 

### 7 Lime Kiln (LK07) No. 13 Power Boiler (PB13) No. 1 5 

### Recovery Furnace (RF1 5) No. 15

### Recovery Furnace Smelt Dissolving Tank (RFI0)

b. Where the results of a performance test which is required annually are greater than 85 percent of the allowable limit, the Permittee shall begin testing on a semiannual basis with the next performance test due approximately six months following that test. 

### If any subsequent test is less than or equal to 

### 85 percent of the allowable limit, the Permittee shall resume annual testing. Theprovisions of Condition No. 4.2.2.a do not apply until the results of two consecutive tests are less than or equal to 

### 85 percent of the allowable. -- - --- --a 

### PM - 

### annual PM -

### annual SO2-

### annual NOx -

### annual 

### PM -

### annual 

### PM - 

### annual 

### .IRS -

### biennial

Page 20 of72International Pa~er -Savannah Title V Permit Pennit No.: 2631-05 1-0007-V-02-0
c. Where the results of a performance test which is required biennially are greater than 85 percent of the allowable limit, the Permittee shall begin testing on an annual basis with the next performance test due approximately twelve months following that test. If any subsequent test is less than or equal to 85 percent of the allowable limit, the Permittee shall resume biennial testing. d. Data from these tests shall be used to establish the operational parameters as specified in Condition No. 6.1.7. Data from a previously approved performance test which demonstrated compliance with the applicable emission limit may be used to establish the operational parameters in lieu of the most recent perfonnance tests as long as that previous performance test is representative of cusrent operations of the emission unit and was conducted during the five years prior to the most recent performance test or the life ofthis permit, whichever is shorter.
e. As required by Condition No. 6.1.7.d.xii, the Permittee shall submit a list of all the current operational parameters established in accordance with Condition No.4.2.2 for the purpose of reporting under Condition No. 6.1.7 with the quarterly report required by Condition No. 6.1.4. This list shall include all operation parameters required to be monitored and the current operating range for each operational parameter. NOTE: No. 13 Power Boiler (Source Code: PB 13) Compliance Testing -The sulhrdioxide (SO2) perfonnance test on the No. 13 Power Boiler shall be conducted while feeding the facility-wide NCG collection system to the boiler and while firing coal at its maximum firing rate. The performance test shall consist of 24 consecutive one-hour runs. Compliance with Condition No. 3.3.7.b.v shall be determined from any consecutive three-hour period during the perfonnance test. Cluster Rule 4.2.3 The Biological Treatment System (Source Code: AP18) serves as the backup control device for the Pulping Process Condensates (Source Code: PPCC). During times when the Biological Treatment System is used to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18, thePermitteeshal1: [40CFR 63.4530') and 40 CFR 63.457(1)]
a. Conduct a performance test for total hazardous air pollutant (HAP) mass on the Biological Treatment System within seven days of a failure of the Steam Stripper (SourceCode: AP17). Total HAP mass shall be measured as acetaldehyde, methanol, methyl ethyl ketone, and propionaldehyde and shall be calculated using the procedures in 40 

### CFR 63.457(1). b. 

### If the Permittee is using the Biological Treatment System to demonstrate compliance as a supplement to the Steam Stripper, conduct a perfonnance test on the Biological Treatment System within 45 days after the beginning of each quarter.
c. Calculate the mass flow rate of total HAP or methanol using the procedures of 40 CFR 63.457Cj). Page 21 of 72International Paver -Sava~ah 

### Title V 

### Permit Permit No.: 2631-051-0007-V-02-0 d. Conduct the annual ht quarter performance test for total HAP mass. Total HAP mass shall be measured as acetaldehyde, methanol, methyl ethyl ketone, and propionaldehyde.
e. If condensates are treated in the Biological Treatment System in additional calendar quarters, conduct quarterly performance tests for total HAP or methanol for the remaining quarters of each calendar year. The same r-value (the ratio of the sum of acetaldehyde, methyl ethyl ketone and propionaldehyde to methanol mass) from the first quarter's test or from the performance test conducted in accordance with Condition No. 4.2.3.a may be used for subsequent quarterly tests during a given year. f. During these performance tests, record the values of the parameters recorded in accordance with Condition No. 5.2.6. If compliance with Condition No. 3.3.17 is demonstrated, these values shall be used to establish a site-specific operating range for treatment ofthe pulping condensates. 4.2.4 When the Biological Treatment System (Source Code: AP18) is used to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18, a mass emission rate test may be conducted using the procedures set forth in 40 CFR 63.453(p) any time the monitoring parameters set forth in Condition No. 5.2.6.b fall outside the operating ranges determined in accordance with Condition No. 4.2.3.f and the excursion is not attributable to startup, shutdown, or malfunction (SSM). [40CFR 63.453(p)] 4.2.5 For the purposes of complying with Condition No. 4.2.4, Condition Nos. 4.1.2 and 4.2.6 shall not apply. [391-3-1-.02(6)(b)1] 4.2.6 Within 180 days of the issuance of this permit, the Permittee shall conduct a perfonnance test for all emissions sources subject to the limits in 40 CFR 63.446 as specified in Condition Nos. 3.3.14 and 3.3.17. The test shall be conducted over a maximum 15-day period unless otherwise specified by the Division. The Permittee shall repeat the performance test every five years. [40CFR 63.7(a)(3), 40 CFR 63.457, 391-3-1-.02(3), and 391-3-1-.03(2)(c)] 4.2.7 The Pennittee shall provide the Division 60 days prior written notice of the date of any performance test(s) required by 40 CFR Part 63 to afford the Division the opportunity to witness and/or audit the test, and shall provide with the notification a test plan in accordance with Division guidelines. [40CFR 63.7(b)]

Page 22 of 72

### TitleV 

### Permit InternationalPaper - Savannah
-- Permit No.: 2631-05 1-0007-V-02-0 

### P14Kf

### 5.0 MEQI2REMENTS FOR MONITORING (Related to Data Collection) 5.1 

### General Monitoring Requirements 5.1.1 Any continuous monitoring system required by the Division and installed by the Permittee shall be in continuous operation and data recorded during all periods of operation of the affected facility except for continuous monitoring system breakdowns and repairs. Monitoring system response, relating only to calibration checks and zero and span adjustments, shall be measured and recorded during such periods. Maintenance or repair shall be conducted in the most expedient manner to minimize the period during which the system is out of service. [391-3-1-.02(6)(b)l] 5.2 

### Specific Monitoring Requirements 5.2.1 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated pollutants on the following equipment. Each system shall meet the applicable performance specification(s) ofthe Division's monitoring requirements. [391-3-l-.O2(6)(b)l and 40 CFR 70.6(a)(3)(i)]
a. Opacity, Total Reduced Sulfur (TRS), and Oxygen for the No. 7 Lime Kiln (Source Code: LK07) [40CFR 63.864(d) and 391-3-1-.02(2)(b)l; 40 CFR 60.284(a)(2) and 391-3-1-.02(2)(gg)l(iv) (subsumed)] b. Opacity, Total Reduced Sulfur (TRS), Nitrogen Oxides 

### (NOx), and Oxygen for the No. 15Recovery Furnace (Source Code: RF15) [40 CFR 63.864(d), 40 CFR 60.48b(a) 40 CFR 60.49b(f), 40 CFR 60.284(a)(1), and 391-3-1-.02(2)(b)l (subsumed); 40 CFR 60.284(a)(2) and 391 -3- 1-.02(2)(gg) 1

### (i)(II); 40 CFR 52.211
c. Opacity for the No. 13Power Boiler (Source Code: PB13) 140CFR 60.45(a) and 391-3-1-.02(2)(d)3] 5.2.2 The Permittee shall install, calibrate, maintain, and operate a system to continuously monitor and record the indicated parameters on the following equipment. Where such performance specification(s) exist, each system shall meet the applicable performance specification(s) of the Division's monitoring requirements. [391-3-1 -.O2(6)(b)1and 40 CFR 70.6(a)(3)(i)]
a. Scrubbant Type (Fillback or Water), Scrubbant Flow Rate, and Fan Motor Current for the No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15) [40CFR 52.21,40CFR 63.864(e)(10)&(13), 40 CFR Past 64 and 40 CFR 60.284(b)(2) (subsumed)]

Page 23 of 72International Pa~er - Savannah Title V Permit Permit No.: 2631-051-0007-V-02-0 

### b. Process Wastewater Feed Rate (condensate flow), Steam Feed Rate (steam flow), Process Wastewater Column Feed Temperature (condensate feed temperature), and Stripper Pressure for the Steam Stripper (Source Code: AP17). Using the equations in Condition No. 6.1.7.c.vii, the Steam-to-Condensate Ratio shall be calculated and recorded continuously. [40 CFR 63.453(g)(1) through (3) and 40 CFR 63.453(m)]


### c. Pressure Drop and Scrubbant Flow Rate for the White Liquor NCG Scrubber (Source Code: WLSI). [Avoidance of40 CFR 52.2

### 11 d. Gas Stream Flow in each bypass line in the closed-vent system. A 

### flow indicator on each bypass line shall record the presence of gas stream flow in the bypass line at least once every fifteen minutes. [40CFR 63.450(d)(l) and 40 CFR 63.454(e)] 5.2.3 The Permittee shall install, calibrate, maintain, and operate monitoring devices for the measurement of the indicated parameters on the following equipment. Data shall be recorded at the frequency specified below. Where such performance speciiication(s) exist, each system shall meet the applicable performance specification(s) of the Division's monitoring requirements. [391-3-1-.02(6)(b)l and 40 CFR 70.6(a)(3)(i)]
a. Scrubbant flow rate for the No. 7 Lime Kiln Dust Scrubber (Source Code: AP03). The average ofthe data from each eight-hour shift ofoperation shall be recorded. [Avoidance of 40 CFR 52.21, 40 CFR Part 64 391-3-1-.02(2)(b)1, and 391-3-1-.02(2)(e)l (i)] b. Secondary Current and Secondary Voltage for each electrically isolatable section (bus section) of the No. 7 Lime Kiln Electrostatic Precipitator (ESP), the No. 15Recovery Furnace ESP, and the No. 13 Power Boiler ESP (Source Codes: APOI, AP14, and AP07, respectively). The arithmetic average value of each parameter shall be recorded for each eight-hour shift of operation. The Average Total Secondary Power for each ESP shall be calculated from the arithmetic average values of Secondary Current and Secondary Voltage and recorded for each shift ofoperation. [391-3-1-.02(6)(b)l and 40 CFR Part 641 5.2.4 The Permittee shall obtain an analysis of each shipment of tall oil pitch to be fired in the No. 7 Lime Kiln (Source Code: LK07) for sulfur content, moisture content, and Gross Calorific Value (GCV). The sample shall be acquired using ASTM D140, "Standard Practice for Sampling Bituminous Materials". The sample shall be analyzed for sulfur content using the method prescribed in 

### Condition No. 4.1.3.q and for moisture content and GCV using the procedures of Section 12.5.2.2 in Method 19 of the Division's Procedures for Testing and Monitoring Sources of Air Pollutants. 

### [391-3-1-.02(2)(g)2 and 391-3-1-.02(2)(b)l]

Page 24 of 72International Paper -- Savannah 

### Title 

### V Permit Permit No.: 2631-051-0007-V-02-0 5 

### 2.5 For each day of operation or portion of day of operation, the Permittee shall obtain an analysis of a gross sample of as-bunkered coal to be combusted in the No. 13 Power Boiler (Source Code: PB13) for sulfur content, moisture content, and Gross Calorific Value (GCV). The sample shall be acquired and analyzed using the procedures of Section 12.5.2.1 in Method 19 of the Division's 

### Procedures for Testing and 

### Monitoring Sources of Air Pollutants. The Permittee may use Test Method ASTM D5865, "Standard Test Method for Gross Calorific Value of Coal and Coke", for determining GCV of the samplein lieu of the method specified in Method 19. [40CFR 52.21,40 CFR 60.45(b)(2), 391-3-1-.02(2)(g)1&2, and 391-3-1-.02(6)(b)l] 5.2.6 The Permittee shall monitor and record the following parameters to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18:
a. Daily composite stripper influent for methanol and total condensate influent flow rate for the Steam Stripper (SourceCode: AP17). [40 CFR 63.453(m)] b. When the Biological Treatment System (Source Code: AP18) is used to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18, [40CFR 63.453(j)(2)] 

### i. Daily composite foul condensate tank influent for methanol and total condensate flow rate.

. . 11. Daily COD-to-horsepower ratio (CODIhp). 5.2.7 Each enclosure and closed-vent system used to comply with 40 CFR 63.450(a) shall comply with the following requirements: [40CFR 63.453(k)] a. For each enclosure opening, a visual inspection of the closure mechanism specified in 40 CFR 63.450(b) shall be performed at least once per month, with at least fourteen days elapsed time between inspections, to ensure the opening is maintained in the closed position and sealed. 

### b. Each closed-vent system required by 40 CFR 63.450(a) shall be visually inspected at least once per month, with at least fourteen days elapsed time between inspections, and at other times as requested by the Division. The visual inspection shall include inspection of ductwork, piping, enclosures, and connections to covers for visible evidence ofdefects.


### c. For positive pressure closed-vent systems or portions of closed-vent systems, demonstrate no detectable leaks as specified in 40 CFR 63.450(c) measured initially and annually by the procedures in 40 CFR 63.457(d). 

### d. Demonstrate initially and annually that each enclosure opening is maintained at negative pressure as specified in 40 CFR 63.457(e).

Page 25 of 72InternationalPa~er - Savannah 

### Title V 

### Permit Permit No.: 263 1-051 -0007-V-02-0


### e. The valve or closure mechanism specified in 40 CFR 63.450(d)(2) shall be inspected at least once per month, with at least fourteen days elapsed time between inspections, to ensure that the valve ismaintained in the closed position and the emission point gas stream isnot diverted through the bypass line. 

### f. If an inspection required by paragraphs (a) through (e) of this Condition identifies visible defects in ductwork, piping, enclosures, or connections to covers required by 40 CFR 63.450, or if an instrument reading of 500 parts per million by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions shall be taken as soon as practicable. i. A 

### first effort to repair or correct the closed-vent system shall be made as soon as practicable but no later than five calendar days after theproblem isidentified.

. . 

### 11. The repair or corrective action shall be completed no later than fifteen calendar days after the problem is identified. Delay of repair or corrective action is allowed if the repair or corrective action is technically infeasible without a process unit shutdown or ifthe Permittee determines that the emissions resulting from immediate repair would be greater than the emissions likely to result from delay of repair. Repair of such equipment shall be completed by the end of the next process unit shutdown. 5.2.8 Each pulping process condensate closed collection system used to comply with 40 CFR 63.446(d) shall comply with the following requirements: [40 CFR 63.453(1)]
a. 

### Each pulping process condensate closed collection system shall be visually inspected at least once per month, with at least fourteen days elapsed time between inspections, and shall comply with the inspection and monitoring requirements in 40 CFR 63.964, except the inspection and monitoring requirements for closed-vent systems and control devices specified in 40 CFR 63.964(a)(2). Closed-vent systems and control devices shall comply with the inspection and monitoring requirements specified in 40 CFR 63.453(a) and 

### (k). b. Each condensate tank used in the closed collection system shall be operated with no detectable leaks as specified in 40 CFR 63.446(d)(2)(i) measured initially and annuallyby theprocedures specified in 40 CFR 63.457(d).
c. 

