2393 Kimberton lbad @ Suite 100 0 P.O. Box 299 0 Kimberton, PA 19442 

c 610.933.5246 (phone) 9 610.933.5127 (fax) www.al14inc.com 

April 25,2006 

James Boylan, Ph.D. 

Georgia Department of Natural Resources 

Environmental Protection Division - Air Protection Branch 

4244 International Parkway, Suite 120 

Atlanta, GA 30354 

RE: Packaging Corporation of America Valodosta, GA Mill 

Best Available Retrofit Technology (BART) Visibility Modeling Protocol 

Dear Dr. Boylan: 

Enclosed is one copy of a visibility modeling protocol for a Best Available Retrofit 

Technology (BART) exemption modeling analysis for the Packaging Corporation of 

America (PCA) pulp and paper mill located in Valdosta, Georgia. This protocol contains 

information on all BART eligible sources at the Valdosta Mill, as well as a discussion on 

the procedures that will be used to conduct the visibility modeling analysis for these 

sources that is required under the Regional Haze regulations codified in 40 CFR Part 

51.308. 

Please note that the visibility modeling analysis described in this protocol will be 

conducted by the Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS). PCA previously submitted all emissions information associated with the 

BART eligible sources at the Valdosta Mill to the Georgia Environmental Protection 

Division (GEPD) on February 7, 2006. This emissions information was to be forwarded 

to VISTAS by GEPD so that VISTAS can begin the visibility modeling analysis. This 

emissions information is included in the enclosed protocol for completeness purposes. 

PCA believes that this submittal, combined with the earlier submission of emissions data 

on February 7, satisfies GEPDYs requests for information from BART eligible sources. If 

GEPD requires additional information in order to begin the visibility modeling analysis 

for the Valdosta Mill, please contact me at 610-933-5246 Ext. 30. 

Sincerely, 

Thomas S. Wickstrom 

Environmental Scientist 

A114 Inc. 
cc: Virginia Holton (PCA) 

Jim Little (USEPA) 

Cindy M. Huber (USDA Forest Service) 

Catherine Collins (US Fish and Wildlife Service) 
Visibility Modeling Protocol - BART Exemption Modeling 

Submitted Bv: 

PCA - VALDOSTA MILL 

HIGHWAY 31 

CLYATTVILLE, GA 31 604 

Submitted To: 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

4244 international Parkway 

Suite 120 

Atlanta, Georgia 30354-3906 

April 2006 

Prepared bv: 

2393 Kimberton Road, 

Kimberton, PA 19442 

61 0.933.5246 (phone) 

61 0.933.51 27 (fax) 

Suite 100 
TABLE OF CONTENTS 

Section ................................................................................................................... Page Number 

Introduction .................................................................................................................. 1-1 

2 . Description of the PCA Valdosta Mill ....................................................................... 2-1 

2.1 MANUFACTURING PROCESS DESCRIPTION ........................................ 2-1 

2.2 MILL LOCATION .......................................................................................... 2-3 

2.3 LOCATION OF CLASS I AREAS ................................................................. 2-5 

. . 3 . Emissions Inventory ...................................................................................................... 3-1 

3.1 BART ELIGIBLE SOURCES ........................................................................ 3-1 

3.2 EMISSION RATES ....................................................................................... 3-2 

3.3 STACK CHARACTEMSTICS ...................................................................... 3-2 

4 . Visibility Modeling Approach and Technical Information ........................................ 4-1 

4.1 CALMET CONFIGURATION ...................................................................... 4-1 

4.2 CALPUFF CONFIGURATION ...................................................................... 4-2 

4.3 CALPOST AND POSTUTIL CONFIGURATION ......................................... 4-2 

5 . Presentation of Visibility Modeling Results ............................................................ 5-1 

5.1 SUBMITTAL OF AIR QUALITY MODELING RESULTS .......................... 5-1 

6 . References ..................................................................................................................... 6-1 

Appendix A . Emissions Calculations Supporting Information 
LIST OF TABLES 

Table 3-1 Maximum 24-hr Emission Rates ................................................................................. 3-3 

Table 3-2 Stack Characteristics ................................................................................................... 3-4 
LIST OF FIGURES 

