# Appendix M

Permit Conditions for Sources Subject to Additional BART or Reasonable Progress RequirementsE miss ions Limits Established Through BART Analysis

Permit Conditions for Interstate Paper, Power Boiler

1. The Permittee shall: (a) bur n only natural gas in the Power Boiler (Source Code PW01) except during periods of natura l gas curtailment, and (b) burn TRScontaining waste gas streams in the Po wer Boiler only during periods when both the Lime Kiln (primary TRS waste cont rol 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 sixt y-first month after the month in which Georgia’s Regional Haze State Implemen tation Plan (for the progress period ending in 2018) is approved by U.S. EPA.

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

to meet Condition 1 not later than 18 m onths 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, whiche ver is applicable, in order to ensure compliance with Condition 1. The Permitt ee shall submit the proposal (or plan) not later than 18 months prior to the effective date of Condition 1.E miss ions Limits Established Through Four-Factor Analysis

The following language will be added to the resp ective 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 Po wer Boiler #4 (Source Code U700) sulfur dioxide (SO2) emissions in excess of 568 tons during any twelve-consecutive month period. The first compliance pe riod 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, whiche ver is applicable, in order to ensure compliance with condition 1, on or before June 30, 2010.

Permit Conditions for International Pape r 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-vol ume high-concentration (LVHC) noncondensable gases, high-volume low-concentration (HVLC) non-condensable gases, and stripper off-gases (SOG) (exc luding 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-c onsecutive 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, whiche ver is applicable, in order to ensure compliance with condition 1, on or before June 30, 2014.Permit Conditions for Georgia-Pacific Ceda r Springs Recovery Boiler 3 and Power

Boilers 1 and 2

(Note that these conditions have been propos ed 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 ma king 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, th e 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 averag e 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 Po wer Boilers No. 1 and 2 to determine compliance with the limits specified in Condition 3.2.19 and also establish theexcursion limits for pH of the scrubbing solution to meet the limits specified in Condition 3.2.19. The RATA test and the pe rformance 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 R ecovery Boiler No. 3 (Source Code R402) to determine compliance with the limits specified in Condition 3.2.6. The RATA test and the performance te st shall be performed si multaneously. The compliance

with the emission limits in condition 3.2.6 will be demonstrated using continuous 24 hour of CEMS data, the first hour starti ng 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 a pplicable 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 inst allation of a continuous m onitor 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 r ecord the indicated parameters on the following equipment. Where such performance specification(s) exist, each system shall meet the applicable performance specifi cation(s) of the Division's monitoring requirements.

d. Pressure drop, pH and scrubbant fl ow 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 emissi on units (PSEUs) are subject to the Compliance Assurance Monitori ng (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 perfor mance criteria listed in the table below for the particulate matter and sulfur dioxi de 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 (R ATA) shall be conducted on the CEMS at least once every four successive op erating 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 conduc ted daily in accordance with 40 CFR 60.13(d).

6.1.7 For the purpose of reporting excess emi ssions, exceedances or excursions in the report required in Condition 6.1.4, the fo llowing 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 pr oject, the Permittee shall abide by the following :

For Recovery Boiler No. 3 (Source Codes R402), any 24-hour period during which the SO2 con centration, expressed as the arithmetic average of 24 conti guous 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 rang e 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 acco rdance 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 applicab le 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-mont h rolling emission totals, records of demonstration calculations, records of any factors us ed in the calculation of criteria pollutant emissions, and ot her 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.