### If an inspection required by this section identifies visible defects in the closed collection system, or if an instrument reading of 500parts per million (ppm) or greater above background is measured, then corrective actions specified in 40 CFR 63.964(b) shall be taken. 5.2.9 For each day of operation or portion of day of operation, the Permittee shall check and record the status ofthe high level probe on the K2 Fines Cyclone (SourceCode: AP06). [Avoidance of40 CFR 52.21, 391-3-1-.02(6)(b)l, and 40 CFR 70.6(a)(3)(i)]

Page 26 of 72International Paper - Savannah Title 

### V Permit Pennit No.: 263 1-05 1-0007-V-02-0 5.2.1

### 0 For the No. 7 Lime Kiln and the No. 15 Recovery Furnace (Source Codes: LK07 and RF15, respectively), each continuous opacity monitoring system (COMS),referenced in Condition Nos. 5.2.1.a and 5.2.1.b, shall meet the following criteria: [40 CFR 63.864jd)l
a. Each COMS must be operated in accordance with the provisions of 40 CFR 63.6(11) and 40 CFR 63.8. b. Each COMS must complete a minimum of one cycle of sampling and analyzing for each successive ten-second period.
c. Each COMS must complete a minimum of one cycle of data recording for each successive six-minuteperiod. d. The COMS data must be reduced as specified in 40 CFR 63.8(g)(2). 5.2.11 For the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RFlO), the continuous parameter monitoring system (CPMS),referenced in Condition No. 5.2.2.a, shall meet the following criteria: [40CFR 63.864(e)(lO) and 40 CFR 63.864(ej(13 j]
a. The CPMS must analyze and record the scrubbant flow rate and the fan motor current at least once every successive fifteen-minute period using the procedures in 40 CFR 63.8(c). b. The CPMS used for the continuous measurement of the scrubbant flow rate must be certified by the manufacturer to be accurate within *0.5 percent of the design scrubbant flow rate.
c. The CPMS used for the continuous measurement of the fan motor current must be certified by the manufacturer tobe accurate within *5 percent of an amp. 5.2.12 The following pollutant specific emission units 

### (PSEU) are subject to the Compliance Assurance Monitoring (CAM) Rule in 40 CFR 64.



## INo. 15Recovery Furnace Smelt Dlssolvlng Tank (WlO) 

## I Scrubber

### (%' 15) 

## -1 

# PMI EmissionBait (Source Code) No 7 L~me K~ln (LK07) No I5 Recovery Furnace (RF15) No 13Power Boder (PB13) 

## 1No. 15Recovery Furnace Smelt Dissolving Tank (RFIO) 

## I Scrubber (AP15) 

## I TRS 

## I 

## I Lime Conveyor System (OPG8) 

## I Scrubber (AP03) 

## 1 PM 

## I Control

### Device (Source

### Code)

Electrostatic Precipitator (APOI) Electrostatic Precipitator (AP 14) Electrostatic Preciv~tator (AP07)

Permit conditions in this permit for the PSEU(sj listed above with regulatory citation 40 CFR 70.6(a)(3)(i) are included for the purpose of complying with 40 CFR 64. In addition, the Permittee shall meet the requirements, as applicable, of 40 CFR 64.7, 40 CFR 64.8, and 40 CFR 64.9. [40 CFR 641 PoUutane PM PM PM

- -- Page 27 of72

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 5.2.13 The Permittee shall comply with the performance criteria listed in the table below for the particulate matter 

### (PM)emissions fiom theNo. 

### 7 Lime Kiln (SourceCode: LK07). [40 CFR 64.6(c)(l)(iii)]

*riormnnre Criteria Indicator No. 1 M.4ta)PN 

### -- Opacity Data Representativeness Opacity is measured using a Continuous [64.3(b)il

### )I Opacity Monitoring System (COMS).
I

. Verification of O~erational Status (newimoditied monitoring Not Applicable euui~~nent only) COMS is calibrated in accordance with '. QAIQC Practices and Criteria the requirements of Performance [64.3(b)(3)] Soecification 1.
). Monitoring Frequency l64.3(b)(4)1 Indicator

### KO.2 ESP 'l'ntsl Secondary Power Average Total Secondary Power is calculated tiom the arithmetic average values of secondary current and secondaly voltage.
Not Applicable

Annual calibration in accordance with manut:dcturer'srecommendations.
Continuous Once per 8-hour shift Data monitored by the Data Acquisition Data monitored by the Data Collection Data Collection Procedures System (DAS) and recorded in the System (DCS) and recorded in the [64.3(b)(4)1 Process hfo~mation (PI) System. Process Infomlation (Pi) System. Averaging Period 6 minutes Onceper 8-hour shift [h4.3(b)(4)] 5.2.14 The Pennittee shall comply with the performance criteria listed in the table below for the particulate matter (PM) emissions from the No. 15 Recovery Furnace (Source Code: RF15). [40CFR 64.6(c)(l)(iii)] ndicatarNo. 2 :SPTotalSecondary Power --.----- Performance Criteria [64.Wt3)1 torNo. 1 tY

D. Monitoring Frequency 

# I IOJXh)(4)l 11 

### E Average Total Secondary Power 1s calculated from the arithmetic average values of secondary current and seconda~y voltage.
Not Applicable I 

### 1 A. Data Representativeness [64.3(b)(1)] B. Veritication of Opedona1 Status (ncwl~nodified monitoring equipment only) [64.3(b)(2)1 C. QAJQC Practices and Criteria

Continuous Indica Opacil ..-- P.. .--- Opacity is measured using a Continuous Opacity Monitoring System (COMS).
Not Applicable

Once per 8-hour shift [64.3(b)(3)] COMS is calibrated in accordance with .,.- -L-n-L- Annual calibration in accordance with

~,> Data Collection Procedures [()4.3(b)(4)1

Page 28 of72 Averaging Period [04.30~)(4)1 Data monitored by the Data Acquisition System (DAS) and recorded in the Process Information (PI) System. Data monitored by the Data Collection System (DCS) and recorded in the Process ~nfonnation (PI) System. 6 minutes Once per 8-hour shiftInternationalPaper - Savannah 

### Title V 

### Permit Permit No.: 2631-051-0007-V-02-0 5 

### 3 IS The Permittee shall comply with the performance criteria listed in the table below for the particulate matter (PM) emissions from theNo. 

### 13Power Boiler (Source Code: PB13). [40CFR 64.6(c)(l)(iii)]

4. Data Representativeness Opacity is measured using a Continuous calculated from the arithmetic average [64.3(b)(1)I Opacity Monitoring System (COMS). values of secondary current and Pcrformancc Criteria Indkntor No. 1 W.4(alC3)1 

### ---- Opacitylsecondary voltage. B. Verification of Overational lndicrtorNo. 1 ESPTotal Secondary Power 

### - Average Total Secondary Power la

Not Applicable Status (newlmodified moriitoring equipment only) 164.3(bW2)1 Not Applicable

D. Monitoring Frequency [64.3(b)(4)1 C. QA/QC Practices and Criteria [64.3(b)(3)1 Continuous Onceper 8-hour shift COMS is calibrated in accordance with the requirements of Performance Snecification 1. Annual calibration in accordance with manufacturer's recommendations.

6 minutes Data Collection Procedures [64.3(b)(4)1 Onceper 8-hour shift 5.2.16 The Permittee shall comply with the performance criteria listed in the table below for the particulate matter 

### (PM) emissions fi-om the No. 15 Recovery Furnace Smelt Dissolving 1Data monitored by the Data Acquisition System (DAS) and recorded in the Process Information (PI) System.

Tank (Source Code: 

### RF10). [40 

### CFR 64.6(c)(l)(iii)] Data ~nonitored by the Data Collection System (DCS) and recorded in the Proccss Information (PI) System

Indicator Fan Moto~ Scrubbant flow rate is measured by a

I B. Verification of O~erational A. Data Representativeness [64.3(b)(111 magnetic flow meter. Minimum acceptableaccuracy of i0.5percent of the design scrubbant flow rate. Fan motor current is measured by a fan amp meter. Minimum acceptable accuracy ofi5 percent of full scale reading for phase current input and i- I percent of full scale reading for analog current output. Status (newlmodified monitoring equipment only) [64.3(b)(2)] Not Applicable Not Applicable
C. QNQC Practices and Criteria Per MACT QAIQC Plan for flow; must Per MACTQNQC Planfor current [64.3(b)(3)1 be at least annual calibration D. Monitoring Frequency [64.3@)(4)1 

# I Continuous 

# I Continuous

3 hours Data Collection Procedures [64.3(b)(4)1 3 hours

Page 29 of 72 Data monitored by the Data Collection System (DCS) and recorded in the Process Information (PI) Svstem. Data monitored by the Data Collection System (DCS) and recorded in the Process Information (PI)Svstem.

### Title V Permit International Paper -Savannah Permit No.: 263 1-05 1-0007-V-02-0 5.2.1

### 7 The Permittee shall comply with the performance criteria listed in the table below for the total reduced sulfur (TRS) emissions from the No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RF10). [40 CFR 64.6(c)(l)(iii)]
ndicator 

### KO. 1 krahhant Flow Rate ndirator No. 2 Tan Motor Current banmotor current is 

# 7- [ndicatorNo.3 Fillhack Valve Position

4. Data Representativeness [64.3(b)(111

B. Veritication ofOperational Status (newlmodified monitoring equipment only)

D. Monitoring Frequency 164.3(bi(4)1 Scrubbant flow rate is measured by a magnetic flow meter. Minimum acceptable accuracy of i0.5 percent of the design scrubbant flow rate.

[64.3(bWiI C. QNQC Practices and Criteria [64.3(b)(3)1 

# I Continuous Not Applicable

Continuous measured by a fan amp meter. Minimum acceptable accuracy of *5 percent of full scale reading forphase current input and *I percent of full scale reading for

Per QtL'QC for flow; must be at least annual calibration Continuous Scrubbant type (fillback 01 water) is determined using the position of the tillback valve. analog current output.
Not Applicable Not Applicable

Per MACT QA/QC Plan for cun.cnt

3 hours Annual preventative maintenance



### . ~ ,~ > Data Collection Procedures [64.3(b)i4)1

3 hours 3 hours Data monitored by the Data Collection System (DCS) and recorded in the Process Information (PI) System.



### 5.2.18 The Permittee shall comply with the performance criteria listed in the table below for the particulate matter 

### (PM) emissions from the Lime Conveyor System (SourceCode: 

### OPG8). [40CFR 64.6(c)(l)(iii)] I I Data ~nonitored by the Data Collection System (DCS)and recorded in the Proccss Infonnatiorl (PI) System. Data monitored by the Data Collection System (DCS) and recorded in the Process lnfonnation (PI) System.

A. Data Representativeness [64.3(b)(l )I B. Verification of Operational Status (newlmodified monitoring equipment only) [64.3(b)(2)1 C' QAiQC Practicesand [64.3@)(3)1 D. Monitoring Frequency [64.3@)(4)1 Data Collection Procedures [64.3@)(4)1 Averaging Period [64.3ib)i4)1 Indicator

### NO.1 SctuhhsntFlow Rate Scrubbant flow rate is measured by a magnetic flow meter. Minimum acceptable accuracy of i0.5 percent of the design scrubbant flow rate.
Not Applicable

Annual calibration in accordance with 1nanufacturcr.s recommendations.
Onceper 8-hour shift Data monitored by the Bailey Data Collection System (DCS) and recorded in the Process Infonnation (PI) System. (Becausethe monitoring interface is exception based, data is recorded in the PI based on when the values change.) Onceper 8-hour shift Page 30of 72

### Title 

### V Permit International Paper -- Savannah Pennit No.: 263 1-051 -0007-V-02-0 

### PART 49-0 

### RECORD KEEPING AND REPORTING REQUIREMENTS 6.1 

### General Record Keeping and Reporting Requirements 6.1.1 Unless otherwise specified, all records required to be maintained by this Permit shall be recorded in a permanent form suitable for inspection and submission to the Division and to the EPA. Therecords shall be retained for at least five years following the date of entry. [391-3-1-.O2(6)(b)1(i) and 40 CFR 70.6(a)(3)] 6.1.2 In addition to any other reporting requirements of this Permit, the Permittee shall report to the Division in writing, within seven days, any deviations from applicable requirements associated with any malfunction or breakdown of process, fuel burning, or emissions control equipment for aperiod of four hours or more which results in excessive emissions. The Permittee shall submit a written report that shall contain the probable cause of the deviation(s), duration of the deviation(s), and any corrective actions or preventive measures taken. (391-3-1-.02(6)(b)l (iv), 391-3-1-.03(1O)(d)l(i),and 40 CFR 70.6(a)(3)(iii)(B)] 6.1.3 The Permittee shall submit written reports of any failure to meet an applicable emission limitation or standard contained in this pennit andlor any failure to comply with or complete a work practice standard or requirement contained in this pennit which are not otherwise reported in accordance with Condition No. 6.1.4 or Condition No. 6.1.2. Such failures shall be determined through observation, data from any monitoring protocol, or by any other monitoring which is required by this permit. The reports shall cover each semiannual period ending June 30 and December 

### 31 of each year, shall be postmarked by the 30th day following the end of each reporting period, July 30 and January 30, respectively, and shall contain the probable cause of the failure(s), duration of the failure(s), and any corrective actions or preventive measures taken. [391-3-l -.O3(lO)(d)l.(i) and 40 CFR 70.6(a)(3)(iii)(B)] 6.1.4 The Permittee shall submit a written report containing any excess emissions, exceedances, andlor excursions as described in this permit and any monitor 

### malfunctions for each quarterly period ending March 31, June 30, September 30, and December 31 of each year. All reports shall be postmarked by the 30th day following the end of each reporting period, April 30, July 30, October 30, and January 30, respectively. In the event that there have not been any excess emissions, exceedances, excursions or malfunctions during a reporting period, the report should so state. Otherwise, the contents of each report shall be as specified by the Division's Procedures for Testing and Monitoring Sources ofAir Pollutants and shall contain the following: [391-3-1-.02(6)(b)l and 40 CFR 70.6(a)(3)(iii)(A)]
a. A summary report of excess emissions, exceedances and excursions, and monitor downtime, in accordance with Section 1.5(c) and (d) of the above referenced document, including any failure to follow required work practice procedures. b. Total process operating time during each reporting period.
Page 31 of 72Title 

### V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0
c. The magnitude of all excess emissions, exceedances and excursions computed in accordance with the applicable definitions as determined by the Director, and any conversion factors used, and the date and time of the commencement and completion of each timeperiod ofoccurrence. d. Specific identification of each period of such excess emissions, exceedances, and excursions that occur during startups, shutdowns, or malfunctions of the affected facility. Include the nature and cause of any malfunction (if known), the corrective action taken or preventive measures adopted.
e. The date and time identifying each period during which any required monitoring system or device was inoperative (including periods of malfunction) except for zero and span checks, and the nature ofthe repairs, adjustments, or replacement. When the monitoring system or device has not been inoperative, repaired, or adjusted, such information shall be stated in thereport. f. Certification by a Responsible Official that, based on information and belief formed afier reasonable inquiry, the statements and information in the report are true, accurate, and complete. 6.1.5 Where applicable, the Permittee shall keep the following records: [391-3-l-.O3(lO)(d)l(i) and 40 CFR 70.6(a)(3)(ii)(A)]
a. Thedate, place, and time of sampling ormeasurement; b. Thedate(s) analyses wereperformed;


### c. The company or entity that performed the analyses; d. The analytical techniques ormethods used;
e. Theresults of such analyses; and f. The operating conditions as existing at the time of sampling or measurement. 