Figure 2-1 Location of PCA Valdosta Mill ....... .. .. ..... .. ..... .. .... . ........ ... . . ........... . . . . 2-4 

Figure 2-2 Location of Class I Areas within 300 km of the PCA Valdosta Mill ......................... 2-6 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

1. INTRODUCTION 

Packaging Corporation of America (PCA) owns and operates a kraft pulp mill (the "Mill") 

in Valdosta, Georgia. The Mill produces linerboard, which is used in the outer plies of 

corrugated box stock and in various other packaging. The Mill is a major source as 

defined by the federal operating permit program (40 CFR Part 70) and the federal new 

source review (NSR) program (40 CFR Part 52). In addition, the Mill is also subject to 

the Georgia Title V permit regulations and Prevention of Significant Deterioration (PSD) 

regulations, Chapter 391 -3-1 -.O3(lO) and 391 -3-1 -.O2(7), respectively. 

The Mill is subject to the Best Available Retrofit Technology (BART) rule that is part of 

the Regional Haze Rules listed at 40 CFR Part 51.308. Under the Regional Haze rules, 

an air quality modeling analysis is required to be performed for facilities that have BART 

eligible sources to determine if the sources at the facility cause or contribute to visibility 

impairment at nearby Class I areas. If the source does not cause or contribute to visibility 

impairment, then the facility with BART eligible sources does not need to conduct any 

further air quality modeling under the Regional Haze Rules. 

The Visibility Improvement State and Tribal Association of the Southeast (VISTAS) has 

established modeling procedures (VISTAS Common Modeling Protocol - 2005) that 

sources should follow to conduct visibility modeling for BART. In addition to 

establishing the modeling procedures, VISTAS has processed meteorological data for the 

CALPUFF model that should be used in any BART modeling analysis. The Georgia 

Environmental Protection Division (GEPD) has offered VISTAS as a technical resource 

to assist some sources in completion of the necessary CALPUFF modeling analyses. The 

assistance is available to sources with a ratio of actual annual SOz emissions (tpy) to 

distance to the nearest Class I area (krn) (i.e., the Q/D ratio) of 10 or lower. The PCA 

Valdosta Mill is one of the sources that qualifies for VISTAS assistance. 

For sources with Q/D<10, VISTAS has proposed that these sources attempt to show that 

they do not cause or contribute to visibility impairment through a BART exemption 

BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 

1-1 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

modeling process. This air quality modeling protocol outlines the procedures that will be 

used to conduct the BART exemption modeling. It should be noted that PCA is 

submitting the air quality modeling protocol to GEPD to provide documentation of the 

visibility modeling procedures that will be used, despite the fact that the actual modeling 

will be conducted by VISTAS. Since VISTAS will follow procedures outlined in their 

guidance document, this protocol will serve to (1) identify the BART eligible units at the 

PCA Valdosta Mill, (2) quantify emission rates and stack parameters, and (3) re-affirm 

the parameters that VISTAS will use in visibility modeling analyses of the PCA Valdosta 

Mill. 

The air quality modeling protocol includes the following sections: 

Section 2 Description of the PCA Valdosta Mill 

Section 3 Emissions Inventory 

Section 4 Visibility Modeling Approach and Technical Information 

Section 5 Presentation of Air Quality Modeling Results 

Section 6 References 

Appendix A - Emissions Calculations Supporting Information 

BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 

1-2 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

2. DESCRIPTION OF THE PCA VALDOSTA MILL 

This section of the BART exemption modeling protocol contains a description of the 

PCA Valdosta Mill. The description contains general information on the manufacturing 

processes, and a description of the geographic and topographic setting of the Mill. 

2.7 MANUFACTURING PROCESS DESCRIPTION 

The facility produces linerboard, which is used in the outer plies of corrugated box stock 

and in various other packaging. The Mill process begins as logs are delivered to the Mill by 

truck. The logs are debarked and processed into wood chips, which are then screened and 

transferred to storage in chip piles or stored in chip silos. Purchased chips are also delivered 

by truck and rail and are combined with the processed chips in the chip piles. The chips are 

reclaimed fi-om the chip piles, and then are screened and processed in the Mill's digesters or 

are stored in chip silos prior to being processed in the Mill's digesters. The bark and screen 

rejects are collected and burned in the C.E. and Riley Combination Boilers. Purchased 

wood refuse, sawdust, and bark (collectively referred to as wood residue fuel) are stored in a 

wood residue fuel pile for subsequent firing in these two boilers. 

