Georgia Department of Natural Resources 

Environmental Protection Division Air Protection Branch 

4244 international Parkway Suite 120 Atlanta Georgia 30354 

4041363-7000 Fax: 4041363-71 00 

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) is providing supplemental 

information to Georgia's State Implementation Plan (SIP )for Regional Haze, which was submitted to 

EPA Region IV on February 11,2010. At the time of submittal, Title V 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 in both the narrative 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 of the facilities. This transmittal includes electronic and paper 

copies of the relevant permits in their entirety. Some of the permits contain conditions that address 

programs other than Regional Haze, so a table is attached that lists only the permit conditions that are 

relevant to Regional Haze. Only those 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 the public notice and EPA review processes. 

Note that all of the permit renewals and amendments were prepared in accordance with Title V of the 

Clean Air Act and Georgia Rule 39 1-3-6-1 -.O3(l O), which incorporates the requirements of 40 CFR Part 

70. These requirements address permit applications, public participation, and review by EPA. The final 

permits/amendments are posted on the Georgia Department of Natural Resources web at 

http://airpermit.dnr.state.ga. us/~aail~ermits/. 

The permit conditions reflect, in some cases, changed language due to the permit application process 

andlor comment and review by the public and EPA. The language does not match word-for-word the 

language of the proposed conditions submitted with Appendix M on February 11,2010. However, these 

Mr. Dick Schutt (continued) 

conditions retain the same restrictions. The attached permits are final and federally enforceable and 

therefore supersede those proposed conditions found in Appendix M of the SIP. 

If you have further questions about this letter, contact me by phone at 404-363-7014 or by e-mail at 

jimmy.johnston@dnr.state.ga.us. 

Sincerely, 

Program Manager 

Planning and Support Program 

c: Michelle Notariami, EPA 

Updated 1 1-4 -20 10 

Permit Amendments Supporting Georgia's Regional Haze SIP 

GA Pacific 

Brunswick 

Cellulose 

AIRS 

l27OOOO3 

GA Pacific Cedar Springs 

AIRS 

09900001 

Interstate 

Paper 

AIRS 

l79OOOO 1 

Internat. Paper 

- Savannah 

AlRS 

5 IOOOO7 

Power Boiler 

No. 4 

Power Boiler 

Nos. 1 and 2, 

Rec. Boiler 3 Power Boiler PWO 1 Power Boiler 13 

Permit amendment 263 1 - 127-0003- 

V-05- 1 

502(b)(10) change 

Issued 3-26-20 10 

Effective 3-26- 10 

Permit amendment 263 1-099-0001 - 

V-02-6 

Significant Modification 

Issued 7-23-09 

Effective 7-23-09 Permit amendment 263 1 - 179-000 1 - 

v-02- 1 

502(b)(10) change 

Issued 9-20-10 Effective 9-20- 10 

Pennit amendment 263 1-05 1-0007- 

v-02-0 

Renewal Issued 4-20-20 10 Effective 4-20- 10 

Conditions - 

Emissionsloperatilrg limits. 

CondTestinand ---- R

F 

Regional Haze SIP C

3.2.29 and 6.2.39 

3.2.6(c), 3.2.19(a) 4.2,26

5.2.2(d

5.2.29

(xvi), 6.1.7(b

6.2.42

State of Georgia 

Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

502(b)(10) Permit for Part 70 Source 

Facility Name: Brunswick Cellulose, Inc. 

1400 West Ninth Street 

Brunswick, Georgia 31521, Glynn County 

Mailing Address: P.O. Box 1438 

Brunswick, Georgia 31 521 

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 Construction and Operattng Permit for: 

The addition of SO2 conditions for 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 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. 

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 specified on the attached 3 page(s). 

Environmental Protection Division 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Brunswick Cellulose, Inc. Permit No.: 263 1-127-0003-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 of Modification ................................................................................................... 1 

REQUIREMENTS FOR EMISSION UNITS ......................................................................... 2 

Emission Units .................................................................................................................................. 2 

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

OTHER RECORD KEEPING AND REPORTING REQUIREMENTS .................................. 3 

Specific Record Keeping and Reporting Requirements 2 ................................................. . . . . . . ... ... 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Brunswick Cellulose, Inc. Permit No.: 263 1-127-0003-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 3 
502(b)(10) PERMIT FOR PART 70 SOURCE . .. - 

Brunswick Cellulose, Inc. Permit No.: 263 1-127-0003-V-05-1 

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. 

3.1.1 Emission Units 

40 CFR 61 Subpart E 

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 6.2.1 1. 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/standards and corresponding permit conditions are intended as a compliance tool and may not be definitive. 

Emission Units Air Pollution Control Devices 

3.2 Equipment Emission Caps and Operating Limits 

ID 

UEP4 

Specific Limifatian~equirtmenb 

ID No. 

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) sulk dioxide (SOz) emissions in 

excess of 568 tons during any twelve-consecutive month period. The first compliance 

period shall be January through December, 2012. 

[40 CFR 5 1.308 - Regional Haze] 

Dmcription 

power ~oiler#4 ESP 

Applicsble 

~equircmentslStnnditrds 

40 CFR 52.21 

Dtscription 

Power oiler #4 

Page 2 of 3 

Corr~ponding Permit 

Conditions - - 

3.2.1 through 3.2.6, 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Brunswick Cellulose, Inc. Permit No.: 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 

emission limit of Condition 3.2.29, on or before June 30,2010. 

[40 CFR 5 1.308 - Regional Haze] 

6.2.40 The Permittee shall submit a proposal to satisfy the periodic 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 3.2.29, on or 

before June 30,20 10. 

[40 CFR 5 1.308 - Regional Haze] 

Page 3 of 3 

State of Georgia 

Department of Natural 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: 

Facility AIRS Number: 04-1 3-099-00001 

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 issued a construction permit for: 

Limit SO2 emissions from Power Boilers No. 1 and 2 to 135 Iblhr each and limit Recovery Boiler No. 3 

SO2 emissions to 350 ppm on a dry basis corrected to 8 percent oxygen when firing black liquor to 

comply with BART regulations. 

This Permit Amendment shall also serve as a final amendment to 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 

condition of this Permit Amendment and Permit No. 2631 -099-0001 -V-02-0 Unless modified or revoked, this Permit 

Amendment expires upon issuance of the next Part 70 Permit for this source. 

This Permit Amendment 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. 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 affecting the emissions from this source. 

This Permit Amendment is further subject to and conditioned upon the terms, conditions, limitations, standards, or 

schedules contained in or specified on the attached 11 pages. 

Environmental Protection Division 

i 

I 

I Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No . . 263 1-099-000 1 -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 of Modification ................................................................................................... 1 

REQUIREMENTS PERTAINING TO 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 Covered by a Federal or SIP Rule and Not Instituted as an Emission 

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 (Related to Data Collection) ............................... 5 

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

OTHER RECORD KEEPING AND 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 Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -V-02-6 

PART 1.0 FACILITY DESCRIPTION 

1.3 Process Description of Modification 

Georgia-Pacific Corporation-Cedar Springs operation is making the following changes at the facility to 

comply with BART regulations. 

Limit SO2 emissions 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 SO2 emissions from the recovery boiler to 350 ppmv on a dry basis corrected to 8 percent 

oxygen when firing black liquor for the complete 24-hour block period. 

Install CEMS on Recovery Boiler No. 3 to monitor SOz emissions. 

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 scrubber blowdown to 

the waste water treatment system. 

PART 2.0 

2.1 

REQUIREMENTS PERTAINING TO THE ENTIRE FACILITY 

Facility Wide Emission Caps and Operating Limits 

None Applicable. 

Facility Wide Federal Rule Standards 

None Applicable. 

Facility Wide SIP Rule Standards 

None Applicable. 

Facility Wide Standards Not Covered by a Federal or SIP Rule and Not Instituted as an 

Emission Cap or Operating Limit 

None Applicable 

Page 1 of I I 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -V-02-6 

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. 