### 6.1.6 The Permittee shall maintain files of all required measurements, including continuous monitoring systems, monitoring devices, and performance testing measurements; all continuous monitoring system ormonitoring device calibration checks; and adjustments and maintenance performed on these systems or devices. These files shall be kept in a permanent form suitable for inspection and shall be maintained for a period of at least five years following the date of such measurements, reports, maintenance, and records. [391-3-l-.03(IO)(d)l (i) and 40 CFR 70.6 (a)(3)(ii)(B)]

Page 32 of 72International Paver - Savannah Title 

### V Permit Permit No.: 263 1-051-0007-V-02-0 6.1. For the purpose of reporting excess emissions, exceedances or excursions in the report required in Condition No. 6.1.4, the following excess emissions, exceedances, and excursions shall be reported: [391-3-1-.02(6)(b)1 and 40 CFR 70.6(a)(3)(i)]
a. Excess emissions: (means for the purpose of this Condition and Condition No. 6.1.4, any condition that is detected by monitoring or record keeping which is specifically defined, or stated to be, excess emissions by an applicable requirement) No. 7 Lime Kiln i. Any twelve-hour average total reduced sulfur (TRS) concentration from the No. 7 Lime Kiln (Source Code: LK07), measured and recorded in accordance with Condition No. 5.2.1.a,in excess of 8 parts per million (ppm) on a dry basis (corrected to 10 percent oxygen). The twelve-hour averages shall be the two consecutive periods of each operating day. [40CFR 60.284(d)(2),40 CFR 60.284(~)(1), and 391-3-1 -.02(2)(gg) l(iv) (subsumed)] No. 15 Recovery Furnace



### .. 11.

. . . Ill.

iv. Any twelve-hour average total reduced sulfur (TRS) concentration from the No. 15 Recovery Furnace (Source Code: RF15), measured and recorded in accordance with Condition No. 5.2.1.b, in excess of 5 parts per million (ppm) on a dry basis (corrected to 8 percent oxygen). The twelve-hour averages shall be two consecutive periods of each operating day. [40CFR 60.284(d)(l)(i),40 CFR 60.284(~)(1), and 

### 391-3-1-.02(2)(gg)l(i)(lI)] Any six-minute period during which the average opacity from the No. 15 Recovery Furnace (Source Code: RF15), measured and recorded in accordance with Condition No. 5.2.I .b, is in excess of 20 percent, except for one six-minute average per hour ofnot morethan 27 percent opacity. [40CFR 60.49b(h)(l)&(3), 40 CFR 60.284(d)(l)(ii) (subsumed), and 391-3-1-.02(2)(b)l (subsumed)] Any 24-hour period during which the average nitrogen oxide (NOx) concentration from the No. 15 Recovery Furnace (Source Code: RFlS), measured and recorded in accordance with Condition No. 5.2.1.b, is in excess of 100 parts per million (ppm) on a dry basis (corrected to 8percent oxygen). [40CFR 52.211 No. 13 Power Boiler


### v. Any six-minuteperiod during which the average opacity from the No. 13 Power Boiler (Source Code: PB13), measured and recorded in accordance with Condition No. 5.2.1.c, is in excess of 20 percent, except for one six-minute average per hour of not more than 27 percent opacity, except during periods of startup, shutdown, ormalfunction. [40CFR 60.45(g)(1) and 391-3-1-.02(2)(d)3] Page 33 of 72Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 vi. Any 30-day rolling period during which the average sulhr dioxide (SO2) emissions from the No. 13 Power Boiler (Source Code: PB13), calculated in accordance with Condition No. 6.2.6.a, are in excess of the following applicable value: [40CFR 60.45(g)(2) and 391 -3-1-.02(2)(g)l] A. When firing solid fossil fuel or solid fossil fuel and wood residue, 1.2pounds per million Btu (lb/MMBtu); B. When firing liquid fossil fuel or liquid fossil fuel and wood residue, 0.80 pounds per million Btu (lb/MMBtu); or 

### C. When firing different fossil fuels simultaneously in any combination, the prorated emission limitation calculated in accordance with Condition No. 3.3.7.b.iii. Cluster Rule vii. For the Steam Stripper (Source Code: AP17), any periods during which the time of excess emissions (including periods of startup, shutdown, or malfunction) divided 

### by the total process operating time in a semi-annual reporting period exceeds 10 percent. [40CFR 63.446(g)] viii. Any periods during which the time of excess emissions (excluding periods of startup, shutdown, or malfunction) divided by the total process operating time in a semi-annual reporting period exceeds the following levels: [40

### CFR 63.443(e)] A. 1percent for the No. 13 Power Boiler (Source Code: PB13) (primary) and the No. 7 Lime Kiln (Source Code: LK07) (backup) that are used to reduce the total HAP emissions from the LVHC systems (Source Codes: LVH1 and LVH2); B. 4 percent for control devices used to reduce the total HAP fiom the HVLC system (Source Code: HVLC); and C. 4 percent for control devices used to reduce the total HAP emissions from both the LVHC and HVLC systems (Source Codes: LVH1, LVH2, and 

### HVLC). ix. Any fifteen-day rolling period of process operation during which the Pulping Process Condensates (Source Code: PPCC) from equipment systems listed in Condition No. 3.3.13, collected in accordance with Condition No. 3.3.14, in total contain less than a total hazardous air pollutant (HAP) mass of 7.2 pounds oftotal HAP per ton ofoven-dried pulp (lblton ODP). [40CFR 63.446(~)(3)]

Page 34 of72Title V Permit InternationalPaper - Savannah Permit No.: 2631-051-0007-V-02-0


### x. Any fifteen-day rolling period of process operation during which the treatment of the Pulping Process Condensates (Source Code: PPCC) from equipment systems listed in Condition No. 3.3.13, collected in accordance with Condition No. 3.3.14, removes less than 6.6 pounds of total hazardous air pollutant (HAP) per ton of oven-dried pulp (Iblton ODP). [40CFR 63.446(e)(4)] b. Exceedances: (means for the purpose of this Condition and Condition No. 6.1.4, any condition that is detected by monitoring or record keeping that provides data in terms of an 

### emission limitation or standard and that indicates that emissions (or opacity) do not meet the applicable emission limitation or standard consistent with the averaging period specified for averaging the results ofthe monitoring) Electric Output for Sale 

### i. Any twelve-month rolling period during which more than one-third of the potential electric output capacity and 25 MW electrical output is supplied to any utility power distribution system for sale from the No. 15 Recovery Furnace (Source Code: RF 15)orthe No. 13Power Boiler (Source Code: PB13). [Avoidance of40 CFR 60 Subpart Da and Avoidance of 40 CFR 72 Subpart A] Fuel

. . 11. 

### Any period ofprocess operation during which the sulfurcontent of the fuel fired in the No. 7 Lime Kiln (Source Code: LK07) or the No. 13 Power Boiler (Source Code: PB13) exceeds 3 percent sulfur,by weight. [391-3-1

### -.02(2)(g)2] Poultry Lines

... 

### 111. Any twelve-month rolling period of process operation during which the volatile organic compound (VOC) emissions from the Poultry Line (Source Code: PL), calculated in accordance with Condition No. 6.2.32, are equal to or in excess of 10tons. [Avoidance of40 CFR 52.211 iv. Any twelve-month rolling period of process operation during which the volatile organic compound (VOC) emissions from the No. 2 Poultry Line (Source Code: PL2), calculated in accordance with Condition No. 6.2.32, are equal to or in excess of 10tons. [Avoidance of40 CFR 52.211 Box Plant


### v. Any twelve-month rolling period of process operation during which the volatile organic compound (VOC) emissions from the Box Plant (Source Code: BP), calculated in accordance with Condition No. 6.2.35 are in excess of 100tons. [Avoidance of 391

### -3-1

### -.02(2)(mm)]
Page 35 of 72

### Title 

### V Permit International Paper -Savannah Permit No.: 2631-051-0007-V-02-0 vi. Any month of process operation during which more than 400 kilograms (kg) of organic HAP is applied to product and packaging rotogravure or wide-web flexographic printing presses in the Box Plant (Source Code: BP). The subject equipment includes the Flexo/Folder/Gluers as well as the Corrugators and any other stand-alone equipment included in accordance with 40 CFR 63.821(a)(2)&(3). [40CFR 63.861(b)(2)] 40 

### CFR 63 

### Subpart 

### MM Periods of monitoring exceedances reported for Condition Nos. 6.1.7.b.vii and 6.1.7.b.viii shall be in violation of 40 CFR 63 Subpart 

### MM if the total period of monitoring exceedances divided by the total period of operating time is in excess of 

### 6percent within any quarterly period. [40CFR 63.864(k)(2)(i)&(ii)] vii.

.

### .. v111. For the No. 15 Recovery Furnace (Source Code: RF 15), any quarterly period when the opacity reading, measured and recorded in accordance with Condition No. 5.2.l.b, is greater than 35 percent (six-minute average) for 6 percent or more ofthe operating time. [40CFR 63.864(k)(2)(i)] For the No. 7 Lime Kiln (Source Code: LK07), any quarterly period when the opacity reading, measured and recorded in accordance with Condition No. 5.2.1.a,is greater than 20 percent (six-minute average) for 6percent or more ofthe operating time. [40CFR 63.864(k)(2)(ii)] Periods of monitoring exceedances reported for Condition Nos. 6.1.7.b.j~ through 6.1.7.b.x shall be in violation of 40 CFR 63 Subpart 

### MM if six or more 3-hour average parameter readings within any six-month reporting period are below the parameter limits listed below. For purposes of determining the number ofnonopacity monitoring exceedances, no more than one exceedance will be attributed in any given 24-hour period. [40CFR 63.864(k)(2)(iii)&(vi) and 40 CFR 63.864(k)(3)] ix. For the No. 15Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), any three-hour average scrubbant flow rate, measured and recorded in accordance with Condition No. 5.2.2.a, less than 396 gallons per minute (gpm). [40 CFR 63.864(k)(2)(iii)]

x. For the No. 15Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), any three-hour average fan motor amperage, measured and recorded in accordance with Condition No. 5.2.2.a, less than 28.64 amps. [40CFR 63.864(k)(2)(vi)]

Page 36 of 72Title V Permit International Paper - Savannah - Pennit No.: 2631-05 1-0007-V-02-0 Pulp Production xi. Any twelve-month rolling period during which the production of virgin pulp fiber is in excess of 1,222,750 air-dried tons. [Avoidance of40 CFR 52.21, 391-3-1-.02(6)(b)l, and 40 CFR 70.6(a)(3)(i)] No. 15 Recovery Furnace xii. Any period of process operation during which the fuel oil fired in the No. 15 Recovery Furnace (Source Code: RF15) does not meet the definition of "very low sulfur oil" set forth in 40 CFR 60.41b or does not comply with the specifications for Nos. 1 and 2 fuel oils, as defined by ASTM D396, "Standard Specification for Fuel Oils". 140CFR 60.42b(a)&fi), 40 CFR 60.49b(r)(l), and 391 -3-1-.02(2)(g)2 (subsumed)] xiii. Any twelve-month rolling period during which the annual capacity factor for fuel oil and natural gas fired in the No. 15 Recovery Furnace (Source Code: RF15) is greater than 10 percent. The annual capacity factor shall be determined on a twelve-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. [40CFR 60.44b(e)] No. 13 Power Boiler xiv. Any 24-hour period during which the sulfur dioxide (SO4 emissions from the No. 13 Power Boiler (Source Code: PB13), calculated in accordance with Condition No. 6.2.6.b, are in excess of 2822 pounds per hour (Iblhr). [40CFR 52.211
c. Excursions: (means for the purpose of this Condition and Condition No. 6.1.4, any departure from an indicator range or value established for monitoring consistent with any averagingperiod specified for averaging the results of the monitoring) No. 7 Lime Kiln i. Any three consecutive eight-hour shift average values of the total secondary power for the No. 7 Lime Kiln Electrostatic Precipitator (Source Code: APOI), calculated and recorded in accordance with Condition No. 5.2.3.b, which fall below 75 percent of the operating value determined in accordance with Condition Nos. 4.2.1 and 4.2.2. [391-3-1-.02(2)(e)l(i)]

Page 37 of 72International Paoer - Savannah Title V Permit Permit No.: 2631-05 1-0007-V-02-0 Lime Area



### . . 11. Any three consecutive eight-hour shift average values for which the scrubbant flow rate for the No. 7 Lime Kiln Dust Scrubber (Source Code: AP03), measured and recorded in accordance with Condition No. 5.2.3.a, falls below 93 gallons per minute (gpm). [Avoidanceof40 CFR 52.21, 391-3-I-.02(2)(b)I, and 391-3-1-.02(2)(e)l(i)] No. 

### 15Recovery Furnace



### . . . 111. Any three consecutive eight-hour shift average values of the total secondary power for the No. 15 Recovery Furnace Electrostatic Precipitator (Source Code: AP14), calculated and recorded in accordance with Condition No. 5.2.3.b, which fall below 75 percent of the operating value determined in accordance with Condition Nos. 4.2.1 and 4.2.2. [391-3-1-.02(2)(e)l(i)] No. 15 Recovery Furnace Smelt Dissolving Tank 

### iv. Any three-hour period during which the position of the fillback valve on the No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), monitored and recorded in accordance with Condition No. 5.2.2.a, is closed, indicating that fillback isnot being used asthe scrubbant. [Avoidanceof40 CFR 52.21, 391-3-1-.02(2)(gg)l(iii), and 40 CFR 60.283(a)(4) (subsumed)] v. For the No. 15Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), any three-hour period during which any of the following conditions occur for the parameters measured and recorded in accordance with Condition No. 5.2.2.a: [40 CFR 52.21, Avoidance of 40 CFR 52.21, 391-3-1-.02(2)(b)1, 391-3-1-.02(2)(e)l 

### (i); 391-3-1-.02(2)(gg)l (iii), 40 CFR 63.862(a)(l)(i)(B) (subsumed), 40 CFR 60.282(a)(2) (subsumed), and 40 CFR 60.283(a)(4) (subsumed)] A. 

### The average scrubbant flow rate falls below 396 gallons per minute 

### (gpm) 

### B. The average fan motor current falls below 28.64 amps. No. 13 Power Boiler 

### vi. Any three consecutive eight-hour shift average values of the total secondary power for the No. 13 Power Boiler Electrostatic Precipitator (Source Code: AP07), calculated and recorded in accordance with Condition No. 5.2.3.b, falls below 75 percent of the operating value determined in accordance with Condition Nos. 4.2.1 and 4.2.2. [40 CFR 52.2 1, 40 CFR 60.42(a)(l) (subsumed), and 391 -3-1-.02(2)(d)2(iii) (subsumed)
Page 38 of72International Paver - Savannah Title

### V Permit Permit No.: 2631-051-0007-V-02-0 Cluster Rule vii. Any three-hour period during which the steam-to-condensate ratio for the Steam Stripper (Source Code: AP17), calculated and recorded in accordance with Condition No. 5.2.2.b, falls below 0.101. The steam-to-condensate ratio shall be calculated using the following equations: [40CFR 63.453(g)]

where S = Steam Feed Rate (steam flow), pounds per hour (lb/hr) 

### C = Process Wastewater Feed Rate (condensate flow), pounds per hour (lblhr) 

### TI = Stripper Bottom Temperature, in degrees Fahrenheit (OF) 

### T2 = Process Wastewater Column Feed Temperature(condensate feed temperature), in degrees Fahrenheit (OF) 

### P = Stripper Pressure, in pounds per square inch absolute (psia) viii. When the Biological Treatment System (Source Code: AP18) is used to demonstrate compliance with Condition Nos. 3-3.14, 3.3.17, and 3.3.18, any three-day period during which the average COD-to-horsepower ratio (CODlhp), measured and recorded in accordance with Condition No. 5.2.6.b.ii, is greater than 118. The Permittee may use the procedures in Condition No. 4.2.4 to demonstrate theparameter excursion is not a violation of40 CFR 63.446(e)(2). [40CFR 63.453(p)] K2 Fines Cyclone 

### ix. Any failure of the high level probe to effectively shut down the K2 Fines Cyclone (Source Code: AP06). [Avoidance of40 CFR 52.2 1, 391 -3-1-.02(2)(b)l, and 391 -3-1-.02(2)(e)l (i)] White Liquor NCG Scrubber

x. For the White Liquor NCG Scrubber (Source Code: WLSI), any three-hour period of scrubber operation duringwhich any 

### ofthe following conditions occur for the parameters measured and recorded in accordance with Condition No. 5.2.2.c: [Avoidance of40 CFR 52.2