Wood chips are transferred by conveyor and charged to one of ten batch digesters where 

they are cooked in white liquor; a sodium hydroxide/sodium sulfide solution. During the 

cooking process, steam is added with the white liquor and chips which causes high 

temperature and pressure in the digester. At this elevated pressure and temperature, the 

caustic in the white liquor penetrates the chips and dissolves and breaks down the lignin 

and other organics in the wood. 

When the cooking process is completed, the digester blow valve is opened and the 

contents are "blowny' into a blow tank. As the digester is blown, the abrupt pressure 

change causes the cooked chips to transform into fibers. These fibers make up the pulp that 

is ultimately made into linerboard. 

The pulp is refined, screened and washed to remove the excess spent cooking liquor. The 

spent cooking liquor (black liquor) contains the lignin and other impurities fkom the chips 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

as well as the spent inorganic fraction of the cooking liquor. The black liquor is washed 

from the pulp in the brown stock washers (No. 3A BSW System), and is then collected and 

processed in the recovery area of the Mill. The washed pulp, referred to as stock, is 

removed from the washers and stored in high-density stock tanks. The stock from the tanks 

is mixed with certain additives and also with internally recycled pulp and is then processed 

on the paper machine. The paper machine forms the pulp into a continuous web, which is 

then drained, pressed, dried, and wound into large rolls of finished linerboard. 

In the kraft process, the black liquor from the brown stock washers is reprocessed back into 

white liquor in the chemical recovery cycle and is then reused in the digesters. The black 

liquor from the brown stock washers, referred to as weak black liquor, is collected and sent 

to the multiple effect evaporators (MEE). The MEE removes water and concentrates the 

solids in the black liquor. Additional evaporation occurs in the black liquor oxidation 

system and in the direct contact evaporator (DCE) sections of the recovery furnaces. The 

black liquor can be fired in one of three recovery furnaces at the Mill. In the recovery 

furnaces, the organics in the black liquor are burned off in a reducing atmosphere, 

producing steam and leaving molten sodium carbonate and sodium sulfides behind. The 

molten mass of salts, called smelt, flows to a tank in which weak wash from the causticizing 

area is mixed with the smelt to create an intermediate stream called green liquor. 

Green liquor is an aqueous solution of sodium carbonate and sodium sulfide that has a 

greenish tint. The green liquor is processed in the causticizing area, where it is converted 

back into white liquor by adding lime (calcium oxide) to it. The lime converts the sodium 

carbonate into sodium hydroxide and calcium carbonate. The sodium hydroxide is soluble, 

and this caustic solution is recovered as white liquor, stored, and reused in the digesters. 

The calcium carbonate precipitates out of the white liquor, and is collected, washed, and 

calcined in the lime kiln, which converts the calcium carbonate back to calcium oxide by 

adding heat. The "reburned" lime is stored and added again to green liquor. 

In addition to the C.E. Combination Boiler and the Riley Combination Boiler, the Mill 

operates two other power boilers, the C.E. Power Boiler and a Package Boiler. The C.E. 

Power Boiler can fire natural gas and fuel oil while the standby Package Boiler fires natural 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

gas. The boilers, as well as the recovery haces, produce steam for process and heating 

use throughout the facility. The steam is also used to drive steam turbines that produce a 

portion of the Mill's electricity requirements. The remaining electrical power is purchased 

fiom the local public utility. 

The Mill operates a wastewater treatment plant that treats process wastewater fiom the Mill 

prior to discharge to the Withlacoochee River. The wastewater treatment process includes 

primary clarification, followed by secondary biological treatment in a series of 

impoundments. Land application of the effluent is the back-up method of treatment for dry 

weather scenarios. 

2.2 MILLLOCATION 

The Valdosta Mill is located in Clyattville, Georgia which is approximately 16 kilometer 

(km) south of Valdosta, Georgia. Situated in the southern portion of Lowndes County, the 

Mill is about 5 Ism fiom the Georgia and Florida border. A facility location map is provided 

in Figure 2- 1. 