3.1.1 Additional Emission Units 

m No. - 

u500 

U501 

R402 

Genera 

Description 

-- 

Power Boiler No. I 

Power Boiler No. 2 

Recovery Boiler No. 3 

- 

Specific Umiiationsi&qui~~ents 

Andics ble I Corresponding Permit 

- ~epire&nts/~tandards ----- 40 CFR 61 Subpart E 

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 1 Appendix Y 

40 CFR 61 Subpart E 

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 1 Appendix Y 

40 CFR 63 Subpart MM 

40 CFR 64 

39 1-3-1-.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 5 1 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 

through 4.2.6, 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 

through 4.2.6,4.2.12. 

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 

through 4.2.11,4.2.27, 

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, 6.2.7 through 

6.2.13,6.2.23 through 

6.2.25,6.2.39 and 7.14.1* I I 

1 applicable requirements contained in this permit may also apply to emission units list 

Air 

ID No. 

C500 

S500 

C501 

S501 

C402 

' above. 

elution Control Devices 

Description ---- Multicyclone 

Venturi Scrubber with 

Caustic solution as scrubbing 

media or limestone injection 

system 

Multicyclone 

Venturi Scrubber with 

Caustic solution as scrubbing 

media or limestone injection 

system 

Dry Bottom Electrostatic 

Precipitator 

Page 2 of 1 1 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1 -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 350 ppm on a 

dry basis corrected to 8 percent oxygen as a block 24-hour period beginning each 

calendar day at 12 midnight or other appropriate starting times as may be specified or 

approved by the Division 

[40 CFR Part 5 1 Appendix Y-BART] 

[Modified Permit Condition] 

3.2.8 The Permittee shall burn no more than 10,000 pounds per hour and 120 tons per day of tire 

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 of 40 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 5 1.308(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 120 tons per day of tire 

derived fuel (TDF) in Power Boilers No. 1 and No. 2 combined (Source Codes U500 and 

USOl). 

[Avoidance of 40 CFR 52.21) 

Page 3 of 11 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1-V-02-6 

PART 4.0 REQUIREMENTS FOR TESTING 

4.2 Specific Testing Requirements 

[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. 

[Georgia Rule 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 RATA testing. 

[Georgia Rule 391-3-1 -.02(6)(b)l] 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -V-02-6 

PART 5.0 REQUIREMENTS FOR MONITORING (Related to Data Collection) 

5.2 Specific Monitoring Requirements 

[Modified Permit Condition] 

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) of the Division's monitoring requirements. 

[39 1-3-1 -.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 continuous monitor for sulfur dioxide will be 

effective on the date of the completion of the BART Exemption Pro-iect 

[40 CFR Part 5 1, 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) of the Division's monitoring requirements. 

[Georgia Rule 39 1-3- 1 -.O2(6)(b) 1 and 40 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). 

[Modified Permit 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 complying with 40 CFR 64. In addition, 

the Permittee shall meet the requirements, as applicable, of 40 CFR 64.7, 64.8, and 64.9. 

[40 CFR 641 

- 

Ecission Unit 

Lime Handling System (Group Code LEG2) 

Power Boiler Nos. 1 and 2 (Source Codes U500 and U501) 

Lime Kiln Nos. I and 2 (Source Codes L600 and L601) 

Recovery Boiler Nos. 1 and 2 (Source Codes R400 and R401) 

Recovery Boiler No. 3 (Source Codes R402) 

Smelt Dissolving Tank Nos. 1, 2, and 3 (Source Codes R404, R405, and R406) 

Incinerator I Scrubber System (Source Code R425) 

Page 5 of 1 l 

Pollutant 

PM 

PM, SO2 

PM 

PM 

PM 

PM 

PM, SO2 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -V-02-6 

[Modified Permit 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 

Codes U500 and U501): 

[40 CFR 64.6(c)(l)(iii)] 

indicator No, 2 

Pressure Drop 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 the mill 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)] 

[New Permit 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 of completion of the RATA. 

b. A cylinder gas audit shall be conducted at least once every quarter in accordance with 

Appendix F of 40 CFR 60. 

c. CEMS drift checks shall be conducted daily in accordance with 40 CFR 6O.l3(d). 

Page 6 of 1 1 
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 

[Modified Permit 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 

shall be reported: 

[39 1-3- 1 -.O2(6)(b) 1 and 40 CFR 70,6(a)(3)(i)] 

a. Excess emissions: (means for the purpose of this 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 emissions by 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 accordance with 5.2.1 .c is in excess of 350 ppm on a dry basis corrected to 

8 percent oxygen when firing black liquor only for the complete 24-hour 

period. 

[40 CFR 5 1.308(e)] 

Power Boilers No. 1 and 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 during which the SO2 concentration, 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 135 Ibs per 

hour. 

[40 CFR 5 1.308(e)] 

Page 7 of l 1 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -V-02-6 

6.2 Specific Record Keeping and Reporting Requirements 

Modified Permit Condition 

Power Boilers No. 1 and 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), sulfur dioxide (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 72 hours following 

the end of that calendar day. The equations to be used for each calculation follow. 

[Avoidance of 40 CFR 52.211 

a. SAM Emissions: 

SAM, 2 = T[(SAM Emission Pactor,- Ibhr SAM SO2 Emission Rate,, - day ,=I Iblhr SO, 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. CO Emissions: 

e. SO2 Emissions: 

Ib " i 20 9% 1 - hour average SOZ Conc, , - - 

SO - = z (A~flow DSCFh,( I[ hr ,=, 20 9%-O,% 10" 

Page 8 of I 1 
Title V Permit Amendment 

Georgia-Pacific Corporation- Cedar Springs Operation Permit No.: 263 1-099-000 1 -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 calculations will 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-month rolling 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 SO2 for 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 shall be submitted by the 3oth day of the following calendar 

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 inspection by or submittal to the Division for a period of 

five years following the date of record. 

[Avoidance of 40 CFR 52.2 1,40 CFR 5 1.308(e)] 

Page 9 of 1 1 
i Title V Permit Amendment 

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

7.1 Operational Flexibility Associated with this Amendment 

7.2 Off-Permit Changes Associated with this Amendment 

7.3 Alternative Requirements Associated with this Amendment 

[White Paper #2] 

Not Applicable 

7.4 Insignificant Activities 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 Sources Associated with this Amendment 

[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 Compliance Schedule/Progress Reports Associated with this Amendment 

[391-3-l -.O3(lO)(d)3 and 40 CFR 70.6(~)(4)] 

None applicable. 

7.8 Emissions Trading Associated with this Amendment 

[391-3-1-.03(10)(d)l(ii) and 40 CFR 70.6(a)(10)] 

Not Applicable 

7.9 Acid Rain Requirements Associated with this Amendment 

Not Applicable. 

7.12 Revocation of Existing Permits and Amendments 

The following Air Quality Permits and Amendments are subsumed by this pennit and are hereby 

revoked: 

Page 10 of 11 

Air Quality Permit Number@) 

263 1-099-000 1 -V-02-5 

Dates of Original Permit Issuance or Amendment 

Feb 24,2009 
Title V Permit Amendment d 

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

7.13 Pollution Prevention Associated with this Amendment 

Not Applicable 

7.14 Specific Conditions Associated 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 shall be completed by July 30,201 1. 

Page 1 I of 11 
State of Georgia 

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 3 1323 

ParentlHolding Interstate Resources Incorporated 

Company: 

Facility AIRS Number: 04-1 3-1 79-00001 

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(l O)(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-19720 dated 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 . .263 1-1 79-0001 -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 of Modification .................................................................................................... 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 ....................................................................... 5 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Interstate Paper, LLC Permit No.263 1-1 79-0001 -V-02-1 

PART 1.0 FACILITY DESCRIPTION 

1.3 Process Description of Modification 

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-month period. TRS (Total reduced sulfur) emissions will be limited to 18 

tons during any consecutive 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 as the 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 is not considered a major modification for PSD. 