### 1] A. The average scrubbant flow rate falls below 15.0 gallonsper minute 

### (gpm) B. The average pressure drop falls below 

### 6.0inches ofwater (in. H20).International Pa~er - Savannah Title V Permit Permit No.: 263 1-051-0007-V-02-0 xi. When combusting the total reduced sulfur (TRS) gas streams from Emission Groups LVH 1and LVH2 in the No. 13Power Boiler (Source Code: PB13),any twelve-month rolling period during which the TRS gas streams are scrubbed in the White Liquor NCG Scrubber (Source Code: WLSI) less than 90percent of the facility operating time. [Avoidance of40 CFR 52.2I] d. In addition to the excess emissions, exceedances and excursions specified above, the following should also be included with the report required in Condition No. 6.1.4: Fuel Sampling and Analysis i. The results of the analyses of the tall oil pitch shipments and of the daily coal samples, as specified in Condition Nos. 5.2.4 and 5.2.5, respectively. [40 CFR 52.2 1,40CFR 60.43,40CFR 60.45(b)(2), and 391-3- 1 -.02(2)(g)1 &2] No. 15 Recovery Furnace ii. For each month in the reporting period, the annual capacity factor for fuel oil and natural gas fired in the No. 15 Recovery Furnace (Source Code: RF15). The annual capacity factor shall be determined on a twelve-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. [40CFR 60.44b(e)] iii. A statement that only "very low sulfur oil", that meets the definitions in 40 CFR 60.41b and 40 CFR 60.49b(r), and/or pipeline quality natural gas was combusted in the No. 15 Recovery Furnace (Source Code: RF15) during the reporting period. [40CFR 60.49b(r)(l)] Cluster Rule iv. Any period of downtime of the Pulping Process Condensate Collection System, the Steam Stripper, the No. 13 Power Boiler, and the No. 7 Lime Kiln (Source Codes: PPCC, AP17, PB13, and LK07, respectively). [40CFR 70.6(a)(3)(i) and 391-3-1-.O2(6)(b)l]


### v. When the Biological Treatment System (Source Code: AP18) is used to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18, the result of any calculation performed in accordance with Condition No. 4.2.3 which demonstrates a total hazardous air pollutant (HAP) mass removal of less than 6.6 pounds oftotal 

### HAP per ton of oven-dried pulp (Iblton 

### ODP). [40CFR 63.446(e)(4) and 40 CFR 63.457(1)]

Page 40 of72InternationalPa~er - Savannah Title V Permit Permit No.: 263 1-051-0007-V-02-0 40 CFR 63 Subpart 

### MM vi. For the No. 15 Recovery Furnace (Source Code: RF15), any average of ten consecutive six-minute opacity averages which results in a measurement greater than 20percent opacity in accordance with Condition No. 6.2.26.a. [40CFR 63.864(k)(l)(i)] vii. For the No. 7 Lime Kiln (Source Code: LK07), any average of ten consecutive six-minute opacity averages which results in a measurement greater than 20percent opacity in accordance with Condition No. 6.2.26.b. [40CFR 63.864(k)(I)(i)] viii. For the No. 15Recovery Furnace (Source Code: RF15), any six-minute period during which the average opacity, measured and recorded in accordance with Condition No. 5.2.1.b, is in excess of 35 percent. [40CFR 63.862(a)(l)(i)(A) and 40 CFR 63.864(k)(2)(i)] 

### ix. For the No. 7 

### Lime Kiln (Source Code: LK07), any six-minute period during which the average opacity, measured and recorded in accordance with Condition No. 5.2.1.a,isin excess of 20percent. [40CFR 63.862(a)(l)(i)(C) and 40 CFR 63.864(k)(2)(ii)] White Liquor NCG Scrubber


### x. For each month in the reporting period, a report of the twelve-month rolling totals of downtime and operating time of the White Liquor NCG Scrubber (Source Code: WLSI), calculated in accordance with Condition No. 6.2.24.c. [Avoidance of40 CFR 52.21 No. 

### 13 Power Boiler 

### xi. For each month in the reporting period, a report of the twelve-month rolling totals ofbark fired in the No. 13Power Boiler (Source Code: PB 13),calculated in accordance with Condition No. 6.2.10. [40CFR 70.6(a)(3)(i) and 391-3-1

### -.O2(6)(b)1

### ] General 

### xii. A list of all the current operational parameters established in accordance with Condition No. 4.2.2. This list shall include all operation parameters required to be monitored and the current operating range for each operational parameter. [40CFR 70.6(a)(3)(i) and 391-3-1-.O2(6)(b)l]

Page 41 of 72Title V Permit International Paper -Savannah Permit No.: 2631-05 1-0007-V-02-0 

### 6.2 Specific Record Keeping and Reporting Requirements No. 

### 7 Lime Kiln 6.2.1 The Permittee shall maintain the following daily records for the No. 

### 7 Lime Kiln (Source Code: LK07): [391-3-1-.02(2)(b)1 and 391-3-1-.02(2)(e)l(i)]
a. Thelimemud feed rate, and b. Either the percent solids orthe density of the lime mud feed. No. 15Recovery Furnace 6.2.2 ThePermittee shall maintain the daily records of either the percent black liquor solids or the black liquor density for the No. 15Recovery Furnace (SourceCode: RF15). [391-3-1-.02(2)(b)l and 391-3-1-.02(2)(e)l(i)] 6.2.3 The Permittee shall obtain and maintain fuel receipts from the fuel supplier that certify that the fuel oil fired in the No. 15 Recovery Furnace (Source Code: RF15) meets the definition of "very low sulfur oil", as defined in 40 CFR 60.41b, and complies with the specifications for Nos. 1 and 2 fuel oils, as defined by ASTM D396, "Standard Specification for Fuel Oils". [40 CFR 60.49b(r)(l), 40 CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l] 6.2.4 The Permittee shall record and maintain records of the amounts of fuel oil and natural gas combusted during each day for the No. 15 Recovery Furnace (Source Code: RF15) and calculate the annual capacity factor individually for he1oil and natural gas for each quarter. The annual capacity factor is determined on a twelve-month rolling average basis with a new annual capacity factor calculated at the end of each calendar month. [40CFR 60.49b(d),40 CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)1]

Page 42 of 72

### Title V Permit International Paper

-Savannah Permit No.: 2631-051-0007-V-02-0 Yo I.3 Power Boiler
- .- -- The Permittee shall maintain, at a minimum, the following daily records for the No. 13 Power Boiler (SourceCode: PB13): [40 CFR 52.21, 40 CFR 60.43(a)(1)&(2), 40 CFR 60.43(b), 40 CFR 60.44(a)(2)&(3), 40 CFR 60.44(b), 391-3-1

### -.02(2)(d)4(i)&(ii)&(iv), 391-3-1-.02(2)(g)1(i)&(ii)&(iii), 391 -3- 1 -.02(2)(g)2,40 CFR 60.42(a)(l) (subsumed), and 391-3-1-.02(2)(d)2(iii) (subsumed)]
a. Each type offuel fired, b. Thequantity of each fuel fired, and
c. The steam production records. The Permittee shall calculate and maintain the following records ofthe sulfur dioxide (SO2) emission rate for the No. 13Power Boiler (SourceCode: PB13):
a. For each day of operation or portion of day of operation, the 30-day rolling average SO:! emission rate, in pounds per million Btu (IbIMMBtu), to determine compliance with the SO2 emission standards in Condition Nos. 3.3.7.b.i through 3.3.7.b.iii. [40CFR 60.43(a)&(b), 40 CFR 60.45(g)(2), and 391-3-1-.02(2)(g)1] 

### b. The 24-hour rolling average SO2 emission rate, in pounds per hour (lb/hr), to determine compliance with the SO2emission standard in Condition No. 3.3.7.b.i~. [40CFR 52.211 The average SO:! emission rates shall be calculated using the results of the coal analyses required by Condition No. 5.2.5, the fuel sulfur content of the fuel oil fired as determined from the fuel supplier certifications required by Condition No. 6.2.12, and the emission factor of 0.087 pounds of SO2 per million Btu (lb S02/MMBtu) for the average sulfur content of the wood waste fired. The calculation of the 24-hour rolling average SO2 emission rate in paragraph (b) of this Condition shall include the factor developed to reflect the maximum SO:! emission rate resulting from the combustion of noncombustible gases (NCGs) and stripper off gases (SOGs).

Page 43 of72

### Title 

### V Permit International Paper - Savannah Permit No.: 263 1-051-0007-V-02-0 

### 6.2.7 Before beginning actual construction of the No. 13 Power Boiler Bark Burning Project described in Section 1.3 of this Permit, the Permittee shall document and maintain a record ofthe following information: 

### [391-3-1-.02(7)(b)15(i)(I)]
a. A 

### description ofthe project; b. Identification of the emissions unit whose emissions of a regulated New Source Review (NSR)pollutant could be affected by the project; and
c. A 

### description ofthe applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded under Georgia Rule 391-3-1-.02(7)(a)2(ii)(II)III and an explanation for why such amount was excluded, and any netting calculations, if applicable. The records required by this Condition shall be retained for a period of fifteen years following resumption ofregular operations after the completion ofthe project. 6.2.8 ThePermittee shall calculate and maintain records ofthe following information for a period of ten years following resumption of regular operations after completion of the No. 13 Power Boiler Bark Burning Project described in Section 1.3ofthis Permit:
a. The annual emissions of each regulated New Source Review (NSR) pollutant, in tons per year (tpy) on a calendar year basis; and [391-3-1-.02(7)(b)1S(i)(III)] b. The actual increase in emissions of each regulated NSR pollutant due to demand growth, in tonsper year (tpy) on a calendar year basis. [391-3-1-.02(7)(b)15(i)(IV)] The records required by this Condition shall be retained for a period of five years past the end of each calendar year. 6.2.9 The Permittee shall submit a report to the Division within 60 days after the end of each year during which the records must be generated under Condition No. 6.2.8 setting out the annual emissions from the No. 13 Power Boiler (Source Code: PB13) of each regulated New Source Review (NSR) pollutant and, if applicable, the actual increase in emissions from the No. 13 Power Boiler of each regulated NSR pollutant due to demand growth during the calendar year that preceded submission of the report. [391-3-1-.02(7)(b)S5(i)(V)] 6.2.10 For each calendar month, the Permittee shall calculate and maintain records of the twelve-month rolling total of bark fired in the No. 13 Power Boiler (Source Code: PB13), in tons per year (tpy). [40CFR 70.6(a)(3)(i) and 391-3-1-.02(6)(b)l]

Page 44 of 72International Paper - Savannah 

### Title 

### V Permit Permit No.: 263 1-051-0007-V-02-0 Electric Output for Sale 6.2.11 For each calendar month, the Pennittee shall calculate and maintain the following records for the No. 15 Recovery Furnace (Source Code: RF15) and for the No. 13 Power Boiler (Source Code: PB13): [Avoidanceof40 CFR 60 Subpart Da and Avoidance of40 CFR 72 Subpart A]
a. The twelve-month rolling total electrical output, in megawatt-hours (MWe-lm), supplied to any utility power distribution system for sale; and b. The percent of the potential electric output capacity represented by the twelve-month rolling total of electrical output supplied to any utility power distribution system for salecalculated in accordance with Condition No. 6.2.1 1 .a. Fuel Oil 6.2.12 For each shipment ofresidual oil received that is to be fired in the No. 7 Lime Kiln and the No. 13 Power Boiler (Source Codes: LK07 and PB13, respectively), the Permittee shall obtain a fuel supplier certification, which shall include the following information: [40 CFR 52.21,40 

### CFR 60.45(b)(2),391-3-1-.02(2)(g)2,40 CFR 70.6(a)(3)(i), and 391

### -3-1-.02(6)(b)1]
a. Name ofthe oil supplier; b. Location of the oil when the sample was drawn for analysis to determine the sulfur content of the oil, specifically including whether the oil was sampled as delivered to the Pennittee or whether the sample was drawn from oil in storage at the oil supplier's or oil refiner's facility or other location;
c. Sulfur content ofthe oil from which the shipment came (or ofthe shipment itself); d. Method used to determine the sulfur content ofthe oil;
e. Quantity of fuel oil received; and f. Heat content of fuel oil received. For the purposes of this permit, residual oil is defined as any fuel oil that does not comply with the specifications for Nos. 1 and 2 fuel oils, as defined by ASTM D396, "Standard Specifjcation for Fuel Oils", and all Nos. 4, 5, and 6 fuel oils, as defined by ASTM 

### D396. 6.2.13 For each shipment of distillate fuel oil received, the Permittee shall obtain a fuel supplier certification, which shall include the following information: [391-3-1-.02(2)(g)2,40CFR 70.6(a)(3)(i), and 391

### -3-1-.02(6)(b)l]
a. Name ofthe supplier; and b. Statement that the fuel oil complies with the specifications for Nos. 1 and 2 fuel oils, as defined in ASTM D396, "Standard Specification for Fuel Oils". Page 45 of72Title V 

### Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 Used Oil 6.2.14 For each shipment ofused oil received, the Permittee shall maintain the following records: [391-3-1-.02(2)(g)2,40 CFR 70.6(a)(3)(i), and 391 -3-1-.02(6)(b)I]
a. Quantity of used oil received; and b. Sulfurcontent ofthe used oil received. Tall Oil Pitch 6.2.15 For each shipment oftall oil pitch received that is to be fired in the No. 7 Lime Kiln (Source Code: LK07), the Permittee shall maintain records of the analyses obtained in accordance with Condition No. 5.2.4. Therecords shall include the following information: [391-3-1-.02(2)(g)2,40 CFR 70.6(a)(3)(i), and 391 -3-1-.02(6)(b)I]
a. Quantity oftall oil pitch received; 

### b. Sulfur content ofthe tall oil pitch received;
c. Moisture content ofthe tall oil pitch received; and d. Gross Calorific Value (GCV) ofthe tall oil pitch received.

6.2.16 The Permittee shall maintain records of the daily analyses of gross samples of as-bunkered coal to be combusted in the No. 13 Power Boiler (Source Code: PB13) obtained in accordance with Condition No. 5.2.5. Therecords shall include the following information: [40 CFR 52.2 1, 40 CFR 60.45(b)(2), 391-3-1-.02(2)(g)1, 391-3-I-.02(2)(g)2, 40 CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l]
a. Sulhrcontent ofthe coal received; b. Moisture content ofthe coal received; and
c. Gross Calorific Value (GCV) of the coal received. Cluster Rule 6.2.17 The Permittee shall maintain daily records of all periods duringwhich the following occur: [40 CFR .70.6(a)(3)(i), 391-3-1-.02(6)(b)l, 40 CFR 63 Subpart S, 40 CFR 60 Subpart BB, and 391-3-1-.02(2)(gg)]
a. Emission Groups LVHl and LVH2 are i. controlled by theNo. 13Power Boiler (Source Code: PB13); ii. controlled by the No. 7 Lime Kiln (SourceCode: LK07);

. .