The geographical coordinates for the approximate center of the processing area of the Mill 

are: 

Universal Transverse Mercator (UTM) Easting: 279,400 

Universal Transverse Mercator (UTM) Northing: 3,397,800 

UTM Zone : 17 

North American Datum (NAD): 1927 

Longitude (degrees, minutes, seconds): 83" 18' 11.2" 

Latitude (degrees, minutes, seconds): 30" 41' 39.3" 

The Valdosta Mill is in the Southwest Georgia Intrastate Air Quality Control Region 

(AQCR). Within this AQCR, Lowndes County is in attainment or 

unclassifiable/attainment for all criteria pollutants including ozone as designated in the 

July 2003 Code of Federal Regulations and amended on September 26, 2003. It is also 

anticipated that the area will be in attainment with PM2.5. The area surrounding the 
0 

1 

1 

kilometers nsed on USGS 1 24,000 topographcal map for Clyalonlle, Gowgtn, 1988 

a 

Packaging Corporation of America 

Valdosta Mill 

Clyattville, Lowndes County, Georgia 

FIGURE 2-1 

FACILITY LOCATION MAP 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

Valdosta Mill is generally flat with minor changes in elevation. The Mill elevation is 200 

fi above mean sea level (arnsl). 

2.3 LOCATION OF CLASS I AREAS 

The following five Class I areas are located within 300 km of the PCA Valdosta Mill: 

e Okefenokee National Wildlife Refuge: 73.1 km 

e St. Marks National Wildlife Refuge: 89.1 km 

e Bradwell Bay Wilderness: 128.5 km 

e Wolf Island National Wildlife Refuge: 201 km 

Chassahowitzka National Wildlife Refuge: 220.8 km 

A map showing the locations of these Class I areas and the PCA Valdosta Mill is shown 

in Figure 2-2. 
Scale In Kilometers Figure 2-2 

Location of Class I Areas 

0 150 300 Within 300 km of the PCA Valdosta Mill 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

3. EMISSIONS INVENTORY 

This section identifies the BART eligible units at the PCA Valdosta Mill and provides an 

overview of the emissions data that were developed and will be relied upon for the BART 

exemption modeling analysis. 

3.1 BART ELIGIBLE SOURCES 

The final Regional Haze Regulations and Guidelines for BART Determinations were 

published on July 6, 2005 in the Federal Register. According to the guidance contained 

in the Regional Haze Regulations, a source is considered BART eligible if the following 

three criteria are met: 

If the potential emissions are at least 250 tpy of a visibility impairing 

pollutant; 

= If the source was installed between August 7, 1962 and August 7, 1977; 

and 

If the source falls within one of the 26 listed source categories summarized 

in the guidance. 

The BART eligible sources at the PCA Valdosta Mill are: 

Riley Bark Boiler 

No. 3 Recovery Furnace 

No. 3 Smelt Dissolving Tank 

Lime Slaker 

These sources have been identified by GEPD as meeting the emissions and installation 

date criteria for BART eligibility. These are the only sources at the Mill that will be 

included in the BART exemption modeling. 

3-1 BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

3.2 EMISSION RATES 

The Regional Haze Regulations state that the highest 24-hour average actual emission 

rate of visibility impairing pollutants for the most recent three to five years be used in the 

visibility modeling analysis. VISTAS defines visibility impairing pollutants as SOz, 

NOx, H2S04, and PMlo, and PMlo sub-species. The 24-hr actual emission rates of these 

pollutants fiom the BART eligible sources at the PCA Valdosta Mill are shown in Table 

3-1. These emission rates represent maximum daily production data applied to emission 

factors for each pollutant. All relevant supporting information for the emissions 

calculations is included in Appendix A of this protocol. These data were previously 

provided to GEPD on February 7,2006, as required. 

The stack characteristics for the BART eligible sources are provided in Table 3-2. The 

gas stream volumetric flow rates and temperatures represent stack data used in previous 

air quality modeling analyses of the PCA Valdosta Mill. 

The VISTAS visibility modeling procedures state that facilities that are not within 50 krn 

of a Class I area do not need to consider building downwash in the BART modeling 

analysis. As shown in Section 2, the PCA Valdosta Mill is not located within 50 km of 

any Class I area, and therefore, no building downwash information is included in this 

protocol. 