Page 1 of 6 
502(b)(10) PERMIT FOR 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 of 40 CFR 52.2 11 

lD No. 

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. 

[Avoidance of 40 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 

39 1-3-1 -.02(2)(b) 

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

391-3-1 -.02(2)(g) 

39 1-3-1 -.02(2)(gg) 

40 CFR 63 Subpart MM 

40 CFR 64 (CAM) 

pp 

39 1-3- 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-month period. 

[Avoidance of 40 CFR 52.2 1] 

Page 2 of 6 

LimitationsfRequirements 

Corresponding Permit 

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 

3.4.20 and 3.4.2 1 

I Air 

ID No, 

CDOI 

None 

None 

- - ~- 

Pollution Control Devices_ 

Description 

Venturi Scrubber System 

None 

None 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Interstate Paper, LLC Permit No.:263 1-179-0001-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 during periods 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 1,201 1. 

[40 CFR 51.308; Avoidance of 40 CFR 52.211 

Page 3 of 6 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Interstate Paper, LLC Permit No.263 1-1 79-0001 -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) of the Division's monitoring requirements. 

[39 1-3- 1 -.O2(6)(b) 1 and 40 CFR 70.6(a)(3)(i)] 

1. The natural 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 of the monitoring) 

xxviii. Any use of natural gas in the Power Boiler (Emission Unit ID NO. PWOI) 

exceeding 1,100 MCF during any consecutive 12-month period. 

xxix. Any firing of Black Liquor Solids (BLS) in the Recovery Furnace (Emission 

Unit ID NO. PWO2) exceeding 309,3 16 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-he1 Boiler 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-month period. 

Page 4 of 6 
502(b)(10) PERMIT FOR PART 70 SOURCE 

Interstate Paper, LLC Permit No.:263 1-1 79-0001 -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. 

263 1 - 179-000 1 -V-02- 1. 

[40 CFR 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. These records shall be 

available for inspection or submittal to the Division upon request. 

[39 1-3- 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. 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 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 of 6 
. Interstate Paper, LLC 

502(b)(10) PERMIT FOR PART 70 SOURCE 

Pennit No.:263 1-1 79-000 1 -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 the monitoring 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. 

These records 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 of the 

month, as to 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 12 month 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 of the 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. The Permittee 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 of how 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 of NCG burning in the Power Boiler shall be recorded. 

[391-3-1 -.02(6)(b)(I ) and 40 CFR 70.6(a)(3)(i)] 

The Permittee 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 

of its curtailment. 

[391-3-1-.02(6)(b)(l) and 40 CFR 70.6(a)(3)(i)] 

Page 6 of 6 

Permit Number: 

Facility Name: 

Facility Address: 

Mailing Address: 

ParentrHolding 

Company: 

State of Georgia 

Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

Part 70 Operating Permit 

2631 -051 -0007-V-02-0 Effective Date: APR 2 O 2010 

International Paper - Savannah 

West Lathrop Avenue 

Savannah, Georgia 31408, Chatham County 

P.O. Box 570 

Savannah, Georgia 31402 

International Paper Company 

Facility AIRS Number: 04-13-051-00007 

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 QuaMy Control, Chapter 391-3-1, adopted pursuant to and in effect under the Act. 

the Permittee described above is issued a Part 70 Pemit for: 

The operation of a Krafl Pulp, Paper, and Paperboard Mill and a Corrugated Paperboard 

Container production facility. 

This Pemit is conditioned upon compliance with all provisions of The Georgia Air Quality Act. 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 indicated above. 

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-16986 and 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 1-05 1-0007-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 Standards Not 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 

Specific Testing Requirements .......................................................................................................... 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 of Accidental Releases (Section 1 12(r) of the 1990 CAAA) .......................................... 55 

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

Revocation of Existing 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 . . 263 1-05 1 -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 

Sulfur Dioxide .................................................................................................................................... 68 

Particulate Emissions ......................................................................................................................... 68 

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

Solvent Metal Cleaning ...................................................................................................................... 69 ......................................................................................................................................... Incinerators 70 

Volatile Organic Liquid Handling and Storage ................................................................................. 71 

Use of Any Credible Evidence or Information .................................................................................. 71 

Diesel-Fired Internal Combustion Engines ........................................................................................ 71 

CI? Attachments .............................................................................................................................................................. IL 

A . List of Standard Abbreviations and List of Permit Specific Abbreviations 

B . Insibmificant Activities Checklist. Insignificant Activities Based on Emission Levels and Generic 

Emission Groups 

C . List of References 
International Pauer - Savannah 

Title V Permit 

Pem~it No.: 263 1-05 1 -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. 05 1-00148) 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 (AIRS No. 05 1-001 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 of products ranges from the lightest weight unbleached paper used in the manufacture of paper 

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. 

The kraft (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. 

The initial 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. The pulplblack liquor mixture is pumped to 

pulp washers where the spent black liquor is washed from the pulp. The dilute black liquor fi-om the 

pulp washers is then 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.: 263 1-05 1 -0007-V-02-0 

The black 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 is pumped 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. The burning of the 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 of white 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. Completing the chemical recovery process, 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 hourly bark 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 the precipitator; 

Adding a magnet and metal detector in the bark lines; 

Recommissioning the second side of the Wennburg bark screw and hog; and 

Reconfiguring the bark feeders to reduce housekeeping issues. 

Page 2 of 72 
International Paver - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 of 40 CFR 52.2 11 

Facility Wide Federal Rule Standards 

None applicable. 

Facility Wide SIP Rule Standards 

None applicable. 

Facility Wide Standards Not Covered by a Federal or SIP Rule and Not Instituted as an 

Emission Cap or Operating Limit 

None applicable. 

Page 3 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 

LK I0 

LKl l 

RF 15 

RF 10 IEmission Units 

Description 

\io. 7 Lime Kiln 

lime Conveyor 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 

10 CFR 60 Subpart A 

t0 CFR 50 Subpart BB 

LO CFR 63 Subpart A 

$0 CFR 63 Suhpart MM 

10 CFR Part 64 

391 -3-1 -.02(2)(a)3(i) 

19 1-3-1 -.02(2)(b) 

191 -3-1 -.02(2)(e) 

19 1-3- 1 -.02(2)(g) 

391 -3-1 -.02(2)(gg) 

10 CFR 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) 

10 CFR 52.2 1 

40 CFR 60 Subpart A 

10 CFR 60 Subpart Db 

10 CFR 60 Subpart BB 

10 CFR 63 Subpart A 

10 CFR 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 

39 1-3- 1 -.02(2)(b) 

39 1-3-1 -.02(2)(e) 

39 1-3- 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 

39 1-3- 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. 

APO l 

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 72 
International Paper - Savannah 

Title V Permit 

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

Emission Units 

-r----- 

LVH? 

H V LC 

PPCC 

--A 

Sox Pla 

B P 

-- - 

PL 

--- - P L', 

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 

Specific EimitationslRequirements 

Applicable Corresponding Permit 

Requirements/Standards Conditions 

39 1-3- 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 Subpart A 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 63 Subpart 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 13.3.1 1, 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 Subpart A 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 

- 

.White Liquor 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 of 40 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 The Pesmittee shall supply no more than one-third of its 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 of40 CFR 60 Subpart Da and Avoidance of 40 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 1-05 I -0007-V-02-0 

3.3 Equipment Federal Rule Standards 

No. 7 Lime Kiln 

3.3.1 The Permittee shall not discharge or cause the discharge into the atmosphere fiom the No. 7 

Lime Kiln (Source Code: LK07) any gases which: 

a. Contain particulate matter (PM) emissions in excess of 0.064 grains per dry standard 

cubic foot(gr1dscf) (corrected to 10 percent oxygen). 