### . 111. exhausted via the bypass stack. Page 46 of 72International Paver - Savannah 

### Title V 

### Permit Permit No.: 2631-051-0007-V-02-0 

### b. Emission Group HVLC is i. controlled by theNo. 13 Power Boiler;



### .. 11. 

### exhausted via the bypass stack. ThePermittee shall record and maintain records of the following infonnation: [40CFR 70.6(a)(3)(i) and 391-3-1-.02(6)(b)l]
a. For gases from equipment and collection systems, any times of greater than five minutes during which the total hazardous air pollutant (HAP) emissions from the equipment listed in Condition Nos. 3.3.10 and 3.3.11 

### are not controlled; and b. For gases at the control device, any times of greater than one minute during which the total hazardous air pollutant (HAP) emissions from the equipment listed in Condition Nos. 3.3.10 and 3.3.1 1 are not controlled. The Permittee shall maintain records sufficient to calculate the total hazardous air pollutant (HAP) mass of the Pulping Process Condensates (Source Code: PPCC) collected in accordance with Condition No. 3.3.14. Using these condensate collection records, the Permittee shall calculate and record the fifteen-day rolling average total HAP mass of collected condensates, inpounds per ton of oven-dried pulp (lblton 

### ODP). 140CFR 63.446(~)(3), 40 CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)1] The Permittee shall develop a written plan as described in 40 CFR 63.6(e)(3) that contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction (SSM), and a program of corrective action for malfunctioning process and air pollution control systems used to comply with 40 CFR 63 Subpart S. As required under 40 CFR 63.8(c)(l)(iii), the plan shall identify all routine or otherwise predictable continuous monitoring system (CMS) malfunctions. [40CFR 63.6(e) and 40 CFR 63.455(a)] For each applicable enclosure opening, closed-vent system, and closed collection system subject to 40 CFR 63 Subpart S, the Permittee shall prepare and maintain a site-specific inspection plan including a drawing or schematic of the components of applicable affected equipment and shall record the following information for each inspection: [40 CFR 63.454(b)]
a. Date ofinspection; b. The equipment type and identification;
c. Results ofnegative pressure tests for enclosures; d. Results ofleak detection tests;
e. The nature of the defect or leak and the method of detection (i.e., visual inspection or instrument detection);
Page 47 of 72

### Title V Permit International Paper - Savannah Permit No.: 263 1-051-0007-V-02-0 f. The date the defect or leak was detected and the date of each attempt to repair the defect or leak; g. Repair methods applied in each attempt to repair the defect or leak; h. The reason for the delay if the defect or leak is not repaired within 15 days after discovery; i. The expected date of successful repair of the defect or leak if the repair is not completed within 15days; 

### j. Thedate of successful repair ofthe defect or leak; 

### k. The position and duration of opening of bypass line valves and the condition of any valve seals: and 1. The duration ofthe use ofbypass valves on computer controlled valves. 6.2.22 The Permittee shall maintain records of the tiine, date, and duration of excess emissions from the Steam Stripper (Source Code: AP 17), including periods of startup, shutdown, or malfunction (SSM). Said records shall be used as specified in Condition No. 6.1.7.a.vii to show compliance with the requirements of40 CFR 63.446(g). [40CFR 63.10(b), 40 CFR 63.454(a), and 40 CFR 63.4551 Biological Treatment System 6.2.23 The Permittee shall submit a written report to the Division within seven days of sending all of the Pulping Process Condensates (Source Code: PPCC) to the backup control device, the Biological Treatment System (Source Code: AP18), due to a failure of the Steam Stripper (Source Code: AP17). This report shall state the cause of the failure and the expected return to operation of Steam Stripper (Source Code: AP 17). [40CFR 70.6(a)(3)(i) and 391-3-1 -.02(6)(b)l] 6.2.24 The Permittee shall submit a written report to the Division whenever a mass emission rate test is conducted on the Biological Treatment System (Source Code: AP18) in accordance with Condition No. 4.2.4 to demonstrate compliance with Condition Nos. 3.3.14, 3.3.17, and 3.3.18. This report shall contain the results of the testing as well as the values of the parameters required to be recorded by Condition No. 5.2.6.b. [40CFR 70.6(a)(3)(i) and 391-3-1-.02(6)(b)l] White Liquor NCG Scrubber 6.2.25 The Permittee shall maintain records of the following information to determine compliance with Condition No. 3.3.1O.b: [Avoidanceof40 CFR 52.2l,40CFR 70.6(a)(3)(i), and 391-3-1-.O2(6)(b)

### I]
a. Thetwelve-month rolling total operating time of the Pre-Evaporator Island; b. Thetwelve-month rolling total down tiine ofthe White Liquor NCG Scrubber (Source Code: WLSl); and Page 48 of72International Pa~er - Savannah 

### Title 

### V Permit Permit No.: 2631-051-0007-V-02-0


### c. The percent of operating time that the gas stream from Emission Group LVH2 is scrubbed in the White Liquor NCG Scrubber (Source Code: WLSI) prior to combustion in the No. 13 Power Boiler (Source Code: 

### PB13) for each twelve-month rolling period. 40 CFR 63 Subpart 

### MM 6.2.26 The Permittee shall develop a written plan as described in 40 CFR 63.6(e)(3) that contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction (SSM), and a program of corrective action for malfunctioning process and air pollution control systems used to comply with 40 CFR 63 Subpart 

### MM. In addition to the information required in 40 CFR 63.6(e), the plan must also include the following requirements: [40CFR 63.6(e)(3) and 40 CFR 63.866(a)]
a. Procedures for responding to any process parameter level that is inconsistent with the level(s) established including the procedures specified as follows: i. Procedures to determine and record the cause of an operating parameter excursion and the time the excursion began and ended; and

. . 1. 

### Corrective actions to be taken in the event of an operating parameter excursion, including procedures for recording the actions taken to correct the excursion. b. The SSM plan also must include the schedules as follows: i. A 

### maintenance schedule for each control technique that is consistent with, but not limited to, the manufacturer's instructions and recommendations for routine and long-term maintenance; and

.. 

### 11. An inspection schedule for each continuous parameter monitoring system (CPMS) required under Condition No. 5.2.2 to ensure, at least once in each 24-hour period, that each continuous monitoring system isproperly functioning. 6.2.27 The Permittee shall implement corrective action if any of the following monitoring exceedances occur: a. For the No. 

### 15 Recovery Furnace (Source Code: RF15), any average of ten consecutive six-minute averages resulting in a measurement of greater than 20percent opacity



### . 140CFR 63.864(k)(l)(i)] b. For the No. 7 

### Lime Kiln (Source Code: LK07), any average of ten consecutive six-minute averages resulting in a measurement of greater than 20 percent opacity. [40CFR 63.864(k)(l)(i)]

Page 49 of72

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0


### c. For the No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), any three-hour average scrubbant flow rate less than 396 gallons per minute (gpm). [40CFR 63.864(k)(l)(ii)] d. For the No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber (Source Code: AP15), any three-hour average fan motor amperage less than 28.64 amps. [40 CFR 63.864(k)(l)(v)] 6.2.28 The Permittee shall maintain records of any occurrence when corrective action is required under Condition No. 6.2.27 and any occurrence when an exceedance is noted under Condition Nos. 6.1.7.b.vii through 6.1.7.b.x. [40 CFR 63.866(b)] 6.2.29 In 

### addition to the general records required by 40 CFR 63.10(b)(2), the Permittee shall maintain the following: [40CFR 63.866(c)]
a. Records of the black liquor solids (BLS) firing rate, in tons per day (tpd), for the No. 15Recovery Furnace (Source Code: RF15); [40CFR 63.866(~)(1)] b. Records of the calcium oxide (CaO) production rate, in tons per day (tpd), for the No. 7 Lime Kiln (Source Code: LK07); [40CFR 63.866(~)(2)]
c. Records of parameter monitoring data required under 40 CFR 63.864, including any period when the operating parameter levels were inconsistent with the levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred, the time corrective action was initiated and completed, and the corrective action taken; [40CFR 63.866(~)(3)] d. Records and documentation of supporting calculations for compliance determinations made under 40 CFR 63.865(a) through (d); and [40CFR 63.866(~)(4)] e. Records ofmonitoring parameter ranges established for the No. 15 Recovery Furnace Smelt Dissolving Tank Vent Scrubber (SourceCode: AP 15). [40CFR 63.866(~)(5)] Pulp Production 6.2.30 For each calendar month, the Permittee shall calculate and maintain records of the twelve-month rolling total of the facility-wide fiber production, in air-dried tons of virgin pulp fiber per year. [Avoidanceof40 CFR 52.2l,4O CFR 70.6(a)(3)(i), and 391-3- 

### 1-.02(6)(b)l]

Page 50 of 72

### Title V 

### Permit InternationalPaper - Savannah Permit No.: 263 1-051-0007-V-02-0

6.2.3 1 The Permittee shall maintain monthly usage records of all materials used at the Poultry Line and the No. 2 Poultry Line (Source Codes: PL and PL2, respectively) that contain volatile organic compounds (VOC). Separate records shall be maintained for each poultry line. These records shall include the total weight of each material used and the VOC content of each material (expressed as a weight percentage). The Permittee may subtract from the monthly usage the volatile content of any containerized material disposed as waste provided that the total weight, VOC content (expressed as a weight percentage), and documentation of the method for determining the VOC content of any such waste material be included as part ofthe record. All calculations used to determine usages shall also be kept as part ofthe monthly record. [Avoidance of40 CFR 52.2 1,40CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l] 6.2.32 The Permittee shall maintain records ofthe total monthly volatile organic compound (VOC) emissions from the Poultry Line and the No. 2 Poultry Line (Source Codes: PL and PL2, respectively). Separate records shall be maintained for each poultry line. The Permittee shall use the monthly usage records required by Condition No. 6.2.30 to calculate the total monthly VOC emissions from each poultry line using the following equations:
a. VOC (Ibs) = [MrrteiiolUsogrirc (lbs)]x [VOCContent (Ibs VOCllbr Moteriid)] ;or b. VOC (lbs) = [Mateiiiil Usage (gullons)]~ [VOCContent (Ibs VOC 

### I gollons Muterial)]



### . The Permittee shall notify the Division in writing ifthe total VOC emissions from either the Poultry Line or the No. 2 Poultry Line exceed 0.83 tons during any calendar month. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to maintain compliance with the applicable emissions limitation set forth in Condition No. 3.3.20 or Condition No. 3.3.21. [Avoidanceof40 CFR 52.21,40CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l] 6.2.33 For each calendar month, the Permittee shall maintain records of the total volatile organic compound (VOC) emissions from the Poultry Line and the No. 2 Poultry Line (Source Codes: PL and PL2, respectively) for each twelve consecutive month period. Separate records shall be maintained for each poultry line. The Permittee shall use the calculations required by Condition No. 6.2.31 to determine the twelve-month rolling total VOC emissions from each poultry line. The Permittee shall notify the Division in writing if the total VOC emissions from either the Poultry Line or the No. 2 Poultry Line equal or exceed 10tons during any twelve consecutive month period. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to attain future compliance with the applicable emissions limitation set forth in Condition No. 3.3.20 or Condition No. 3.3.21. [Avoidance of40 CFR 52.21,40CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l]

Page 51 of 72

### Title V Permit InternationalPaper - Savannah Pennit No.: 263 1-051-0007-V-02-0 Box PlantThe Permittee shall maintain monthly usage records of all materials used at the Box Plant (Source Code: BP) that contain volatile organic compounds (VOC). These records shall include the total weight of each material used and the VOC content of each material (expressed as a weight percentage). The Permittee may subtract from the monthly usage the volatile content of any containerized material disposed as waste provided that the total weight, VOC content (expressed as a weight percentage), and documentation of the method for determining the VOC content of any such waste material be included as part of the record. All calculations used to determine usages shall also be kept as part of the monthly record. [Avoidanceof 391-3-1-.02(2)(mm), 40 CFR 70.6(a)(3)(i), and 391-3-1-.02(6)(b)l] ThePermittee shall maintain records ofthe total monthly volatile organic compound (VOC) emissions from the Box Plant (Source Code: BP). The Permittee shall use the monthly usage records required by Condition No. 6.2.33 to calculate the total monthly VOC emissions from the Box Plant using the following equations:

a. VOC (Ibs) =

# ateri rial Usage (lbs)]x [VOCContent (Ibs VOC 1lbs Material)] ;or b. VOC (Ihr) = [~uterial Usage (gallor,s)]x [VOC Content (Ibi VOC

### Igallons Mater-ial)]



### . The Permittee shall notify the Division in writing if the total VOC emissions from Box Plant exceed 8.33 tons during any calendar month. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to maintain compliance with the emissions limitation set forth in Condition No. 3.4.14. [Avoidanceof 391-3-1-.02(2)(mm), 40 CFR 70.6(a)(3)(i), and 391-3-1-.O2(6)(b)l] For each calendar month, the Permittee shall maintain records of the total volatile organic compound (VOC) emissions from the Box Plant (Source Code: BP) for each twelve consecutive month period. The Permittee shall use the calculations required by Condition No. 6.2.34 to determine the twelve-month rolling total VOC emissions from the Box Plant. The Permittee shall notify the Division in writing if the total VOC emissions from the Box Plant equal or exceed 100 tons during any twelve consecutive month period. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to attain future compliance with the emissions limitation set forth in Condition No. 3.4.14. [Avoidance of 391 -3-1-.02(2)(mm), 40 CFR 70.6(a)(3)(i), and 391 -3-1-.02(6)(b)1] The Permittee shall maintain records of the total mass and the organic hazardous air pollutant (HAP) content of each material applied on product and packaging rotogravure or wide-web flexographic printing presses in the Box Plant (Source Code: BP) during each month. The subject equipment includes the Flexo/Folder/Gluers as well as the Corrugators and any other stand-alone equipment included in accordance with 40 CFR 63.821(a)(2)&(3). [40CFR 63.829(e)(2)]
Page 52 of 72InternationalPa~er - Savannah 

### Title 

### V Permit Permit No.: 263 1-051-0007-V-02-0 

### Recordkeeping and Reporting Associated with Monitoring Requirements --- 

### 6.2.38 The Permittee shall, in accordance with the requirements of Condition Nos. 6.1.1 and 6.1.6, maintain records of all data and information required by the Conditions listed in Section 5.2 of Part 5.0 of this permit. Reports shall be submitted in accordance with the requirements of Condition No. 6.1.4. [40CFR 70.6(a)(3)(i) and 391-3-1 -.O2(6)(b)

### 11 Responsible Official Certifications 6.2.39 Pursuant to Condition No. 8.8.3, 

### any application form, report, or compliance certification submitted shall contain a certification by the appropriate Responsible Official or, if applicable, certifications by both Responsible Officials. [40CFR 70.5(d), 40 CFR 70.6(c)(l), and 391-3-1-.03(1O)(c)2]

### Title V 

### Permit International Paper - Savannah PermitNo.: 2631-051-0007-V-02-0 

### PART 7.0 OTHER SPECIFIC REQUIREMENTS 

### 7.1 Operational Flexibility The Permittee may make Section 502(b)(10) changes as defined in 40 CFR 70.2 without requiring a Permit revision, if the changes are not modifications under any provisions of Title 1of the Federal Act and the changes do not exceed the emissions allowable under the Permit (whether expressed therein as a rate of emissions or in terms oftotal emissions). For each such change, the Permittee shall provide the Division and the 

### EPA with written notification as required below in advance of the proposed changes and shall obtain any Permits required under Georgia Rules 391-3-1-.03(1) and (2). The Permittee and the Division shall attach each such notice to their copy of this Pesmit. [391-3-1-.03(1O)(b)5 and 40

### CFR 70.4(b)(12)(i)]
a. For each such change, the Permittee's written notification and application for a construction Pesmit shall be submitted well in advance of any critical date (typically at least 3 months in advance of any commencement of construction, Permit issuance date, etc.) involved in the change, but no less than seven days in advance of such change and shall include a brief description of the change within the Permitted facility, the date on which the change is proposed to occur, any change in emissions, and any Permit term or condition that is no longer applicable as a result ofthe change. b. The Permit shield described in Condition No. 8.16.1 shall not apply to any change made pursuant to this condition. 

### 7.2 

### Off-Permit Changes 7.2.1 The Permittee may make changes that are not addressed or prohibited by this Permit, other than those described in Condition No. 7.2.2 below, without a Permit revision, provided the following requirements aremet: [391-3-1-.03(1 O)(b)6 and 40 

### CFR 70.4(b)(l4)]
a. Each such change shall meet all applicable requirements and shall not violate any existing Permit term or condition. b. ThePermittee must provide contemporaneous written notice to the Division and to the 

### EPA of each such change, except for changes that qualify as insignificant under Georgia Rule 391

### -3-1-.03(10)(g). Such written notice shall describe each such change, including the date, any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result ofthe change.
c. The change shall not qualify for the Permit shield in Condition No. 8.16.1 d. The Permittee shall keep a record describing changes made at the source that result in emissions of a regdated air pollutant subject to an applicable requirement, but not otherwise regulated under the Permit, and the emissions resulting from those changes.