3 -2 

BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 
Table 3-1 

BART 24-Hour Emission Rates 

PCA Valdosta Mill 

Valdosta, GA 

Riley Bark Boiler NCASl Tech Bulletin 98% of TPM is PM2.5 and 98% of TPM is PMIO 

No. 3 Recovery Furnace NCASl Tech Bulletin 51% of TPM is PM2.5 and 67.2% is PMlO 

No. 3 Smelt Dissolving Tank NCASl Tech Bulletin 89.6% of TPM is PM2.5 and 89.5% is PMIO 

Slaker NCASl Tech Bulletin 98% of TPM is PM2.5 and 100% is PMIO 

Emission Unit 

Riley Bark Boiler 

No. 3 Recovery Furnace 

No. 3 Smelt Dissolving Tank 

Slaker 

E \Clrcnt FdesWCA\Vddona\BARTU3ART Emmwn Rater 2 02 06 dhTsble 2 BART Emlsslons 

Modeling ID 

CSS 

#3RFS 

#3 SDTS 

SLAKER 

BART SO2 24-Hour 

Emission Rate 

(g/sec) 

6.85 

12.85 

0.05 

0.00 

BART NO, 24-Hour 

Emission Rate 

(g/sec) 

10.69 

4.77 

0.00 

0.00 

BART PMlo 

Emission Rate 

(g/sec) 

0.00 

0.15 

0.00 

0.019 

BART PM2.5 

Emission Rate 

(g/sec) 

4.86 

0.48 

0.17 

0.138 
Table 3-2 

Summary of Physical Stack Characteristics for BART Sources 

at the PCA Valdosta Mill 

Valdosta, Georgia 

E \CItentFtlcs\RCA\Val&sta\BARnSART Emman Rates 2 02 06 &Table I BART Stat lnfo 

Source 

Riley Bark Boiler 

#3 Recovery Furnace Stack 

#3 Smelt Dissolving Tank Stack 

Slaker Stack 

Stack ID 

CSS 

#3RFS 

#3SDTS 

SLAKER 

Stack Location 

OJTM Coordinates NAD 27) 

Stack 

Elevation 

(meters) 

61.0 

61.0 

61.0 

61.0 

279,250 

279,303 

279,305 

279,400 

3,397,874 

3,397,846 

3,397,816 

3,397,776 

Stack 

Height 

(meters) 

61.26 

55.17 

33.53 

27.43 

Stack 

Exit Velocity 

(meterskec) 

14.10 

20.71 

9.31 

7.34 

Stack 

Temperature 

(degrees K) 

338.0 

395.0 

328.0 

311.0 

Stack 

Diameter 

(meters) 

3 .05 

2.13 

1.22 

0.61 
Packaging Corporation of America Valposta, GA Mill 

BART Exemption Modeling Protocol 

4. VISIBILITY MODELING APPROACH AND TECHNICAL 

INFORMATION 

This section of the air quality modeling protocol contains information on the technical 

approach that will be followed in the air quality modeling study. The technical approach 

follows the guidance established in the VISTAS modeling protocol, and outlines the 

configurations for CALMET and CALPUFF that will be used by VISTAS to model the 

BART sources at the PCA Valdosta Mill. 

4.1 CALMET CONFlGURATION 

CALMET will be configured as outlined in the VISTAS modeling protocol for BART 

exemption modeling. VISTAS identified the following basic features for the 12-krn 

CALMET runs: 

Modeling period: 3 years (200 1-2003). 

Meteorological inputs: MM5 data provide initial guess fields in CALMET 

CALMET grid resolution: 12-km. 

CALMET vertical layers: 10 layers. Cell face heights (meters): 0, 20, 40, 

80,160,320,640,1200,2000,3000,4000. 

CALMET mode: No-Observations mode including option to read 

overwater data directly from MM5 data. 

Diagnostic options: IWAQM default values, except as follows: diagnostic 

terrain blocking and slope flow algorithms used for 2003 simulations 

(using 36-lun MM5 data), but no diagnostic terrain adjustments in 2001 

and 2002 simulation (using 12-km MM5 data). 

Land use defining water: JWATl = 55, JWAT2 = 55 (large bodies of 

water). 

Geophysical data for regional runs: SRTM-GTOP030 30-arcsec terrain 

data, Composite Theme Grid (CTG) USGS 200m land use dataset. 

BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 

4- 1 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

4.2 CA LPUFF CONFIGURA TlON 

CALPUFF will be configured by VISTAS to model emissions from the PCA Valdosta 

Mill. The following configurations will be used by the VISTAS contractor, as outlined in 

the VISTAS common modeling protocol: 

No building downwash considered. 

CALPUFF domains will be set to an area that provides an adequate buffer 

around all modeled Class I areas. The domains will be sized so to ensure 

at least a 50 km buffer surrounding the Class I area. 

VISTAS will use background concentrations of sulfate and total nitrate 

from their CMAQ runs using 200 1-2003 meteorological data. 

VISTAS will model SO2, H2SO4, NOX, and PMlo (including sub-PMlo 

speciations) from the BART eligible sources at the PCA Valdosta mill. 

VISTAS will use the receptor grids developed by the National Park 

Service for the Okefenokee, Wolf Island Bradwell Bay, St. Marks, and 

Chassahowitzka Class I areas. 

The Pasquill-Gifford (P-G) dispersion option will be used. 

Observed non-urban ozone data for the 2001-2003 CASTnet and AIRS 

monitoring networks will be used. 

A background ammonia concentration of 0.5 ppb will be used. 

a The integrated puff sampling methodology will be used. 

4.3 CALPOST AND POSTUTIL CONFIGURATION 

CALPOST and POSTUTIL will be configured by VISTAS to estimate visibility impacts 

at both Class I areas. The following configurations, as outlined in the VISTAS common 

modeling protocol, will be used: 

BART Exemption Modeling Protowl - PCA Valdosta Wvs Comments 

4-2 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

Visibility Method 6 with Class I area specific monthly relative humidity 

values will be used. 

Ammonia concentrations from CMAQ will be used to define NH3 for each 

Class I area. 

= Natural background light extinction values will be calculated using the 

USEPA's "Guidance for Estimating Visibility for Regional Haze 

Estimates" guidance document. A Raleigh scattering efficiency of ~m-' 

will be used for all Class I areas. 

As stated previously in this protocol, PCA will not be responsible for the CALPUFF 

modeling runs. The modeling effort will be conducted by VISTAS. The 

CALPUFFICALMETICALPOST settings presented here are consistent with the VISTAS 

common modeling protocol. PCA assumes that the VISTAS contractor will not deviate 

from the methodology presented in the VISTAS common modeling protocol. 

BART Exemption Modeling Protocol - PCA Valdosta Wvs Comments 

4-3 
Packaging Corporation of America Valdosta, GA Mill 

BART Exemption Modeling Protocol 

5. PRESENTATION OF VISIBILITY MODELING RESULTS 

This section of the protocol discusses how the results from the visibility modeling 

analyses will be evaluated. PCA will be responsible for the submittal of the visibility 

modeling results for GEPD upon receiving the results of the visibility modeling from 

VISTAS. 

5.1 SUBMITTAL OF AIR QUALITY MODELING RESULTS 

A brief report will be submitted to GEPD that presents the results of the BART 

exemption modeling analysis. For the purposes of this analysis, the PCA Valdosta 

facility will be considered "exempt" from further modeling requirements under the BART 

rule if the results show that no impacts greater than a 0.5 deciview change in visibility 

occur on a 24-hr basis occur over the entire modeling period. The modeling submittal 

will essentially consist of a summary of emission rates, stack characteristics, and a results 

table. The results table will include impacts for all Class I areas within 300 km of the 

Mill. PCA anticipates submitting results to GEPD soon after receiving the visibility 

outputs from VISTAS. 

BART Exempt~on Modeling Protocol - PCA Valdosta Wvs Comments 

5- 1 
6. REFERENCES 

VISTAS 2005 - "Protocol for the Application of the CALPUFF Model for Analyses of Best 

Available Retrofit Technology (BART)" - Visibility Improvement State and Tribal Association 

of the Southeast (VISTAS) 

K BART Exemption Modelmg Protocol - PCA Valdosta ws comments 
APPENDIX A - EMISSIONS CALCULATIONS SUPPORTING 

INFORMATION 

I 

BART Exempt~on Modelfng Protocol - PCA Valdosta wvs comments