[40 CFR 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 10 percent oxygen). 

[40 CFR 60.283(a)(5) and 39 1-3- 1 -.02(2 )(gg) 1 (iv) (subsumed)] 

c. Contain sulfur dioxide (SO2) emissions in excess of 71 9 pounds per hour (lbhr). 

[40 CFR 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 of 40 CFR 52.2 1] 

a. 7.9 pounds per hour (lbhr). 

b. 34.6 tons during any twelve consecutive months. 

No. 15 Recovery 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: RF 1 5) any gases which: 

a. Exhibit an opacity greater than 20 percent (six-minute average), except for one 

six-minute period per hour of not 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 100 parts per million (ppm) by 

volume on a dry basis (corrected to 8 percent oxygen) when burning only black 

liquor. 

[40 CFR 52.211 

Page 6 of 72 
International Paper - Savannah 

Title V Permit 

Permit No.: 263 1-05 1-0007-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 8 percent oxygen). 

[40 CFR 60.283(a)(2) and 391 -3- 1 -.02(2)(gg) 1 (i)(II)] 

d. Contain sulfur dioxide (SO2) emissions in excess of 3 19 pounds per hour (Iblhr). 

[Avoidance of 40 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 60.41 b in the No. 15 Recovery Furnace (Source Code: RF15). 

[40 CFR 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. 15 Recovery 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 state design heat input capacity. 

[40 CFR 60.44b(c)] 

No. 1 5 Recovery Furnace Smelt Dissolving Tank 

3.3.6 The Permittee shall not discharge or cause the discharge into the atmosphere from the 

No. 15 Recovery Furnace Smelt Dissolving Tank (Source Code: RFl 0) any gases which: 

a. Contain particulate matter (PM) emissions in excess of: 

i. 23.1 pounds per hour (lblhr). 

[40 CFR 52.211 

. . 

11. 0.15 pounds per ton of black liquor solids (Iblton BLS). 

[40 CFR 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 1.4 pounds per hour (Ibhr). 

[40 CFR 52.211 

c. Contain total reduced sulfur (TRS) emissions in excess of 2.6 pounds per hour (Ibh). 

[Avoidance of 40 CFR 52.211 

Page 7 of 72 
International Pa~er - Savannah 

Title V Permit 

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

No. 13 Power Boiler 

3.3.7 The Permittee shall not discharge or cause the discharge into the atmosphere from the 

No. 13 Power 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. 

[40 CFR 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 he1 and wood residue. 

[40 CFR 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 = The percentage of total heat input derived from liquid fossil fuel; and 

- - 

A - The percentage of total heat input derived from solid fossil fuel. 

iv. An average of 2822 pounds per hour (lblhr) during any continuous 24-hour 

period. 

[40 CFR 52.211 

v. An average of 4281 pounds per hour (lbhr) during any continuous three-hour 

period. 

[40 CFR 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. 

[40 CFR 60.44(a)(2) and 391 -3-1 -.02(2)(d)4(i)] 

Page 8 of 72 
Title V Permit 

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

ii. 0.70 pounds per million Btu (IbIMMBtu) derived from solid fossil fuel or solid 

fossil fuel and wood residue. 

[40 CFR 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 = The percentage of total heat input derived from liquid fossil fuel; and 

- - 

L. - The percentage of total 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 of not more than 

27 percent opacity. 

[40 CFR 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). 

[Avoidance of 40 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.: 263 1-05 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. 

[Avoidance of 40 CFR 52.2 11 

3.3.1 1 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. 

[40 CFR 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. 

[40 CFR 63.443(c)] 

Cluster Rule (Condensates) 

3.3.13 The Permittee shall collect the Pulping Process Condensates (Source Code: PPCC) from 

any combination of the following sources to meet the requirements of Condition Nos. 3.3.14 

and 3.3.17: 

[40 CFR 63.446(b)] 

a. Each digester system; 

b. Each turpentine recovery system; 

c. Each evaporator system condensate from: 

i. The vapors from each stage where weak liquor is introduced (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 of 7.2 pounds per ton of oven-dried pulp (Man ODP). 

[40 CFR 63.446(~)(3)] 

Page 10 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1-0007-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: 

[40 CFR 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 6.6 pounds per ton of oven-dried pulp (lblton ODP). 

[40 CFR 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. 

[40 CFR 63.4541 

The Permittee shall discharge those pulping process condensates to be treated biologically 

below the liquid surface of the 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 10 tons during any twelve consecutive months. 

[Avoidance of 40 CFR 52.211 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1-0007-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 10 tons during any twelve consecutive months. 

[Avoidance of 40 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 63.82 1 (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". 

[40 CFR 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, 197 1 ", for the operation of the No. 13 Power 

Boiler (Source Code: 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. 15 Recovery Furnace (Source Code: RF 15). 

[40 CFR 60 Subpart Db] 

The Permittee shall comply with all applicable provisions of Federal Standard 40 CFR 60 

Subpart BB, "Standards of Performance for Kraft 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 RF 10, respectively) as well as Ernission 

Groups LVH1 and LVH2. 

[40 CFR 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 1 to 40 CFR 63 Subpart S, Table 1 to 

40 CFR 63 Subpart KK, and Table 1 to 40 CFR 63 Subpart MM. 

[40 CFR 63 Subpart A] 

Page 12 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 52.2 1, "Prevention of Significant Deterioration". 

[40 CFR 63 Subpart S and Avoidance of 40 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 63.82 1 (a)(2)&(3). 

[40 CFR 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). 

[40 CFR 63 Subpart MM] 

Regional Haze 

Effective January 1, 201 6, 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 201 6. 

[40 CFR 5 1.308 ] 

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 or before June 30,2014. 

[40 CFR 5 1.3081 

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, 201 4. 

[40 CFR 51.3081 

Page 13 of 72 
Title V Permit 

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

3.4 Equipment SIP Rule 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 30 tons per hour (tph); 

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

where 

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

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

The Permittee shall fire only fuels containing no more than three percent sulfur, by weight, 

in the No. 7 Lime Kiln (Source Code: 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 (Source Code: LKI 1) the opacity of which is equal to or greater than 

40 percent (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 30 tons per hour (tph). 

where 

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

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

Page 14 of 72 
Title V Permit 

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

No. 1 5 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 allowable rate 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 30 tons per hour (tph). 

where 

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

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

No. 15 Recovery 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: RFI 0) 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: RFI 0) 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 tons per 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. 13 Power 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 (Source Code: PB 13). 

[39 1 -3- 1 -.02(2)(g)2] 

Page 15 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 30 tons per hour (tph); 

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

where 

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

P = process input weight rate in tons per 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 16 of 72 
International Paper - Savannah 

Title V Permit 

Pennit No.: 263 1 -051-0007-V-02-0 

kt% Oi B 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 60 days of the completion of the testing. Any tests 

shall be performed and conducted using methods and procedures that have been previously 

specified or approved by 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 sample point 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 of moisture 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 of nitrogen oxide (NOx) emissions. 

h. Method 9 and the Procedures of Section 1.3 for the visual determination of the opacity 

of emissiom. 

i. Method 10 for the determination of carbon monoxide (CO) emissions. 

j. Method 16 for the determination of total reduced sulfur (TRS) emissions. 

Page 17 of 72 
International Paver - Savannah 

Title V Permit 

Permit No.: 263 1-05 1-0007-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 of volatile 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 

of methanol 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 of tall oil pitch sulfir content. 

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 

of traverse 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. 

[40 CFR 63.865(b)(5)(ii)] 

Page 18 of 72 
International Paper - Savannah 

Title V Permit 

Pennit No.: 263 1-05 1-0007-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 10 may be used as an alternative to Method 3B. 

140 CFR 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 of moisture content of stack gas. 

[40 CFR 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 60 minutes and 0.90 dscm (3 1.8 dscf), and water must be used as 

the cleanup solvent instead of acetone in the sample recovery procedure. 