Page 54 of 72Title V Permit International Paper - Savannah Permit No.: 2631-05 1-0007-V-02-0 7.2.2 The Permittee shall not make, without a Permit revision, any changes that are not addressed or prohibited by this Permit, if such changes are subject to any requirements under Title 

### IV 

### ofthe Federal Act or aremodifications under any provision ofTitle I ofthe Federal Act. [391-3-1-.03(1O)(b)7 and 40 CFR 70.4(b)(15)] Alternative Requirements [White Paper #2] Not Applicable. Insignificant Activities (see Attachment 

### B for the list of Insignificant Activities in existence at the facility at the time of permit issuance) Temporary Sources [391-3-1-.03(10)(d)5and 40 CFR 70.6(e)] Not Applicable. Short-term Activities (seeForm 

### D5 "Short Term Activities" of the Permit application and White Paper #1) Not Applicable. Compliance Schedule/Progress Reports [391-3-1-.O3(lO)(d)3 and 40 CFR 70.6(~)(4)] Not Applicable. Emissions Trading [391-3-1-.03(10)(d)l(ii) and 40 

### CFR 70.6(a)(l0)] Not Applicable. Acid Rain Requirements Not Applicable. 7.10 Prevention ofAccidental Releases (Section 112(r) ofthe 1990 CAAA) [391-3-1-.02(10)] 7.10.1 When and if the requirements of 40 CFR Part 68 become applicable, the Permittee shall comply with all applicable requirements of40 CFR Part 

### 68, including the following.
a. The Permittee shall submit a Risk Management Plan (RMP) as provided in 40 CFR 68.150 through 68.185. The RMP shall include a registration that reflects all covered processes. Page 55 of72International Paper -Savannah 

### Title V 

### Permit Permit No.: 263 1-051-0007-V-02-0 

### b. For processes eligible for Program 1,as provided in 40 CFR 68.10, the Permittee shall coinply with ConditionNo. 7.10.1.a and the following additional requirements: i. Analyze the worst-case release scenario for the process(es), as provided in 40 CFR 68.25; document that the nearest public receptor is beyond the distance to a toxic or flammable endpoint defined in 40 CFR 68.22(a); and submit in the

. . 

### RMP the worst-case release scenario asprovided in 40 CFR 68.165. 11. Complete the five-year accident history for the process as provided in 40 CFR

... 

### 68.42 and submit in the RMP as provided in 40 CFR 68.168 111. Ensure that response actions have been coordinated with local emergency planning and response agencies iv. Include a certification in the RMP as specified in 40 CFR 68.12(b)(4)
c. For processes subject to Program 2, as provided in 40 CFR 68.10, the Permittee shall comply with Condition No. 7.10.1.a, Condition No. 7.10.1.b, and the following additional requirements: i. Develop and implement a management system as provided in 40 CFR 68.15 ii. Conduct ahazard assessment as provided in 40 CFR 68.20 through 68.42

... 

### 111. Implement the Program 2 prevention steps provided in 40 CFR 68.48 through 68.60 or implement the Program 3 prevention steps provided in 40 CFR 68.65 through 68.87 iv. Develop and implement an emergency response program as provided in 40 CFR 68.90 through 68.95 v. Submit as part of the RMP the data on prevention program elements for Program 2 processes asprovided in 40 CFR 68.170 d. 

### For processes subject to Program 3, as provided in 40 CFR 68.10, the Permittee shall comply with Condition No. 7.10.1.a, Condition 

### No. 7.10.1 .b, and the following additional requirements: i. Develop and implement a management system as provided in 40 CFR 68.15

.. 

### 11. Conduct ahazard assessment as provided in 40 CFR 68.20 through 68.42

. . . 

### 111. Implement the prevention requirements of40 CFR 68.65through 68.87 iv. Develop and implement an emergency response program as provided in 40 CFR 68.90 through 68.95 v. Submit as part of the RMP the data on prevention program elements for Program 3 as provided in 40 CFR 68.175
e. All reports and notification required by 40 CFR Part 68 must be submitted electronically (e.g., diskette or compact disc)to:


### MAIL Risk 

### Management Program (RMP) Reporting Center P.O. Box 10162 Fairfax, VA 

### 22038
Page 56 of72International Paper - Savannah Title 

### V Permit Permit No.: 2631-051-0007-V-02-0 COURIER & FEDEX Risk Management Program (RMP) Reporting Center C/O CGI Federal, Inc. 

### 12601 Fair Lakes Circle Fairfax, VA 22033 Compliance with all requirements of this condition, including the registration and submission of the RMP, shall be included as part of the compliance certification submitted in accordance with Condition No. 8.14.1, 7.11 Stratospheric Ozone Protection Requirements (Title 

### VI ofthe CAAA of 1990) 7.11.1 Ifthe Permittee performs any of the activities described below or as otherwise defined in 40 CFR Part 82, the Permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart 

### F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B:
a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to 40 CFR 82.156. b. Equipment used during the maintenance, service, repair, or disposal of appliance must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.
c. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to 40 CFR 82.161. d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with record keeping requirements pursuant to 40 CFR 82.166. [Note: "MVAC-like appliance" is defined in 40 CFR 82.152.1 e. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to 40 CFR 82.156. f. Ownersloperators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to 40 CFR 82.166. 7.1 1.2 If the Permittee performs a service on motor (fleet) vehicles and if this service involves an ozone-depleting substance (refrigerant) in the MVAC, the Permittee is subject to all the applicable requirements as specified in 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners. The term "motor vehicle" as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The tenn "MVAC" as used in Subpart 

### B does not include air-tight sealed refrigeration systems used for refrigerated cargo, or air conditioning systems on passenger buses using HCFC-22 refrigerant.Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 7.12 Revocation ofExisting Permits and Amendments The following Air Quality Permits, Amendments, and 502(b)10 are subsumed by this permit and are hereby revoked:

7.13 Pollution Prevention None applicable.

Air Quality Permit andAmendment Number(s) 2631 -051-0007-V-0 1-0 263 1-051-0007-V-01-2 263 1-051-0007-V-0 1-4 2631-051-0007-V-01-5 263 1-051-0007-V-01-7 263 1-051-0007-V-01-8 263 1-051-0007-V-01-9

7.14 Specific Conditions None applicable. Dates of Original Permit or Amendment I[ssuance April 3, 2002 October 21,2003 June 2,2005 October 18,2005 December 2,2005 March 24, 2008 January 2,2009

Page 58 of 72Title

### V Permit International Paper - Savannah Pernlit No.: 2631-051-0007-V-02-0 PAR

### E 3.0 

### GEVEIWL PROVISIONS 8.1 Terms and References 8.1.1 Terms not otherwise defined in the Permit shall have the meaning assigned to such terms in the referenced regulation. 8.1.2 Where more than one condition in this Permit applies to an emission unit and/or the entire facility, each condition shall apply and the most stringent condition shall take precedence. [391-3-1-.02(2)(a)2] 

### 8.2 EPA Authorities 8.2.1 Except as identified as "State-only enforceable" requirements in this Permit, all terms and conditions contained herein shall be enforceable by the EPA and citizens under the Clean Air Act, as amended, 42 U.S.C. 7401, et seq. [40 CFR 70.6(b)(l)] 8.2.2 Nothing in this Permit shall alter or affect the authority of the EPA to obtain information pursuant to 42 U.S.C. 7414, "Inspections, Monitoring, and Entry." [40 CFR 70.6(f)(3)(iv)] 8.2.3 Nothing in this Permit shall alter or affect the authority of the EPA to impose emergency orderspursuant to 42 U.S.C. 7603, "Emergency Powers." 

### [40CFR 70.6(f)(3)(i)] 

### 8.3 Duty to Comply The Permittee shall comply with all conditions of this operating Pennit. Any Permit noncompliance constitutes a violation of the Federal Clean Air Act and the Georgia Air Quality Act andlor State rules and is grounds for enforcement action; for Permit termination, revocation and reissuance, or modification; or for denial of a Permit renewal application. Any noncompliance with a Permit condition specifically designated as enforceable only by the State constitutes 

### a violation of the Georgia Air Quality Act andlor State rules only and is grounds for enforcement action; for Pennit termination, revocation and reissuance, or modification; or for denial of a Permit renewal application. [391-3-1-.03(10)(d)l(i) and 40 

### CFR 70.6(a)(6)(i)] The Permittee shall not use as a defense in an enforcement action the contention that it would have been necessary to halt or reduce the Permitted activity in order to maintain compliance with the conditions ofthis Permit. [391-3-1-.O3(lO)(d)l(i) and 40 CFR 70.6(a)(6)(ii)] Nothing in this Permit shall alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time ofPermit issuance. [391-3-1-.03(10)(d)l(i) and 40 CFR 70.6(f)(3)(ii)]

Page 59 of72Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 8.3.4 Issuance of this Permit does not relieve the Permittee from the responsibility of obtaining any other permits, licenses, or approvals required by the Director or any other federal, state, or local agency. [391-3-1-.03(1 0)(e)l(iv) and 40 CFR 70.7(a)(6)] 

### 8.4 Fee Assessment and Payment 8.4.1 The Permittee shall calculate and pay an annual Permit fee to the Division. The amount of fee shall be determined each year in accordance with the "Procedures for Calculating Air Permit Fees." [391-3-1-.03(9)] 8.5 Permit Renewal and Expiration This Permit shall remain in effect for five (5) years from the effective date. The Permit shall become null and void after the expiration date unless a timely and complete renewal application has been submitted to the Division at least six (6) months, but no more than eighteen (1

### 8)months prior to the expiration date ofthe Permit. [391-3-1-.03(l0)(d)l(i), (e)2, and (e)3(ii) and 40 CFR 70.5(a)(l)(iii)] Permits being renewed are subject to the same procedural requirements, including those for public participation and affected State and EPA review, that apply to initial Permit issuance. [391-3-1-.03(10)(e)3(i)] Notwithstanding the provisions in Condition No. 8.5.1 above, if the Division has received a timely and complete application for renewal, deemed it administratively complete, and failed to reissue the Permit for reasons other than cause, authorization to operate shall continue beyond the expiration date to the point of Permit modification, reissuance, or revocation. [391-3-1-.03(10)(e)3(iii)] 

### 8.6 Transfer of Ownership or Operation 8.6.1 This Permit is not transferable by the Permittee. Future owners and operators shall obtain a new Permit from the Director. The new Permit may be processed as an administrative amendment if no other change in this Permit is necessary, and provided that a written agreement containing a specific date for transfer of Permit responsibility coverage and liability between the current and new Pennittee has been submitted to the Division at least thirty (30) days in advance ofthe transfer. [391-3-1-.03(4)] 8.7 Property Rights 8.7.1 This Permit shall not convey property rights of any sort, or any exclusive privileges. [391-3-1-.O3(l0)(d)l(i) and 40 CFR 70.6(a)(6)(iv)]

Page 60 of 72TitleV Permit International Paper - Savannah Permit No.: 2631-051 -0007-V-02-0 8.8 Submissions 

### Reports, test data, monitoring data, notifications, annual certifications, and requests for revision and renewal shallbe submitted to: Georgia Department ofNatural Resources Environmental Protection Division Air Protection Branch Atlanta Tradeport, Suite 120 4244 International Parkway Atlanta, Georgia 30354-3908 

### Any records, compliance certifications, and monitoring data required by the provisions in this Permit to be submitted to the EPA shall be sent to: Air and EPCRA Enforcement Branch -

### U. S. EPA Region 4 SamNunn Atlanta Federal Center 61 Forsyth Street, SW Atlanta, Georgia 30303-3104 

### Any application form, report, or compliance certification submitted pursuant to this Permit shall contain a certification by a responsible official of its truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. [391-3-1-.03(lO)(c)2,40 CFR 70.5(d) and 40 CFR 70.6(~)(1)] Unless otherwise specified, all submissions under this pennit shall be submitted to the Division only. 8.9 Duty to Provide Information 

### 8.9.1 The Permittee, upon becoming aware that any relevant facts were omitted or incorrect information was submitted in the Permit application, shall promptly submit such supplementary facts or corrected information tothe Division. [391-3-1-.03(10)(~)5] 8.9.2 The Permittee shall furnish to the Division, in writing, information that the Division may request to determine whether cause exists for modifying, revoking and reissuing, or terminating the Permit, or to determine compliance with the Permit. Upon request, the Permittee shall also furnish to the Division copies ofrecords that the Permittee is required to keep by this Permit or, for information claimed to be confidential, the Permittee may finish such records directly to the EPA, if necessary, along with a claim of confidentiality. [391-3-1-.03(10)(d)l(i) and 40 CFR 70.6(a)(6)(v)]

Page 61 of 72Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 8.10 Modifications 8.10.1 Prior to any source commencing a modification as defined in Georgia Rule 391-3-1-.01(pp) that may result in air pollution and not exempted by Georgia Rule 391-3-1-.03(6), the Permittee shall submit a Permit application to the Division. The application shall be submitted sufficiently in advance of any critical date involved to allow adequate time for review, discussion, orrevision ofplans, ifnecessary. Such application shall include, but not be limited to, information describing the precise nature of the change, modifications to any emission control system, production capacity of the plant before and after the change, and the anticipated completion date of the change. The application shall be in the form of a Georgia Air Quality Permit application to construct or modify (otherwise known as a SIP application) and shall be submitted on forms supplied by the Division, unless otherwise notified by the Division. [391-3-1-.03(1)through (8)] 8.11 Permit Revision, Revocation, Reopening and Termination 8.1 1.1 This Permit may be revised, revoked, reopened and reissued, or terminated for cause by the Director. The Permit will be reopened for cause and revised accordingly under the following circumstances: 

### [391-3-1-.03(10)(d)l(i)]
a. If additional applicable requirements become applicable to the source and the remaining Permit term is one (1) year or longer. In this case, the reopening shall be completed no later than eighteen (18) months after promulgation of the applicable requirement. A reopening shall not be required if compliance with the applicable requirement isnot required until after the date on which the Permit is due to expire; [391-3-1-.03(1O)(e)6(i)(I)] b. If any additional applicable requirements of the Acid Rain Program become applicable to the source; [391 -3- 1 -.03(1O)(e)6(i)(11)] (Acid Rain sources only)
c. The Director determines that the Permit contains a material mistake or inaccurate statements were made in establishing the emissions standards or other terms or conditions ofthe Permit; or [391-3-l-.03(1O)(e)6(i)(III)and 40 CFR 70.7(f)(l)(iii)] d. The Director determines that the Permit must be revised or revoked compliance with the applicable requirements. 

### [391-3-1-.03(10)(e)6(i)(IV) and 40 CFR 70.7(f)(l )(iv)] 8.1 1.2 Proceedings to reopen and reissue a Permit shall follow the same procedures as to initial Permit issuance and shall affect only those parts of the Permit for which cause to reopen exists. Reopenings shall be made as expeditiously as practicable. 

