IP has a Federal Operating Permit (No. 5-1548-

00008/00081) issued under the Clean Air Act that was 

approved by the NY DEC to insure that it operates its 

paper mill in continuous compliance with all the 

general and special conditions and emissions 

limitations set out in the permit (111 pages) for the 

purpose of safeguarding the public health and 

environment. Violations of the Clean Air Act are 

subject to penalties of $32,500 per violation per day. 

IP violated multiple conditions of its Title V Federal 

Operating Permit for stack testing of the main power 

boiler. Since the permit violations occurred over 

multiple periods and days during the TDF test burns, 

IP committed numerous Clean Air Act violations from 

November 7-13, 2006. The Title V permit requires 

continuous compliance with EPA Reference Method 

(EPA RM) 5 to conduct stack testing for particulate 

matter whenever TDF was being fed to the main power 

boiler identified as Emission Unit: P-OWERH in the 

permit, but IP failed to operate the boiler in continuous 

compliance since frequent periods occurred when EPA

RM 5 samples and measurements were not being 

collected when TDF was being fed into the boiler for 

combustion. Continuous compliance was also required 

by the Title V permit with the 20% stack opacity limitation 

at all times during TDF firing in the boiler, which was to be 

determined using EPA Reference Method 9 by a 

certified observer during daylight hours. As a result, 

the TDF burning after sunset was in violation of the Title V 

Federal Operating Permit conditions since it's not 

feasible to take stack opacity readings using EPA RM 9 
without sunlight, and therefore the stack opacity level 

could not be observed and measured for continuous 

compliance as required by the permit. The Title V permit 

further states: “If the opacity exceeds 20%, the facility 

must stop adding TDF until emissions stabilize and 

are in compliance.” Without sunlight, EPA RM 9 could 

not be applied to determine if IP was exceeding the 20% 

stack opacity limitation.

NY DEC

Permit ID: 5-1548-00008/00081 Facility DEC ID: 

5154800008

Page 29 in Title V permit

Item 24.1(From Mod 5):

The facility is authorized to perform regulated processes 

under this permit for:

Emission Unit: P-OWERH

Emission Unit Description:

The power boiler is a multi-fuel boiler that fires no. 6 fuel 
oil, waste fuel type "A", wood residue consisting of bark, 

wood and sawdust, rejected digester wood knots, primary 

clarifier fiber and dried secondary biomass for the 

production of steam and electricity via a turbine generator. 

In addition, the power boiler is used to treat noncondensible gases (ncgs), which are produced in the 

pulping and chemical recovery processes, through thermal 

oxidation. For this modification, the boiler will fire a 

combination of oil, wood and tire derived fuel during a 

two week trial and testing period. It is not an incinerator 

and incinerator regulations such as 6NYCRR Part 219 and 

40CFR61 Subpart E do not apply.

Page 51

Item 37.1(From Mod 5):

This permit authorizes the following regulated processes 

for the cited Emission Unit:

Emission Unit: P-OWERH

Process: TDF Source Classification Code: 1-02-009-01

Process Description:

During a 14 day trial and testing period, tire-derived fuel 

(TDF) will be combusted in the boiler along with number 6 

fuel oil and wood. Alternative fuels (rejected digester knots 

and secondary biosolids) shall not be burned while TDF is 
being burned. The TDF loading will not exceed 3 tons per 

hour and the total heat input to the boiler will not exceed 

748 MMBtu per hour. TDF will be added to wood in the 

woodyard and pneumatically conveyed with the wood to 

the boiler.

During the first week, TDF will be added in gradually 

increasing amounts while the boiler operators adjust 

the boiler to achieve optimum combustion conditions. 

During the second week, extensive stack testing will be 

performed to charactarize emissions. While the trial period 

is planned to be accomplished during consecutive days, it 

is understood that unforeseen conditions may cause 

delays. If such conditions occur, the trial may be 

accomplished during 14 days of TDF use over a 21 day 

period. Whenever TDF is being burned, facility personnel 

will monitor the SO2 emission rate, NOX emission rate 

and stack opacity (during daylight

hours). If any of these indicators exceed permit limits, the

facility will stop adding TDF until the conditions have 

stabilized and are in compliance. During the first week, 

PM emissions will be measured (using EPA Method 5) 

at baseline condition and while TDF is added at 1 ton 

per hour (TPH); 2 TPH; and 3 TPH. If PM emissions 

exceed 0.10 pounds per MMBtu, the facility will stop 

adding TDF.

Page 78
The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Regulated Contaminant(s):

CAS No: 0NY210-00-0 OXIDES OF NITROGEN

Item 5-16.2:

Compliance Certification shall include the following 

monitoring:

Monitoring Type: CONTINUOUS EMISSION 

MONITORING (CEM) 

Monitoring Description:

Whenever tire-derived fuel (TDF) is being burned in the 

power boiler, the NOX emission rate must not exceed 0.25 

pounds per MMBtu. This indicates that the power boiler is 

operating properly. If the NOX emission rate exceeds 0.25 

pounds per MMBtu, the facility must stop adding TDF until 

NOX emissions stabilize and are in compliance.

Manufacturer Name/Model Number: Thermo 

Environmental Model 42C 

Parameter Monitored: OXIDES OF NITROGEN

Upper Permit Limit: 0.25 pounds per million Btus

Reference Test Method: PS-2

Monitoring Frequency: CONTINUOUS

Averaging Method: 3-HOUR BLOCK AVERAGE

Reporting Requirements: ONCE / BATCH OR 

MONITORING OCCURRENCE
Page 79

Item 5-17.1:

The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Item 5-17.2:

Compliance Certification shall include the following 

monitoring:

Monitoring Type: WORK PRACTICE INVOLVING 

SPECIFIC OPERATIONS

Monitoring Description:

Tire-derived fuel (TDF) may be burned in the power boiler 

for a trial period of up to 14 days over a period not to 

exceed 21 consecutive days. The TDF fuel rate shall not 

exceed 3 tons per hour and the total heat input to the 

boiler shall not exceed 748 MMBtu per hour. In addition, 

the only other fuels that may be burned while TDF is being 

burned are oil, wood and non-condensible gases.