[40 CFR 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 of 40 CFR 63.865(b)(2). 

[40 CFR 63.865(b)(2)] 

For Method 21 and pursuant to the leak checks of 40 CFR 63.453(1), the Permittee shall use 

a span gas concentration of a mixture of methane in air at a concentration of approximately, 

but less than, 10,000 parts per million (ppm) by volume of methane. 

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. 

[39 1-3- 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. 

[39 1-3- 1 -.02(3)(b)] 

- -- - 

Page 19 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 (RF 15) 

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] 

Sulfur Dioxide (SO2) 

Nitrogen Oxides (NOx) 

Particulate Matter (PM) I No. 1 5 Recovery Furnace Smelt Dissolving Tank (RFI 0) 

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 (RF 1 5) 

No. 15 Recovery Furnace Smelt Dissolving Tank (RFI 0) 

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. The provisions 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 of 72 
International Pa~er - Savannah 

Title V Permit 

Pennit No.: 263 1-05 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 of this 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 sulhr dioxide (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: 

[40 CFR 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 

(Source Code: 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 2 1 of 72 
International Paver - Sava~ah 

Title V Permit 

Permit No.: 263 1-05 1 -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. 3.3.1 7 is 

demonstrated, these values shall be used to establish a site-specific operating range for 

treatment of the 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). 

[40 CFR 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. 

[40 CFR 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. 

[40 CFR 63.7(b)] 

Page 22 of 72 
Title V Permit 

International Paper - Savannah -- Permit No.: 263 1-05 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) of the 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) 

[40 CFR 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. 15 Recovery 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. 13 Power Boiler (Source Code: PB13) 

140 CFR 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. 

[39 1-3- 1 -.O2(6)(b) 1 and 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) 

[40 CFR 52.2 1,40 CFR 63.864(e)(10)&(13), 40 CFR Past 64 and 

40 CFR 60.284(b)(2) (subsumed)] 

Page 23 of 72 
International Pa~er - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 of 40 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. 

[40 CFR 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 of the data from each eight-hour shift of operation 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. 15 Recovery 

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 of operation. 

[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 72 
International Paper -- Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 

sample in lieu of the method specified in Method 19. 

[40 CFR 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 (Source Code: AP 1 7). 

[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, 

[40 CFR 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: 

[40 CFR 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 of defects. 

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 72 
International Pa~er - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 is maintained in the closed position and the emission point gas 

stream is not 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 the problem is identified. 

. . 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 if the 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 

annually by the procedures 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 500 parts 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 of the high level probe on the K2 Fines Cyclone (Source Code: AP06). 

[Avoidance of 40 CFR 52.21, 391-3-1-.02(6)(b)l, and 40 CFR 70.6(a)(3)(i)] 

Page 26 of 72 
International 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-minute period. 

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: 

[40 CFR 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 to be 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. 

I No. 15 Recovery Furnace Smelt Dlssolvlng Tank (WlO) I Scrubber (%' 15) -1 PMI 

Emission Bait (Source Code) 

No 7 L~me K~ln (LK07) 

No I5 Recovery Furnace (RF 15) 

No 13 Power Boder (PB 13) 

1 No. 15 Recovery 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.: 263 1-05 1 -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 the No. 7 Lime Kiln (Source Code: 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's recommendations. 

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 Once per 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). 

[40 CFR 64.6(c)(l)(iii)] 

ndicatar No. 2 

:SP Total Secondary Power --.----- 

Performance Criteria 

[64.Wt3)1 

tor No. 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 of 72 

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 shift 
International Paper - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 the No. 13 Power Boiler (Source Code: PB 13). 

[40 CFR 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 

lndicrtor No. 1 

ESP Total 

- 

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 Once per 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 

Once per 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 

1 

Data monitored by the Data Acquisition 

System (DAS) and recorded in the 

Process Information (PI) System. 

Tank (Source Code: RF 10). 

[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 

acceptable accuracy of i0.5 percent of 

the design scrubbant flow rate. 

Fan motor current is measured by a fan 

amp meter. Minimum acceptable 

accuracy of i5 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 MACT QNQC Plan for 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 

ban motor current is 7- 

[ndicator No. 3 

Fillhack Valve 

Position 

4. Data Representativeness 

[64.3(b)( 111 

B. Veritication of Operational 

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 for phase 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.cn t 

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 (Source Code: OPG8). 

[40 CFR 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 Practices and 

[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 

Sctuhhsnt Flow 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. 

Once per 8-hour shift 

Data monitored by the Bailey Data Collection System (DCS) and recorded in the 

Process Infonnation (PI) System. (Because the monitoring interface is exception 

based, data is recorded in the PI based on when the values change.) 

Once per 8-hour shift 

Page 30 of 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. The records shall be retained for at least five years following the date of entry. 

[39 1-3- 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 a period 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(1 O)(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 3 1 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 3 1, June 30, September 30, and December 3 1 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 of Air 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 3 1 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 time period of occurrence. 

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 of the repairs, adjustments, or replacement. When the 

monitoring system or device has not been inoperative, repaired, or adjusted, such 

information shall be stated in the report. 

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. The date, place, and time of sampling or measurement; 

b. The date(s) analyses were performed; 

c. The company or entity that performed the analyses; 

d. The analytical techniques or methods used; 

e. The results 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 or monitoring 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(I O)(d)l (i) and 40 CFR 70.6 (a)(3)(ii)(B)] 

Page 32 of 72 
International Paver - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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: 

[39 1-3-1 -.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. 

[40 CFR 60.284(d)(2), 40 CFR 60.284(~)(1), and 39 1-3-1 -.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. 

[40 CFR 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 of not more than 27 percent opacity. 

[40 CFR 60.49b(h)(l)&(3), 40 CFR 60.284(d)(l)(ii) (subsumed), and 

39 1-3- 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 8 percent oxygen). 

[40 CFR 52.211 

No. 13 Power Boiler 

v. Any six-minute period 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, or malfunction. 

[40 CFR 60.45(g)(1) and 391 -3-1 -.02(2)(d)3] 

Page 33 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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: 

[40 CFR 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, 

1.2 pounds 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. 

[40 CFR 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. 1 percent 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: LVH 1 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 

of total HAP per ton of oven-dried pulp (lblton ODP). 

[40 CFR 63.446(~)(3)] 

Page 34 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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). 

[40 CFR 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 of the 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) or the No. 13 Power Boiler (Source Code: PB 13). 

[Avoidance of 40 CFR 60 Subpart Da and Avoidance of 40 CFR 72 Subpart A] 

Fuel 

. . 

11. Any period of process operation during which the sulfur content 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. 

[39 1-3- 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 

10 tons. 

[Avoidance of 40 CFR 52.2 11 

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 10 tons. 

[Avoidance of 40 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 100 tons. 

[Avoidance of 39 1 -3- 1 -.02(2)(mm)] 

Page 35 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 63.82 1 (a)(2)&(3). 

[40 CFR 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 

6 percent within any quarterly period. 

[40 CFR 63.864(k)(2)(i)&(ii)] 

vii. 

. . . v111. 

For the No. 15 Recovery Furnace (Source Code: RF 1 5), 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 of the operating time. 

[40 CFR 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 6 percent or more 

of the operating time. 

[40 CFR 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 of nonopacity 

monitoring exceedances, no more than one exceedance will be attributed in any given 

24-hour period. 

[40 CFR 63.864(k)(2)(iii)&(vi) and 40 CFR 63.864(k)(3)] 

ix. For the No. 15 Recovery 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. 15 Recovery 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. 

[40 CFR 63.864(k)(2)(vi)] 

Page 36 of 72 
Title V Permit 

- 

International Paper - Savannah Pennit No.: 263 1-05 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 of 40 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". 

140 CFR 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. 

[40 CFR 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). 