### [391-3-1-.03(1O)(e)6(ii)] to assure
applicable

Page 62 of 72International Paper -Savannah TitleV Permit Permit No.: 263 1-051-0007-V-02-0 Reopenings shall not be initiated before a notice ofintent to reopen isprovided to the source by the Director at least thirty (30) days in advance of the date the Permit is to be reopened, except that the Director may provide a shorter time period in the case of an emergency. [391-3-1-.03(1O)(e)6(iii)] All Permit conditions remain in effect until such time as the Director takes final action. The filing of a request by the Permittee for any Permit revision, revocation, reissuance, or termination, or of a notification ofplanned changes or anticipated noncompliance, shall not stay any Permit condition. [391-3-1-.O3(lO)(d)l(i) and 40 CFR 70.6(a)(6)(iii)] 

### A Permit revision shall not be required for changes that are explicitly authorized by the conditions ofthis Permit. 

### A Permit revision shall not be required for changes that are part of an approved economic incentive, marketable Permit, emission trading, or other similar program or process for change which is specificallyprovided for in this Permit. [391-3-1-.03(10)(d)l(i) and 40 

### CFR 70.6(a)(8)] 8.12 Severability 8.12.1 Any condition or portion of this Permit which is challenged, becomes suspended or is ruled invalid as a result of any legal or other action shall not invalidate any other portion or condition ofthis Permit. [391-3-1-.03(10)(d)l(i) and 40 CFR 70.6(a)(5)] 8.13 Excess Emissions Due to an Emergency An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under the Permit, due to unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused 

### by improperly designed equipment, lack ofpreventative maintenance, careless or improper operation, or operator error. [391-3-1-.03(1O)(d)7 and 40 CFR 70.6(g)(l)] An emergency shall constitute an affirmative defense to an action brought for noncompliance with the technology-based emission limitations if the Permittee demonstrates, through properly signed contemporaneous operating logs or other relevant evidence, that: [391-3-1-.03(10)(d)7 and 40 CFR 70.6(g)(2) and (3)]
a. An emergency occurred and the Permittee can identify the cause(s) of the emergency; b. The Pennitted facility was at the time ofthe emergency being properly operated;

Page 63 of72Title V Permit International Paper - Savannah Permit No.: 2631-05 1-0007-V-02-0
c. During the period of the emergency, the Permittee took all reasonable steps to minimize levels of emissions that exceeded the emissions standards, or other requirements in the Permit; and d. The Permittee promptly notified the Division and submitted written notice of the emergency to the Division within two 

### (2) working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. 8.13.3 In an enforcement proceeding, the Pennittee seeking to establish the occurrence of an emergency shall have the burden ofproof. [391-3-1-.03(1O)(d)7 and 40 

### CFR 70.6(g)(4)] 8.13.4 The emergency conditions listed above are in addition to any emergency orupset provisions contained in any applicable requirement. [391-3-1-.03(lO)(d)7 and 40 

### CFR 70.6(g)(5)] 8.14 Compliance Requirements 8.14.1 Compliance Certification The Permittee shall provide written certification to the Division and to the EPA, at least annually, of compliance with the conditions of this Permit. The annual written certification shall be postmarked no later than January 30 of each year and shall be submitted to the Division and to the EPA. Thecertification shall include, but not be limited to, the following elements: [391-3-1 -.03(1O)(d)3 and 40 

### CFR 70.6(~)(5)]
a. The identification of each term or condition of the Permit that is the basis of the certification; b. The status of compliance with the terms and conditions of the permit for the period covered by the certification, including whether compliance during the period was col~tinuous or intermittent, based on the method or means designated in paragraph c below. The certification shall identify each deviation and take it into account in the compliance certification. The certification shall also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance as defined under 40 

### CFR Part 64occurred;
c. The identification of the method(s) or other means used by the owner or operator for determining the compliance status with each term and condition during the certification period; d. Any other information that must be included to comply with section 113(c)(2) of the Act, which prohibits knowingly making a false certification or omitting material information; and
e. Any additional requirements specified by the Division. Page 64 of 72

### Title V 

### Permit International Paper - Savannah Permit No.: 263 1-051-0007-V-02-0 8.13.2 Inspection and Entry a. Upon presentation of credentials and other documents as may be required by law, the Permittee shall allow authorized representatives of the Division to perform the following: [391-3-1-.03(10)(d)3 and 40 CFR 70.6(~)(2)] i. Enter upon the Permittee's premises where a Part 70 source is located or an emissions-related activity is conducted, or where records must be kept under the conditions ofthis Permit;

. . 11. Have access to and copy, at reasonable times, any records that must be kept under the conditions ofthis Permit;

... 111. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this Permit; and iv. Sample or monitor any substances or parameters at any location during operating hours for the purpose of assuring Pesmit compliance or compliance with applicable requirements as authorized by the Georgia Air Quality Act. b. 

### No person shall obstruct, hamper, or interfere with any such authorized representative while in the process of carrying out his official duties. Refusal of entry or access may constitute grounds for Permit revocation and assessment of civil penalties. [391-3-1-.O7 and 40 CFR 70.1l(a)(3)(i)] 8.14.3 Schedule of Compliance
a. For applicable requirements with which the Permittee is in compliance, the Permittee shall continue to comply with those requirements. [391-3-1-.O3(lO)(c)2 and 40 CFR 70.5(c)(S)(iii)(A)] b. For applicable requirements that become effective during the Permit term, the Permittee shall meet such requirements on a timely basis unless a more detailed schedule is expressly required by the applicable requirement. [391-3-1 -.O3(lO)(c)2 and 40 CFR 70.5(c)(8)(iii)(B)]
c. Any schedule of compliance for applicable requirements with which the source is not in compliance at the time of Permit issuance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based. [391-3-1-.03(1O)(c)2 and 40 CFR 70S(c)(8)(iii)(C)]

Page 65of 72Title V Permit International Paper -Savannah Permit No.: 2631-051-0007-V-02-0 8.14.4 Excess Emissions
a. Excess emissions resulting from startup, shutdown, or malfunction of any source which occur though ordinary diligence is employed shall be allowed provided that: [391-3-1-.02(2)(a)7(i)] i. Thebest operational practices to minimize emissions are adhered to;

. . 11. All associated air pollution control equipment is operated in a manner consistent with good air pollution control practice for minimizing emissions; and

. . . 111. The duration of excess emissions is minimized. b. Excess emissions which are caused entirely or in part by poor maintenance, poor operation, or any other equipment or process failure which may reasonably be prevented during startup, shutdown or malfunction are prohibited and are violations of Chapter 391-3-1 ofthe Georgia Rules for Air Quality Control. [391-3-1-.02(2)(a)7(ii)]
c. Theprovisions ofthis condition and Georgia Rule 391-3-1-.02(2)(a)7 shall apply only to those sources which are not subject to any requirement under Georgia Rule391-3-1-.02(8) - New Source Performance Standards or any requirement of 40 CFR, Part 60, as amended concerning New Source Performance Standards. [391-3-1-.02(2)(a)7(iii)] 

### 8.15 Circumvention 8.15.1 State Only Enforceable Condition The Permittee shall not build, erect, install, or use any article, machine, equipment or process the use of which conceals an emission which would otherwise constitute a violation of an applicable emission standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard which is based on the concentration of the pollutants in the gases discharged into the atmosphere. [391-3-1-.03(2)(~)] 

### 8.16 Permit Shield 8.16.1 Compliance with the terns of this Permit shall be deemed compliance with all applicable requirements as of the date of Permit issuance provided that all applicable requirements are included and specifically identified in the Pesmit. [391-3-1-.03(lO)(d)6] 8.16.2 Any Pennit condition identified as "State only enforceable" doesnot have a Pesmit shield.

Page 66 of 72Title V Permit International Paper - Savannah Permit No.: 2631-051 -0007-V-02-0 8.17 Operational Practices 8.17.1 At all times, including periods of startup, shutdown, and malfunction, the Permittee shall maintain and operate the source, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on any information available to the Division that may include, but is not limited to, monitoring results, observations of the opacity or other characteristics of emissions, review of operating and maintenance procedures or records, and inspection or surveillance ofthe source. [391-3-1-.02(2)(a)lO] State Only Enforceable Condition 8.17.2 No person owning, leasing, or controlling, the operation of any air contaminant sources shall willfully, negligently or through failure to provide necessary equipment or facilities or to take necessary precautions, cause, permit, or allow the emission from said air contamination source or sources, of such quantities of air contaminants as will cause, or tend to cause, by themselves, or in conjunction with other air contaminants, a condition of air pollution in quantities or characteristics or of a duration which is injurious or which unreasonably interferes with the enjoyment of life or use 

### of property in such area of the State as is affected thereby. Complying with Georgia's Rules for Air Quality Control Chapter 391-3-1 and Conditions in this Permit, shall in no way exempt a person from this provision. [391-3-1-.02(2)(a)l] 8.18 Visible Emissions 8.18.1 Except as may be provided in other provisions of this Permit, the Permittee shall not cause, let, suffer, permit or allow emissions from any air contaminant source the opacity of which is equal to or greater than forty (40)percent. [391-3-1-.02(2)(b)1] 8.19 Fuel-burning Equipment 8.19.1 The Permittee shall not cause, let, suffer, permit, or allow the emission of fly ash and/or other particulate matter from any fuel-burning equipment with rated heat input capacity of less than 10 million Btu per hour, in operation orunder construction on or before January 1, 1972 in amounts equal to or exceeding 0.7pounds per million BTU heat input. [391-3-1-.02(2)(d)] 8.19.2 The Permittee shall not cause, let, suffer, permit, or allow the emission of fly ash and/or other particulate matter from any fuel-burning equipment with rated heat input capacity of less than 10 million Btu per hour, constructed after January 1, 1972 in amounts equal to or exceeding 0.5 pounds per million BTU heat input. [391-3-1-.02(2)(d)]

Page 67 of72Title V Permit International Paper -Savannah Permit No.: 2631-051-0007-V-02-0 

### 8.19.3 The Permittee shall not cause, let, suffer, permit, or allow the emission from any fuelburning equipment constructed or extensively modified after January 1, 1972, visible emissions the opacity of which is equal to or greater than twenty (20) percent except for one six minuteperiod per hour ofnot more than twenty-seven (27)percent opacity. [391-3-1 -.02(2)(d)] 8.20 Sulfur Dioxide 

### 8.20.1 Except as may be specified in other provisions of this Permit, the Permittee shall not bum fuel containing more than 2.5 percent sulfur, by weight, in any fuel burning source that has a heat input capacity below 100million Btu's per hour. [391-3-1-.02(2)(g)] 8.21 Particulate Emissions 

### Except as may be specified in other provisions of this Permit, the Permittee shall not cause, let, permit, suffer, or allow the rate of emission from any source, particulate matter in total quantities equal to or exceeding the allowable rates shown below. Equipment in operation, or under construction contract, on or before July 2, 1968, shall be considered existing equipment. All other equipment put in operation or extensively altered after said date is to be considered new equipment. [391-3-1-.02(2)(e)]

a. 

### The following equations shall be used to calculate the allowable rates of emission from new equipment: 

### E =

### 4.1~' 67 ;

### for process input weight rate up to and including 30 tons per hour (tph). 

### E =

### 55PO.l' -40 ;

### forprocess input weight rate above 30 tons per hour (tph). b. The following equation shall be used to calculate the allowable rates of emission from existing equipment:

In the above equations, 

### E =

### emission rate in pounds per hour (lbhr), and P =

### process input weight rate in tons per hour (tph).

Page 68 of72Title V Permit International Paper - Savannah Permit No.: 263 1-051-0007-V-02-0 822 Ftrpitive Dust [391-3-1-.02(2)(n)] 8.22.1 Except as may be specified in other provisions of this Permit, the Pennittee shall take all reasonable precautions to prevent dust from any operation, process, handling, transportation or storage facility from becoming airborne. Reasonable precautions that could be taken to prevent dust from becoming airborne include, but are not limited to, the following:
a. Use, where possible, of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads or the clearing of land; b. Application of asphalt, water, or suitable chemicals on dirt roads, materials, stockpiles, and other surfaces that can giverise to airborne dusts;
c. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty materials. Adequate containment methods can be employed during sandblasting or other similar operations; d. Covering, at all times when in motion, open bodied trucks transporting materials likely to giverise to airborne dusts; and
e. Theprompt removal of earth or other material from paved streets onto which earth or other material hasbeen deposited. 8.22.2 The opacity from any hgitive dust source shall not equal orexceed 20 percent. 8.23 Solvent Metal Cleaning 8.23.1 Except as may be specified in other provisions of this Permit, the Permittee shall not cause, suffer, allow, or permit the operation of a cold cleaner degreaser unless the following requirements for control ofemissions ofthe volatile organic compounds are satisfied: [391-3-1-.02(2)(ff)l]
a. The degreaser shall be equipped with a cover to prevent escape of 

### VOC during periods ofnon-use, b. The degreaser shall be equipped with a device to drain cleaned parts before removal from the unit, c. If the solvent volatility is 0.60 psi or greater measured at 100 

### "F, or if the solvent is heated above 120

### "F, then one ofthe following control devices must be used: i. The degreaser shall be equipped with a freeboard that gives a freeboard ratio of 0.7 or greater, or

.. 11. The degreaser shall be equipped with a water cover (solvent must be insoluble in and heavier than water), or
Page 69 of 72

### Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0

.

### .. 111. The degreaser shall be equipped with a system of equivalent control, including but not limited to, a refrigerated chiller or carbon adsorption system. d. Any solvent spray utilized by the degreaser must be in the form of a solid, fluid stream (not a fine, atomized or shower type spray) and at a pressure which will not cause excessive splashing, and
e. All waste solvent from the degreaser shall be stored in covered containers and shall not be disposed of by such a method as to allow excessive evaporation into the atmosphere. 8.24 Incinerators Except as specified in the section dealing with conical burners, no person shall cause, let, suffer, permit, or allow the emissions of fly ash and/or other particulate matter from any incinerator, in amounts equal to or exceeding the following: [391-3-1-.02(2)(c)l-41
a. Units with charging rates of 500 pounds per hour or less of combustible waste, including water, shall not emit fly ash and/or particulate matter in quantities exceeding 1.0pound per hour. 

### b. Units with charging rates in excess of 500 pounds per hour of combustible waste, including water, shall not emit fly ash and/or particulate matter in excess of 0.20 pounds per 100pounds of charge. No person shall cause, let, suffer, permit, or allow from any incinerator, visible emissions the opacity of which is equal to or greater than twenty (20) percent except for one six minute period per hour ofnot more than twenty-seven (27) percent opacity. No person shall cause or allow particles to be emitted from an incinerator which are individually large enough to be visible to theunaided eye. No person shall operate an existing incinerator unless:
a. 

### It is a multiple chamber incinerator; b. It is equipped with an auxiliary burner in the primary chamber for the purpose of creating a pre-ignition temperature of 800oF; and
c. It has a secondary burner to control smoke and/or odors and maintain a temperature of at least 1500°Fin the secondary chamber.

Page 70 of 72Title 

### V Permit International Paper - Savannah
-- Permit No.: 2631-051-0007-V-02-0 8.25 h'olatile Organic Liquid Handling and Storage 8.25.1 The Permittee shall ensure that each storage tank subject to the requirements of Georgia Rule 391-3-1-.02(2)(w) "Volatile Organic Liquid Handling and Storage" is equipped with submerged 

### fill pipes. For the purposes of this condition and the pennit, a submerged fill pipe is defined as any fill pipe with a discharge opening which is within six inches of the tank bottom. [391-3-1-.02(2)(~)(1)] 

### 8.26 Use of Any Credible Evidence or Information 8.26.1 Notwithstanding any other provisions of any applicable rule or regulation or requirement of this permit, for the purpose of submission of compliance certifications or establishing whether or not a person has violated or is in violation of any emissions limitation or standard, nothing in this permit or any Emission Limitation or Standard to which it pertains, shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been perfonned. [391-3-1-.O2(3)(a)] 8.2'7 Uiesei-Fired Internal Combustion Engines 8.27.1 The Permittee shall comply with all applicable provisions of New Source Performance Standards (NSPS) Federal Rule 40 CFR Part 60 Subpart A-"General Provisions" and Subpart 1111-"Standards for Stationary Compression Ignition Internal Combustion Engines," for diesel-fired internal combustion engineis) manufactured after April 1, 2006 or modifiedlreconstructed after July 11, 2005. Such requirements include but are not limited to: [40 CFR 60.4205(b), 391-3-1-.02(8)(b)77 ]
a. Equip all emergency generator engines with non-resettable hour meters b. Use only diesel fuel with a maximum sulfur content of 500 parts per million (ppm) (15 ppm after October 1,2010) unless otherwise specified by the Division.

Page 71 of72TitleV Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 Attachments A. 

