Appendix M 

Permit Conditions for 

Sources Subject to Additional BART or 

Reasonable Progress Requirements 
Emissions Limits Established Through BART Analysis

Permit Conditions for Interstate Paper, Power Boiler

1. The Permittee shall: (a) burn only natural gas in the Power Boiler (Source Code 

PW01) except during periods of natural gas curtailment, and (b) burn TRScontaining waste gas streams in the Power Boiler only during periods when both 

the Lime Kiln (primary TRS waste control device) and the Multi-fuel Boiler 

(secondary TRS waste control device) are out of service. This requirement shall 

be effective on the first day of the sixty-first month after the month in which 

Georgia’s Regional Haze State Implementation Plan (for the progress period 

ending in 2018) is approved by U.S. EPA. 

 

2. The Permittee shall submit a plan for any physical or operational changes required 

to meet Condition 1 not later than 18 months prior to the effective date of 

Condition 1.. The plan, if required, shall include all permit applications required 

under Georgia Air Quality Control Rules 391-3-1-.03. 

3. 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 1. The Permittee shall submit the proposal (or plan) 

not later than 18 months prior to the effective date of Condition 1. 
Emissions Limits Established Through Four-Factor Analysis

The following language will be added to the respective facility permits as part of the SIP 

implementation process. 

Permit Conditions for GA Pacific Brunswick Cellulose, Power Boiler No. 4

1. Effective January 1, 2012, the Permittee shall not discharge, or cause the 

discharge, into the atmosphere from Power Boiler #4 (Source Code U700) sulfur 

dioxide (SO2) emissions in excess of 568 tons during any twelve-consecutive 

month period. The first compliance period shall be January through December, 

2012. 

2. The Permittee shall submit a plan for complying with the emission limit of 

condition 1, 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 1, on or before June 30, 2010. 

3. 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 1, on or before June 30, 2010. 

Permit Conditions for International Paper Savannah Mill, Power Boiler No. 13

1. Effective January 1, 2016, the Permittee shall not discharge, or cause the 

discharge, into the atmosphere from Power Boiler No. 13 (Source Code PB13) 

and from the combustion of low-volume high-concentration (LVHC) noncondensable gases, high-volume low-concentration (HVLC) non-condensable 

gases, and stripper off-gases (SOG) (excluding the combustion of any of these 

gases No. 7 Lime Kiln (LK07)) sulfur dioxide (SO2) emissions in excess of 6578 

tons respectively during any twelve-consecutive month period. The first 

compliance period shall be January through December, 2016. 

2. The Permittee shall submit a plan for complying with the emission limit of 

condition 1, 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 1, on or before June 30, 2014. 

3. 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 1, on or before June 30, 2014. 
Permit Conditions for Georgia-Pacific Cedar Springs Recovery Boiler 3 and Power 

Boilers 1 and 2

(Note that these conditions have been proposed as a Title V permit amendment in order 

to exempt the facility from BART determination requirements as well as to satisfy the 

reasonable progress requirements of Regional Haze.) 

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. 

Addition of caustic, limestone or both as a scrubbing media to the existing 

scrubbers use to control PM emissions from Power Boiler No. 1 and Power Boiler 

No.2 

Limiting the SO2 emissions from the recovery boiler to 350 ppm when firing 

black liquor on a daily average basis 

Limit the daily average SO2 emissions from the Power Boiler No. 1 and Power 

Boiler No. 2 to 135 lb/hr each. 

Install CEMS on Recovery Boiler No. 3 to monitor SO2 emissions. 

Repair concentrator sets, install a new caustic day tank and a new lift station to 

connect power boiler scrubber blowdown to the waste water treatment system. 

3.2.6 Upon completion of the BART 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. Sulfur dioxide emissions in excess of 350 ppm on a dry basis corrected to 

8 percent oxygen as a 24-hour average when firing black liquor solids 

3.2.19 Upon completion of the BART project, the Permittee shall abide by the following 

emission limits: 

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 24 hour period. 

4.2.26 Within 90 days of the completion of the BART 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 and also establish the 
excursion limits for pH of the scrubbing solution 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. 

4.2.27 Within 90 days of the completion of the BART 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. 

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. 

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 project 

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. 

d. Pressure drop, pH and scrubbant flow rate from the scrubbers on Power 

Boiler No. 1 and No. 2 (Source Codes U500 and U501). 

The requirement for the measurement of pH will be effective on the date 

of the completion of the BART project. 

5.2.19 The following pollutant specific emission units (PSEUs) are subject to the 

Compliance Assurance Monitoring (CAM) Rule in 40 CFR 64. 

Emission Unit Pollutant 

Power Boiler Nos. 1 and 2 (Source Codes U500 and U501) SO2

In addition, the Permittee shall meet the requirements, as applicable, of 40 CFR 

64.7, 64.8, and 64.9. 
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): 

Performance Criteria Indicator No. 1 

Scrubbant Flow Rate 

Indicator No. 2 

Pressure Drop Across 

Scrubber 

Indicator No. 3 

PH of Scrubbing Media 

A. Data 

Representativeness

The flow rate is 

measured using 

standard instrumentation 

provided for this 

purpose.

The differential pressure 

across the scrubber will 

be measured using 

standard instrumentation 

provided for this 

purpose.

Continuous monitoring 

of scrubbant pH.

B. Verification of 

Operational Status 

(new/modified 

monitoring equipment 

only)

N/A N/A N/A

C. QA/QC Practices and 

Criteria

Annual Calibration. Annual Calibration. Annual Calibration.

D. Monitoring Frequency Continuous. Continuous. Continuous.

E. Data Collection 

Procedures

Recorded by the mill 

data collection system.

Recorded by the mill 

data collection system.

Recorded by the mill 

data collection system.

F. Averaging Period 3-hour average. 3-hour average. 3-hour average.

5.2.29 For 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: 

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 

60.13(d).

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: 

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 project, the Permittee shall abide 

by the following : 

For Recovery Boiler No. 3 (Source Codes R402), 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.c is in excess of 350 ppm on a 

dry basis corrected to 8 percent oxygen when firing black liquor 

only. 

Power Boilers No. 1 and 2 

xvi. Upon completion of the BART 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 lbs per hour. 

c. Excursions: (means for the purpose of this Condition and Condition 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) 

Power Boilers No. 1 and No. 2 

viii. Upon completion of the BART project, the Permittee shall abide 

by the following: 

Any three consecutive 1-hour periods during which the pH 

measured and recorded in accordance with Condition 5.2.2.d for 

either scrubber on Power Boiler No. 1 or No. 2 (Source Codes 

U500 and U501) fall below the values established during the 

performance test required by condition 4.2.26. 

6.2.47 The Permittee shall submit the actual date of the completion of the BART Project. 

This submittal shall include certification that a final inspection has shown that the 

BART Project was completed in accordance with Application No.18385. This 

notification shall be submitted within 15 days following the completion of the 

BART Project. 

 
6.2.48 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 twelvemonth 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 Permittee 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 30th 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. 

7.14.1 The scrubber modification for Power Boilers 1 and 2 and repairs to the 

concentrators sets (BART project) along with all changes identified in Condition 

1.3 to comply with BART shall be completed by July 30, 2011.