[40 CFR 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 averaging period 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 72 
International Paoer - Savannah 

Title V Permit 

Permit No.: 263 1-05 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). 

[Avoidance of 40 CFR 52.21, 391 -3-I-.02(2)(b)I, and 391-3-1-.02(2)(e)l(i)] 

No. 15 Recovery 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 is not being used as the scrubbant. 

[Avoidance of 40 CFR 52.21, 391 -3-1 -.02(2)(gg)l (iii), and 40 CFR 60.283(a)(4) 

(subsumed)] 

v. For the No. 15 Recovery 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 of 72 
International Paver - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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: 

[40 CFR 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 3.3.1 8, 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 the parameter excursion is not a violation of 40 CFR 63.446(e)(2). 

[40 CFR 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 of 40 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 during which any of the following conditions occur 

for the parameters measured and recorded in accordance with Condition 

No. 5.2.2.c: 

[Avoidance of 40 CFR 52.2 1 ] 

A. The average scrubbant flow rate falls below 15.0 gallons per minute (gpm) 

B. The average pressure drop falls below 6.0 inches of water (in. H20). 
International Pa~er - Savannah 

Title V Permit 

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

xi. When combusting the total reduced sulfur (TRS) gas streams from Emission 

Groups LVH 1 and LVH2 in the No. 13 Power Boiler (Source Code: PB 13), any 

twelve-month rolling period during which the TRS gas streams are scrubbed in 

the White Liquor NCG Scrubber (Source Code: WLSI) less than 90 percent of 

the facility operating time. 

[Avoidance of 40 CFR 52.2 I] 

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 1,40 CFR 60.43,40 CFR 60.45(b)(2), and 39 1-3- 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. 

[40 CFR 60.44b(e)] 

iii. A statement that only "very low sulfur oil", that meets the definitions in 

40 CFR 60.41 b 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. 

[40 CFR 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). 

[40 CFR 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, 3.3.1 7, 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 of total HAP per ton of oven-dried pulp (Iblton ODP). 

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

Page 40 of 72 
International Pa~er - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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 20 percent opacity in accordance with Condition No. 6.2.26.a. 

[40 CFR 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 

20 percent opacity in accordance with Condition No. 6.2.26.b. 

[40 CFR 63.864(k)(I)(i)] 

viii. For the No. 15 Recovery 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. 

[40 CFR 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, is in excess of 20 percent. 

[40 CFR 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 of 40 CFR 52.2 1 

No. 13 Power Boiler 

xi. For each month in the reporting period, a report of the twelve-month rolling 

totals of bark fired in the No. 13 Power Boiler (Source Code: PB 13), calculated 

in accordance with Condition No. 6.2.10. 

[40 CFR 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. 

[40 CFR 70.6(a)(3)(i) and 391 -3-1 -.O2(6)(b)l] 

Page 4 1 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 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. The lime mud feed rate, and 

b. Either the percent solids or the density of the lime mud feed. 

No. 15 Recovery Furnace 

6.2.2 The Permittee shall maintain the daily records of either the percent black liquor solids or the 

black liquor density for the No. 15 Recovery Furnace (Source Code: 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 he1 oil 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. 

[40 CFR 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.: 263 1-05 1 -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 (Source Code: 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 of fuel fired, 

b. The quantity of each fuel fired, and 

c. The steam production records. 

The Permittee shall calculate and maintain the following records of the sulfur dioxide (SO2) 

emission rate for the No. 13 Power Boiler (Source Code: 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. 

[40 CFR 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 SO2 emission standard in Condition No. 3.3.7.b.i~. 

[40 CFR 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 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 

of the following information: 

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

a. A description of the 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 of the 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 of regular operations after the completion of the project. 

6.2.8 The Permittee shall calculate and maintain records of the 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 1.3 of this 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)1 S(i)(III)] 

b. The actual increase in emissions of each regulated NSR pollutant due to demand 

growth, in tons per year (tpy) on a calendar year basis. 

[391-3-1-.02(7)(b)1 5(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)S 5(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). 

[40 CFR 70.6(a)(3)(i) and 391 -3-1 -.02(6)(b)l] 

Page 44 of 72 
International 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: PB 13): 

[Avoidance of 40 CFR 60 Subpart Da and Avoidance of 40 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 

sale calculated in accordance with Condition No. 6.2.1 1 .a. 

Fuel Oil 

6.2.12 For each shipment of residual 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 52.2 1, 40 CFR 60.45(b)(2), 39 1-3-1 -.02(2)(g)2, 40 CFR 70.6(a)(3)(i), and 

391 -3-1 -.02(6)(b)1] 

a. Name of the 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 of the oil from which the shipment came (or of the shipment itself); 

d. Method used to determine the sulfur content of the 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)2,40 CFR 70.6(a)(3)(i), and 391 -3-1 -.02(6)(b)l] 

a. Name of the 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 of 72 
Title V Permit 

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

Used Oil 

6.2.14 For each shipment of used 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. Sulfur content of the used oil received. 

Tall Oil Pitch 

6.2.1 5 For each shipment of tall 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. The records 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 of tall oil pitch received; 

b. Sulfur content of the tall oil pitch received; 

c. Moisture content of the tall oil pitch received; and 

d. Gross Calorific Value (GCV) of the 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. The records 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. Sulhr content of the coal received; 

b. Moisture content of the 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 during which 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 39 1-3- 1 -.02(2)(gg)] 

a. Emission Groups LVHl and LVH2 are 

i. controlled by the No. 13 Power Boiler (Source Code: PB13); 

ii. controlled by the No. 7 Lime Kiln (Source Code: LK07); 

. . . 111. exhausted via the bypass stack. 

Page 46 of 72 
International Paver - Savannah 

Title V Permit 

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

b. Emission Group HVLC is 

i. controlled by the No. 13 Power Boiler; 

. . 

11. exhausted via the bypass stack. 

The Permittee shall record and maintain records of the following infonnation: 

[40 CFR 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 3.3.1 1 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, in pounds per ton of oven-dried pulp (lblton ODP). 

140 CFR 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. 

[40 CFR 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 of inspection; 

b. The equipment type and identification; 

c. Results of negative pressure tests for enclosures; 

d. Results of leak 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 1-05 1-0007-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 15 days; 

j. The date of successful repair of the 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 of the use of bypass 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 of 40 CFR 63.446(g). 

[40 CFR 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). 

[40 CFR 70.6(a)(3)(i) and 39 1-3-1 -.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. 

[40 CFR 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. 3.3.1 O.b: 

[Avoidance of 40 CFR 52.2 l,40 CFR 70.6(a)(3)(i), and 391 -3-1 -.O2(6)(b) I] 

a. The twelve-month rolling total operating time of the Pre-Evaporator Island; 

b. The twelve-month rolling total down tiine of the White Liquor NCG Scrubber (Source 

Code: WLSl); and 

Page 48 of 72 
International Pa~er - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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: PB 13) 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: 

[40 CFR 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 is properly 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 20 percent 

opacity . 

140 CFR 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. 

[40 CFR 63.864(k)(l)(i)] 

Page 49 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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). 

[40 CFR 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: 

[40 CFR 63.866(c)] 

a. Records of the black liquor solids (BLS) firing rate, in tons per day (tpd), for the 

No. 15 Recovery Furnace (Source Code: RF15); 

[40 CFR 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); 

[40 CFR 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; 

[40 CFR 63.866(~)(3)] 

d. Records and documentation of supporting calculations for compliance determinations 

made under 40 CFR 63.865(a) through (d); and 

[40 CFR 63.866(~)(4)] 

e. Records of monitoring parameter ranges established for the No. 15 Recovery Furnace 

Smelt Dissolving Tank Vent Scrubber (Source Code: AP 15). 

[40 CFR 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. 

[Avoidance of 40 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 

International Paper - Savannah Permit No.: 263 1-05 1 -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 of the record. All calculations used to determine usages shall also be kept as part of the 

monthly record. 