### List of Standard Abbreviations and List ofPermit Specific Abbreviations 

### B. Insignificant Activities Checklist, Insignificant Activities Based on Emission Levels and Generic Emission Groups 

### C. List ofReferences

Page 72 of72

### Title V 

### Permit International Paper - Savannah Permit No.: 2631-051 -0007-V-02-0 

### ATTACHMENT A List Of StandardAbbreviations 1 AIRS I Aerometric Information Retrieval Svstem I 

# 1 APCD 

# 1 Air Pollution Control Device

ASTM 

## I American Society for Testing and Materials BACT 

### / Best Available Control Technoloev
-2 BTU 

## I British Thermal Unit CAAA 

## I Clean Air Act Amendments

CO 

## I Carbon Monoxide COM 

### I Continuous Ovacitv Monitor CFR CMS
dscfldsc~n Dry Standard Cubic FootIDry Standard Cubic Meter United States Environmental Protection Agency EPCRA Emergency Planning and Conlmunity Right to Know Act '+. Code ofFederal Reguiations ContinuousMonitoring S ystem(s)



## / Grain(~) GPM (mm) 

### / Gallons Der minute 

## \".

z ~-H;O (H20) 

## i Water 

## 1 [ HAP 

## 1 Hazardous Air Pollutant HCFC 

### / Hydro-chloro-fluorocarbon MACT 

### / Maximum Achievable Control Technolow 

### .,. 

## I MMBtu 

### I Million British Thermal Units
Megawatt 

# 1 ::HAP 

# I National Emission Standards for Hazardous Air

# I

MMBtuIhr MVAC 

## I I ~ollutants 

## I Million British Thermal Units per hour Motor Vehicle Air Conditioner 

### NO, Nitrogen Oxides

NSPS 

## I New SourcePerformance Standards 

## 1OCGA 

## 1 Official Code of Georgia Annotated Particulate Matter

RMP 

### / Risk Management Plan SIC 

### I Standard Industrial Classification I SIP I State Imdementation Plan 1

SO2 (SO2) 

## 1 SulhrDioxide 

## I USC 

## I United States Code

- -

VE 

## I Visible Emissions VOC 

### I Volatile Oreanic Comuound

List of Permit Specific Abbreviations

~TUBPOven-Dried Tons ofUnbleached Pulp

CAM 

### LVHC NCG

Appendix Page 1 of 7 Compliance Assurance Monitoring Low Volume, High Concentration Non-Condensable Gases HVLC NAAQS PSEU High Volume, Low Concentration National Ambient Air Quality Standard Pollutant-S~ecific Emission Unit

### Title V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 

### ATTACHMENT B NOTE: Attachment B contains information regarding insignificant emission unitslactivities and groups of generic emission unitslactivities in existence at the facility at the time of Permit issuance. Future modifications or additions of insignificant emission unitslactivities and equipment that are part of generic emissions groups may not necessarily cause this attachment to be updated.

Combustion Equipment

Maintenance, Cleaning, and Housekeeping I 1. Fire fighting and similar safety equipment used to train firetighters or other emergency 1 INSIGNIFICANT ACTIVITIES CHECKLIST

personnel. 2. Small incinerators that are not subject to any standard, limitation or other requirement under Section 1 11 or 112 (excluding 1 12(r)) ofthe Federal Act and are not considered a "designated facility" as specified in 40 CFR 60.32e of the Federal emissions guidelines for Hospital/MedicallInfectious Waste Incinerators, that are operating as follows: Description ofInsignificantActivitylUnit 1. Cleaning and sweeping of streets and paved surfaces

i) Less than 8 million BTUlhr heat input, firing types 0, 1,2, andor3 waste. 

# I Quantity 1

ii) Less than 8million BTU/hr heat input with no more than 10% pathological (type4) waste by weight combined with types 0, 1,2, and/or 3 waste. iii) Less than 4 million BTUhrheat input firing type 4 waste. (Referto 391-3-1-.03(10)(g)2.(ii) for descriptions of waste types) 3. Open burning in compliancewith Georgia Rule 39 1-3-1-.02 (5). I 4. Stationary enginesburning: i) Natural gas, LPG, gasoline, dual fuel, or diesel fuel which are used exclusively as emergency generators shall not exceed 500 hours per year or 200 hours per year if subject to Georgia Rule 391 -3-1-.02(2)(1nmnm).7 ii) Natural gas, LPG, and/or diesel fueled generators used for emergency, peaking, andlor standby power generation, where the combined peaking and standby power generation do 

# 1

not exceed 200 hours per year. iii) Natural gas, LPG, andlor diesel fuel used for other purposes, provided that the output of each engine does not exceed 400 horsepower and that no individual engine operates for more than 2,000 hours per year. iv) Gasolineused for otherpurposes, provided that the output of each engine does not exceed 100horsepower and that no individual engine operates for more than 500 hours per year. 1. Brazing, soldering, and welding equipment, and cutting torches related to manuhcturing and construction activities whose emissions of hazardous air pollutants (HAPS)fall below 1,000 150 pounds per year. I. Blast-cleaning equipment using a suspension of abrasive in water and any exhaust system (or collector) serving them exclusively. 1 2. Portable blast-cleaning equipment.

afterburners. 7. Cleaning operations: Alkaline phosphate cleaners and associated cleaners and burners. 3 of clothes. 4. Cold cleaners having an airhapor interface of not more than 10 square feet and that do not use a halogenated solvent. 5. Non-routine clean out of tanks and equipment for the purposes of worker entry or in preparation for maintenance or decommissioning. 6. Devices used exclusively for cleaningmetal parts or surfaces by burning ofiresidual amounts of paint, varnish, or other foreign material, provided that such devices are equipped with

Appendix Page 2 of 7 3. Non-Perchloroethylene Dry-cleaning equipment with a capacity of 100 pounds per hour or less
3 1Title V Permit International Paper -- Savannah
-- Pennit No.: 2631-051-0007-V-02-0

Category Laboratories and Testing

Pollution Control

industrial Operations INSIGNIFICANT ACTIVITIES CHECKLIST Description of InsignificantActivityIUnit 1. Laboratory fume hoods and vents associated with bench-scale laboratory equipment used for - .. physical orchemical analysis. 2. Research and development facilities, quality control testing facilities and/or small oilot orojects,

. - - 

### . where combined daily emissionsfrom all operations are not individually major or are support facilities not making significant contributions to the product ofa collocated major manufacturing facility. 1. Sanitary waste water collection and treatment systems, except incineration equipment or equipment subject to any standard, limitation or otherrequirement under Section 111 or 112 (excluding 1 12(r))of the Federal Act. 2. On site soil orgroundwater decontamination units that are not subject to any standard. limitation or other requirement under Section 1 11 or 1 12 (excluding 1 12(r)) of the Federal Act. 3. Bioremediation operations units that are not subject to any standard, limitation orother requirement under Section 1 1 1 or 112 (excluding Il2(r)) ofthe Federal Act. 4. Landfills that are not subject to any standard, limitation or other recluirement under Section 111 or 1 12 (excluding 1 I2(r)) ofthe ~ederal Act. 1. Concreteblock and brick plants, concreteproducts plants, and ready mix concreteplants producing less than 125,000 tons per year. 2. Any of the following processes orprocess equipment which are electrically heated or which tire natural gas, LPG or distillate fuel oil at a maximum total heat input rate of not more than 5 million BTU's pcr hour: i) Furnaces for heat treating glass ormetals, the use ofwhich donot involve molten materials or oil-coated parts. ii) Porcelain enameling furnaces orporcelain enameling drying ovens. iii) Kilns for tiling ceramic ware i) Crucibletun~aces, pot furnaces, or induction melting and holding furnaces with a capacity of 1,000 pounds or less each, in which sweating or distilling is not conducted and in which fluxing is not conducted utilizing free chlorine, chlorideortluo~ide derivatives, or ammonium compounds. v) Bakery ovens and confection cookers. 3. Carving, cutting, routing, turnhg, drilling, machining, sawing, stirface grinding, sanding, planing. bufting, shot blasting, shot peening, orpolishing; ceramics, glass, leather, metals, plastics, rubber, concrete, paper stock or wood, also including roll grinding and ground wood pulping stone sharpening, provided that: i Activity is oerformed indoors: & 

### -. ii) No significant fugitive particulate emissionsenter the environment; Xr iii) No visible emissions enter the outdoor atmosphere. 4. Photographic process equipment by which an image is reproduced upon material sensitized to

. . - radiant energy (e.g., blueprint activity, photographic developing and microfiche). 5. Grain, food, or mineral extrusion processes 6. Equipment used exclusively for sintering ofglass or metals, but not including equipment used - .. for sintering metal-bearing ores, metal scale, clay, fly ash, ormetal compounds. 7. Equipment forthe mining and screening of uncrushed native sand and gravel. 8. Ozonization process orprocess equipment. 9. Electrostatic powder coating booths with an appropriately designed and operated particulate control system. 10.Activities involving the application ofhot melt adhesives where VOC emissions areless than 5 tons per year and HAP emissions are less than 1,000 pounds per year. 1 1.Equipment used exclusively for the mixing and blending water-based adhesives and coatings at ambient temperatures. 12.Equipment used for compression, molding and injection ofplastics where VOC emissions are less than 5 tons per year and HAP emissions are less than 1,000pounds per year. 13.Ultraviolet curing processes where VOC emissions areless than 5 tons per year and HAP emissions are less than 1,000pounds per year. Quantity

Appendix Page 3of 7Title V Permit International Paper -Savannah Permit No.: 263 1-051-0007-V-02-0



### Category Storage Tanks and Equipment INSIGNIFICANT ACTIVITIES CHECKLIST Description of InsignificantActivity/Unit 

## I Quantity 1. All petroleum liquid storagetanks storing a liquid with a true vapor pressure of equal to or less 

### I 3 than 0.50psia as stored. 2. All petroleum liquid storagetanks with a capacity of less than 40,000 gallons storing a liquid with a true vapor pressure of equal to or less than 2.0 psia as stored that are not subject to any standard, limitation or other requirement under Section 11 1 or 1 12 (excluding 1 12(r)) ofthe

INSIGNIFICANT ACTIVITIES BASED ON EMISSION LEVELS J

Federal Act. 3. All petroleum liquid storagetanks with a capacity of less than 10,000 gallons storing a petroleum liquid. 4. All pressurized vessels designed to operate in excess of 30 psig storing petroleum fuels that are not subject to any standard, limitation or other requirement under Section 11 1 or 1 12 (excluding I 12(r)) ofthe Federal Act. 5. Gasoline storage and handling equipment at loading facilities handling less than 20,000 gallons per day or at vehicle dispensing facilitiesthat are not subject to any standard, limitation or other requirement under Section 111 or 1 12 (excluding 1 12(r))ofthe Federal Act. 6. Portable drums, barrels, and totes provided that the volume of each container does not exceed 550 gallons. 7. All chemical storagetanks used to store a chemical with a true vapor pressure of less than or equal to 10millimeters of mercury (0.19 psia).

-. - - - - - Description ofEmission UnitsIActivities Quantity 5
550 250

Core Drying Unit 1 Mixing and Storage Tanks for Power Boiler Chemicals Odor Scrubbing of Emergency Process Venting Paint Spray Booth SewerVent Fan

Appendix Page 4 of 7 16 2 1 1 Solvent Recycle Still 1

### Title V Permit International Paper - Savannah Permit No.: 263 1-051-0007-V-02-0 ATTACHMENT 

### B (continued) GENERICEMISSION GROUPS
Emiss~on unitslactivities appearing in the Sollowing table are subject only to one 01- more of Geol-gia Rules 301-3-1-.02 (2) (b), (e) &/or (n). Potential emissions ofparticulate matter, from these sources based on TSP, are less than 25 tons per year per process line or unit in each group. Any emissions unit subject to a NESHAP, NSPS, or any specific Air Quality Permit Condition(s) arenot included in this table. Description

### of EmissionsUnitslActivities (Source Code)
Box Plant Trim Cyclones (CYCL) Coal Conveyors (GE01) Coal Pile (GE02) Coal Silos (GE03) Coal Unloading Station (GE04) Coal Crushers (GE05) - -

I clescoping Chute (GE06)

- - 1rmsier Tower (GE07) Coal Vibrating Feeders (GE08) Bark Conveying Systems (GE09) 2 8 1 4

Bark Metering Bins (GEI0) Bark Hoggers (GE11) Bark Piles (GE 12) Air Density SeparatorCyclones (GE13) Scalping Screens (GE14) K2 ChpScreen Fines Cyclone (GEI5) Primary and Secondary Chip Screens (GE16) Chip Bins (GE17) Fines Bunker (GE18) Slicers (GEI9) 1 2 1 1 2 10

Black Clawson Screen (GE20) Fines BlowerISeparator (GE21) Rader Blower Chip Cyclone (GE22) Rejects Bunker (GE23) Ash Silos (GE24) Ash Unloading Stations (GE25) Ash Silo Condensers (GE26)

-

-- Appendix Page 5 of 7 J J J J

2 3 2 3 3 1 4 3 1 2

Chip Piles (GE27) J J J J J J

1 1 1 2 2 2 2 V' J

J J J J J J J J J J

3 J J J

J J J J J

J J J J J J J J J J J J J J J
J J J J

J

J J J J J J J J J J J J J J

J

J J J J J J J J J- - -. -

International Paper -Savannah Title V 

### Permit Permit No.: 2631-051-0007-V-02-0 Description ofEmissions UnitslActivities (Source Code) ApplicableRules Number ofUnits FugitiveDust 'psfi' 

### MQ ~rocess (if 

### Rule (h) Ralc (n) Rule (e) LogPile (GE28) 1 J J Debarkmg Drums (GE29) 1 J J J Chip Conveyors (GE30) 34 J J Chip Hogs (GE31) 1 J J J Hog Cyclone (GE32) 1 J J 4 Hydrapulpers (GE34) 3 J J J 

# I Maintenance Dust Collector (GE35) 

# I 1 

# IJIJIJ

Starch Silo (STCH) 1 J J

Thefollowing table includes groups offuel butning equipment subject only to Georgia Rules 391-3-b.02 (2)(b)& (d).Any emissions unit subject to a NESHAP, NSPS, or any specific Air Quality Pennit Condition(s)are tlot included in this table. r I 1 Description of Fuel Burning Equipment Fuel burning equipment with a rated heat input capacity of less than I0 million BTUlhrburning only natural gas andlor LPG. Fuel burning equipment with a rated heat input capacity of less than 5 million BTUlhr, burning only distillate fuel oil,natural gas andlor LPG.

Appendix Page 6 of 7 Number ofUnits 

### 0 

### 0 Any fucl bunling equipment with a ratctl heat input capacity of 1 million BTUlhr orless. 

### 0 

# I

### Title 

### V Permit International Paper - Savannah Permit No.: 2631-051-0007-V-02-0 

### ATTACHMENT C 

### LIST OF REFERENCES I. The Georgia Rules for Air Quality Control Chapter 391-3-1. All Rules cited herein which begin with 391-3-1 are StateAir Quality Rules. 2. Title40 ofthe Code of Federal Regulations; specifically40 CFR Pasts 50, 51, 52, 60, 61, 63, 64, 68, 70, 72, 73, 75, 76 and 82. All rules cited with these pasts are Federal Air Quality Rules. 3. Georgia Department of Natural Resources, Environmental Protection Division, Air Protection Branch, Procedures for TestingandMonitoring Sources of Air Pollutants. 4. Georgia Department of Natural Resources, Environmental Protection Division, Air Protection Branch, Procedures for Calculating Air Permit Fees. 5. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume 

### I: Stationary Point and Area Sources. This information may be obtained from EPA's TTN web site at ~~ww.epa.go1)/ttn/chiqf/ap42.html. 6. The latest properly functioning version of EPA's 

### TANKS emission estimation software. The software may be obtained from EPA'sTTN web site at ~~tzw.epa.go~~/ttn/chief/tanks.html. 7. TheClean Air Act (42 U.S.C. 7401 et seq). 8. White Paper for Streamlined Development of Past 70 Permit Applications, July 10, 1995 (White Paper #I). 9. White Paper Number 2 for Improved Implementation ofthe Past 70 Operating Permits Progam, March 5, 1996 (WhitePaper #2).

Appendix Page 7 of 7