Work Practice Type: PROCESS MATERIAL THRUPUT

Process Material: MATERIAL

Upper Permit Limit: 3 tons per hour

Monitoring Frequency: CONTINUOUS

Averaging Method: 1 HOUR MAXIMUM - NOT TO BE 

EXCEEDED AT ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 10/30/2006.

Subsequent reports are due every 6 calendar month(s).
Condition 5-18: Compliance Certification

Effective between the dates of 09/20/2006 and 

06/19/2006

Applicable Federal Requirement: 6NYCRR 200.6

Item 5-18.1:

The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Item 5-18.2:

Compliance Certification shall include the following 

monitoring:

Air Pollution Control Permit Conditions

Mod 5/Active Page 71 of 103 FINAL

Page 80 

Monitoring Type: MONITORING OF PROCESS OR 

CONTROL DEVICE PARAMETERS AS SURROGATE

Monitoring Description:

Whenever tire-derived fuel (TDF) is being burned in the 

power boiler, the opacity must not exceed 20%. The 

facility shall have a certified method 9 opacity 

observer available during daylight hours to make 

hourly readings and additional readings as directed by 

the permitting authority. If the opacity exceeds 20%, the 

facility must stop adding TDF until emissions stabilize 

and are in compliance.
Parameter Monitored: OPACITY

Upper Permit Limit: 20 percent

Monitoring Frequency: AS REQUIRED - SEE PERMIT 

MONITORING DESCRIPTION

Averaging Method: 6-MINUTE AVERAGE (METHOD 9)

Reporting Requirements: ONCE / BATCH OR 

MONITORING OCCURRENCE

Page 80

Condition 5-19: 

Compliance Certification

Effective between the dates of 09/20/2006 and 

06/19/2006

Applicable Federal Requirement: 6NYCRR 200.6

Item 5-19.1:

The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Regulated Contaminant(s):

CAS No: 007446-09-5 SULFUR DIOXIDE

Item 5-19.2:
Compliance Certification shall include the following 

monitoring:

Monitoring Type: CONTINUOUS EMISSION 

MONITORING (CEM)

Monitoring Description:

Whenever tire-derived fuel (TDF) is being burned in the 

power boiler, the SO2 emission rate must not exceed 309 

pounds per hour. This indicates that the power boiler 

scrubber is operating properly. If the SO2 emission rate 

exceeds 309 pounds per hour, the facility must stop 

adding TDF until SO2 emissions stabilize and are in 

compliance.

Manufacturer Name/Model Number: Thermo 

Environmental 43 CHL

Parameter Monitored: SULFUR DIOXIDE

Upper Permit Limit: 309 pounds per hour

Reference Test Method: PS-2

Page 81

Condition 5-20: Compliance Certification

Effective between the dates of 09/20/2006 and 

06/19/2006

Applicable Federal Requirement: 6NYCRR 200.6

Item 5-20.1:
The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Item 5-20.2:

Compliance Certification shall include the following 

monitoring:

Monitoring Type: RECORD KEEPING/MAINTENANCE 

PROCEDURES

Monitoring Description:

For a trial period, tire-derived fuel (TDF) may be 

combusted in the power boiler along with number 6 fuel oil 

and wood. During the trial, extensive stack testing will be 

performed under an approved stack test protocol. Testing 

will measure emissions of the

following:

Filterable and condensible particulate matter

Dioxins and Furans

Polycyclic Aromatic Hydrocarbons (PAHs)

Polychlorinated Biphenyls (PCBs)

Hydrogen Chloride

Heavy metals including Zinc, Lead, Mercury and others

Hexavalent Chrome

Carbon Monoxide

Total Hydrocarbons

At the conclusion of the trial period, the same 
contaminants will be measured while operating the boiler 

at comparable heat input, but without TDF, for comparison 

of emissions.

A stack test report will be submitted to the permitting 

authority

within 60 days of the completion of testing.

Monitoring Frequency: AS REQUIRED - SEE PERMIT 

MONITORING DESCRIPTION

Reporting Requirements: ONCE / BATCH OR 

MONITORING OCCURRENCE

Page 82

Item 5-21.1:

The Compliance Certification activity will be performed for:

Emission Unit: P-OWERH

Process: TDF

Item 5-21.2:

Compliance Certification shall include the following 

monitoring:

Monitoring Type: WORK PRACTICE INVOLVING 

SPECIFIC OPERATIONS
Monitoring Description:

Tire-derived fuel (TDF) may be burned in the power boiler 

for a trial period of up to 14 days over a period not to 

exceed 21 consecutive days. The TDF fuel rate shall not 

exceed 3 tons per hour and the total heat input to the 

boiler shall not exceed 748 MMBtu per hour. In addition, 

the only other fuels that may be burned while TDF is being 

burned are oil, wood and non-condensible gases.

Work Practice Type: PARAMETER OF PROCESS 

MATERIAL

Process Material: FUEL

Parameter Monitored: HEAT INPUT

Upper Permit Limit: 748 million Btu per hour

Monitoring Frequency: CONTINUOUS

Averaging Method: 1 HOUR MAXIMUM - NOT TO BE 

EXCEEDED AT ANY TIME

Reporting Requirements: SEMI-ANNUALLY (CALENDAR)

Reports due 30 days after the reporting period.

The initial report is due 10/30/2006.

Subsequent reports are due every 6 calendar month(s).

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