[Avoidance of 40 CFR 52.2 1,40 CFR 70.6(a)(3)(i), and 391 -3-1 -.02(6)(b)l] 

6.2.32 The Permittee shall maintain records of the 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) = [Mrrteiiol Usogrirc (lbs)] x [VOC Content (Ibs VOC l lbr Moteriid)] ; or 

b. VOC (lbs) = [Mateiiiil Usage (gullons)]~ [VOC Content (Ibs VOC I gollons Muterial)] . 

The Permittee shall notify the Division in writing if the 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. 

[Avoidance of 40 CFR 52.21,40 CFR 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 

10 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 applicable emissions limitation set 

forth in Condition No. 3.3.20 or Condition No. 3.3.21. 

[Avoidance of 40 CFR 52.21,40 CFR 70.6(a)(3)(i), and 391 -3-1-.02(6)(b)l] 

Page 51 of 72 
Title V Permit 

International Paper - Savannah Pennit No.: 263 1-05 1-0007-V-02-0 

Box Plant 

The 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. 

[Avoidance of 391 -3- 1 -.02(2)(mm), 40 CFR 70.6(a)(3)(i), and 391 -3-1 -.02(6)(b)l] 

The Permittee shall maintain records of the 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 [VOC Content (Ibs VOC 1 lbs Material)] ; or 

b. VOC (Ihr) = [~uterial Usage (gallor,s)]x [VOC Content (Ibi VOC I gallons 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. 

[Avoidance of 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 63.82 1 (a)(2)&(3). 

[40 CFR 63.829(e)(2)] 

Page 52 of 72 
International Pa~er - Savannah 

Title V Permit 

Permit No.: 263 1-05 1-0007-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. 

[40 CFR 70.6(a)(3)(i) and 39 1-3-1 -.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. 

[40 CFR 70.5(d), 40 CFR 70.6(c)(l), and 391-3-1-.03(1O)(c)2] 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 1 of 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 of total 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(1 O)(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 of the 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 are met: 

[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. The Permittee 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 39 1 -3- 1 -.03(1 0)(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 of the 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 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 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 

of the Federal Act or are modifications under any provision of Title I of the Federal Act. 

[391-3-1-.03(1 O)(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)5 and 40 CFR 70.6(e)] 

Not Applicable. 

Short-term Activities 

(see Form D5 "Short Term Activities" of the Permit application and White Paper #1) 

Not Applicable. 

Compliance Schedule/Progress Reports 

[39 1-3- 1 -.O3(l O)(d)3 and 40 CFR 70.6(~)(4)] 

Not Applicable. 

Emissions Trading 

[391-3-1-.03(1 0)(d)l (ii) and 40 CFR 70.6(a)(l 0)] 

Not Applicable. 

Acid Rain Requirements 

Not Applicable. 

7.10 Prevention of Accidental Releases (Section 112(r) of the 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 of 40 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 of 72 
International Paper - Savannah 

Title V Permit 

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

b. For processes eligible for Program 1, as provided in 40 CFR 68.10, the Permittee shall 

coinply with Condition No. 7.1 0.1 .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 as provided 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 68.1 2(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 68.1 5 

ii. Conduct a hazard 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 as provided 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 a hazard assessment as provided in 40 CFR 68.20 through 68.42 . . . 111. Implement the prevention requirements of 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 3 as provided in 40 CFR 68.1 75 

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 of 72 
International Paper - Savannah 

Title V Permit 

Permit No.: 263 1-05 1 -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, 

7.1 1 Stratospheric Ozone Protection Requirements (Title VI of the CAAA of 1990) 

7.1 1.1 If the 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.: 263 1-05 1-0007-V-02-0 

7.12 Revocation of Existing 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 and Amendment Number(s) 

2631 -05 1 -0007-V-0 1-0 

263 1-05 1 -0007-V-01-2 

263 1-05 1 -0007-V-0 1-4 

263 1 -05 1 -0007-V-01-5 

263 1-05 1 -0007-V-01-7 

263 1-05 1 -0007-V-01-8 

263 1-05 1 -0007-V-01-9 

7.14 Specific Conditions 

None applicable. 

Dates of Original Permit or Amendment I[ssuance 

April 3, 2002 

October 2 1,2003 

June 2,2005 

October 18,2005 

December 2,2005 

March 24, 2008 

January 2,2009 

Page 58 of 72 
Title V Permit 

International Paper - Savannah Pernlit No.: 263 1-05 1 -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 

orders pursuant to 42 U.S.C. 7603, "Emergency Powers." 

[40 CFR 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 of this Permit. 

[391-3-1 -.O3(l O)(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 of Permit issuance. 

[391-3-1-.03(10)(d)l(i) and 40 CFR 70.6(f)(3)(ii)] 

Page 59 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1-0007-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 of the Permit. 

[39 1-3-1 -.03(l 0)(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 of the 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(l 0)(d)l (i) and 40 CFR 70.6(a)(6)(iv)] 

Page 60 of 72 
Title V Permit 

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

8.8 Submissions 

Reports, test data, monitoring data, notifications, annual certifications, and requests for 

revision and renewal shall be submitted to: 

Georgia Department of Natural 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 

Sam Nunn 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 to the 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 of records 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(1 0)(d)l (i) and 40 CFR 70.6(a)(6)(v)] 

Page 61 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1-0007-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, or revision of plans, if necessary. 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)] 

8.1 1 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 is not required until after the date on which the Permit is due to expire; 

[391-3-1-.03(1 O)(e)6(i)(I)] 

b. If any additional applicable requirements of the Acid Rain Program become 

applicable to the source; 

[39 1 -3- 1 -.03(1 O)(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 of the Permit; or 

[391-3-l -.03(1 O)(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 72 
International Paper - Savannah 

Title V Permit 

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

Reopenings shall not be initiated before a notice of intent to reopen is provided 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(1 O)(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 of planned 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 of this 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 specifically provided 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 of this 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 of preventative 

maintenance, careless or improper operation, or operator error. 

[391-3-1 -.03(1 O)(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 of the emergency being properly operated; 

Page 63 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 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 of proof. 

[391-3-1-.03(1 O)(d)7 and 40 CFR 70.6(g)(4)] 

8.13.4 The emergency conditions listed above are in addition to any emergency or upset provisions 

contained in any applicable requirement. 

[391-3-1 -.03(l O)(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. The certification shall include, but not be limited to, the following 

elements: 

[39 1-3-1 -.03(1 O)(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 64 occurred; 

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 1-05 1 -0007-V-02-0 

8.1 3.2 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 of this Permit; . . 11. Have access to and copy, at reasonable times, any records that must be kept 

under the conditions of this 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 70.1 l(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. 

[39 1-3-1 -.O3(l O)(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. 

[39 1-3-1 -.O3(l O)(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(1 O)(c)2 and 40 CFR 70S(c)(8)(iii)(C)] 

Page 65 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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. The best 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 of the Georgia Rules for Air Quality Control. 

[391-3- 1 -.02(2)(a)7(ii)] 

c. The provisions of this 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. 

[39 1-3-1 -.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. 

[39 1-3-1 -.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" does not have a Pesmit shield. 

Page 66 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 of the 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 or under construction on or before January 1, 

1972 in amounts equal to or exceeding 0.7 pounds per million BTU heat input. 

[39 1-3-1 -.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 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 minute period per hour of not more than twenty-seven (27) percent opacity. 

[39 1-3-1 -.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 100 million 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 ; for process 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 of 72 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1 -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 give rise 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 give rise to airborne dusts; and 

e. The prompt removal of earth or other material from paved streets onto which earth or 

other material has been deposited. 

8.22.2 The opacity from any hgitive dust source shall not equal or exceed 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 of emissions of the 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 of non-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 of the 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.: 263 1-05 1-0007-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 1.0 pound 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 100 pounds 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 of not 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 the unaided 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°F in the secondary chamber. 

Page 70 of 72 
Title V Permit 

International Paper - Savannah -- Permit No.: 263 1-05 1 -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 1 1, 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 7 1 of 72 
Title V Permit 

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

Attachments 

A. List of Standard Abbreviations and List of Permit Specific Abbreviations 

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

Groups 

C. List of References 

Page 72 of 72 
Title V Permit 

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

ATTACHMENT A 

List Of Standard Abbreviations 

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 of Federal Reguiations 

Continuous Monitoring 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 Source Performance Standards 

1 OCGA 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 Sulhr Dioxide 

I USC I United States Code - - 

VE I Visible Emissions 

VOC I Volatile Oreanic Comuound 

List of Permit Specific Abbreviations 

~TUBP Oven-Dried Tons of Unbleached 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.: 263 1-05 1 -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 fire tighters 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 1 12 (excluding 1 12(r)) of the 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 of Insignificant ActivitylUnit 

1. Cleaning and sweeping of streets and paved surfaces 

i) Less than 8 million BTUlhr heat input, firing types 0, 1, 2, andor 3 waste. I 

Quantity 

1 

ii) Less than 8 million BTU/hr heat input with no more than 10% pathological (type 4) waste 

by weight combined with types 0, 1, 2, and/or 3 waste. 

iii) Less than 4 million BTUhr heat input firing type 4 waste. 

(Refer to 391-3-1-.03(10)(g)2.(ii) for descriptions of waste types) 

3. Open burning in compliance with Georgia Rule 39 1-3- 1 -.02 (5). 

I 

4. Stationary engines burning: 

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 

iii) 

not exceed 

Natural gas, LPG, 

standby power 

200 

generation, 

hours per year. 

andlor diesel 

where the combined peaking 

fuel used for other purposes, provided that 

and standby power generation 

the output of 

do 1 

each engine does not exceed 400 horsepower and that no individual engine operates for 

more than 2,000 hours per year. 

iv) Gasoline used for other purposes, provided that the output of each engine does not exceed 

100 horsepower 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 cleaning metal 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 

1 
Title V Permit 

-- 

International Paper -- Savannah Pennit No.: 263 1-05 1-0007-V-02-0 

Category 

Laboratories and 

Testing 

Pollution Control 

industrial 

Operations 

INSIGNIFICANT ACTIVITIES CHECKLIST 

Description of Insignificant ActivityIUnit 

1. Laboratory fume hoods and vents associated with bench-scale laboratory equipment used for - .. physical or chemical analysis. 

2. Research and development facilities, quality control testing facilities and/or small oilot orojects, . - - . where combined daily emissions from all operations are not individually major or are support 

facilities not making significant contributions to the product of a collocated major 

manufacturing facility. 

1. Sanitary waste water collection and treatment systems, except incineration equipment or 

equipment subject to any standard, limitation or other requirement under Section 11 1 or 112 

(excluding 1 12(r)) of the Federal Act. 

2. On site soil or groundwater 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 or other 

requirement under Section 1 1 1 or 11 2 (excluding Il2(r)) of the Federal Act. 

4. Landfills that are not subject to any standard, limitation or other recluirement under Section 11 1 

or 1 12 (excluding 1 I2(r)) of the ~ederal Act. 

1. Concrete block and brick plants, concrete products plants, and ready mix concrete plants 

producing less than 125,000 tons per year. 

2. Any of the following processes or process 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 or metals, the use of which do not involve molten materials 

or oil-coated parts. 

ii) Porcelain enameling furnaces or porcelain enameling drying ovens. 

iii) Kilns for tiling ceramic ware 

i) Crucible tun~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, chloride or tluo~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, or polishing; 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 emissions enter 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 of glass or metals, but not including equipment used - .. 

for sintering metal-bearing ores, metal scale, clay, fly ash, or metal compounds. 

7. Equipment for the mining and screening of uncrushed native sand and gravel. 

8. Ozonization process or process equipment. 

9. Electrostatic powder coating booths with an appropriately designed and operated particulate 

control system. 

10. Activities involving the application of hot melt adhesives where VOC emissions are less 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 of plastics where VOC emissions are 

less than 5 tons per year and HAP emissions are less than 1,000 pounds per year. 

13. Ultraviolet curing processes where VOC emissions are less than 5 tons per year and HAP 

emissions are less than 1,000 pounds per year. 

Quantity 

Appendix Page 3 of 7 
Title V Permit 

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

Category 

Storage Tanks and 

Equipment 

INSIGNIFICANT ACTIVITIES CHECKLIST 

Description of Insignificant Activity/Unit I Quantity 

1. All petroleum liquid storage tanks storing a liquid with a true vapor pressure of equal to or less I 3 

than 0.50 psia as stored. 

2. All petroleum liquid storage tanks 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 1 1 1 or 1 12 (excluding 1 12(r)) of the 

INSIGNIFICANT ACTIVITIES BASED ON EMISSION LEVELS 

J 

Federal Act. 

3. All petroleum liquid storage tanks 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 1 1 1 or 1 12 (excluding 

I 12(r)) of the Federal Act. 

5. Gasoline storage and handling equipment at loading facilities handling less than 20,000 gallons 

per day or at vehicle dispensing facilities that are not subject to any standard, limitation or other 

requirement under Section 11 1 or 1 12 (excluding 1 12(r)) of the Federal Act. 

6. Portable drums, barrels, and totes provided that the volume of each container does not exceed 

550 gallons. 

7. All chemical storage tanks used to store a chemical with a true vapor pressure of less than or 

equal to 10 millimeters of mercury (0.19 psia). 

-. - - - - - 

Description of Emission 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 

Sewer Vent Fan 

Appendix Page 4 of 7 

16 

2 

1 

1 

Solvent Recycle Still 1 
Title V Permit 

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

ATTACHMENT B (continued) 

GENERIC EMISSION 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 of particulate 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) are not included in this table. 

Description of Emissions UnitslActivities 

(Source Code) 

Box Plant Trim Cyclones (CYCL) 

Coal Conveyors (GE01) 

Coal Pile (GE02) 

Coal Silos (GE03) 

Coal Unloading Station (GE04) 

Coal Crushers (GE05) - - 

I c lescoping Chute (GE06) - - 

1 rmsier Tower (GE07) 

Coal Vibrating Feeders (GE08) 

Bark Conveying Systems (GE09) 

2 

8 

1 

4 

Bark Metering Bins (GEI 0) 

Bark Hoggers (GE11) 

Bark Piles (GE 12) 

Air Density Separator Cyclones (GE13) 

Scalping Screens (GE14) 

K2 Chp Screen Fines Cyclone (GEI 5) 

Primary and Secondary Chip Screens (GE16) 

Chip Bins (GE17) 

Fines Bunker (GE18) 

Slicers (GEI 9) 

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.: 263 1-05 1 -0007-V-02-0 

Description of Emissions UnitslActivities 

(Source Code) 

Applicable Rules 

Number 

of Units 'psfi' Fugitive Dust MQ ~rocess (if Rule (h) Ralc (n) Rule (e) 

Log Pile (GE28) 1 J J 

Debarkmg Drums (GE29) 1 J J J 

Chip Conveyors (GE30) 34 J J 

Chip Hogs (GE3 1) 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 

The following table includes groups of fuel 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 BTUlhr burning 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 of Units 

0 

0 

Any fucl bunling equipment with a ratctl heat input capacity of 1 million BTUlhr or less. 0 I 
Title V Permit 

International Paper - Savannah Permit No.: 263 1-05 1-0007-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 State Air Quality Rules. 

2. Title 40 of the Code of Federal Regulations; specifically 40 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 Testing and Monitoring 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's TTN web site at ~~tzw.epa.go~~/ttn/chief/tanks.html. 

7. The Clean 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 of the Past 70 Operating Permits Progam, March 5, 1996 

(White Paper #2). 

Appendix Page 7 of 7