### Issuance Date: March 16, 2001 Effective Date: April 1, 2001 Expiration Date: March 16, 2006



## AIR OPERATING PERMIT 000012-4

In compliance with the provisions of The State of Washington

Clean Air Act Chapter 70.94 Revised Code of Washington

Weyerhaeuser Company

P.O. Box 188 Longview, Washington 98632

including

North Pacific Paper Corporation

P.O. Box 2069 Longview, Washington 98632

are authorized to operate in accordance with the terms and conditions of this permit.

Issued by:

State of Washington

DEPARTMENT OF ECOLOGY

300 Desmond Drive

P.O. Box 47600 Olympia, Washington 98504-7600

______________________________ ______________________________ Carol Kraege, P.E. Robert D. Carruthers, P.E. Industrial Section Supervisor Environmental Engineer

### 2 Table of Contents

INTRODUCTION AND LEGAL AUTHORITY ......................................................................... 3

EMISSION UNIT SPECIFIC REQUIREMENTS ........................................................................ 4

NORPAC A. ONP Baghouse................................................................................................................ .....4 NORPAC I, II .................................................................................................................. ....5

NORPAC III .................................................................................................................... .. 5

KRAFT MILL..................................................................................................................... ........... 6

B. Fiberline .................................................................................................................. .6 C. Volatile Organic Liquid Storage Vessels.................................................................7

D. East Powerhouse ......................................................................................................7

E. Power Boiler #11 .....................................................................................................7 F. Package Boiler (shutdown Feb 28, 2000)................................................................7 G. Power Boilers 6, 7, 9................................................................................................8 H. Recovery Furnace #10 .............................................................................................8 I. Smelt Dissolving Tank...........................................................................................10 J. NCG System ..........................................................................................................11

K. Lime Kiln...............................................................................................................13

L. Slaker Vent .......................................................................................................... 14

NSPS GENERAL RE QUIREMENTS...........................................................................................15

NESHAPS STANDARDS.............................................................................................................1 5

FACILITY-WIDE REQUIREMENTS..........................................................................................16

MONITORING, RECORDKEEP ING & REPORTING ............................................................ 19

STANDARD TERMS & CONDITIONS.................................................................................... 21

PERMIT SHIELD.................................................................................................................. ...... 23

Appendix A -- Permit Shield/Ina pplicable Requirements ........................................................... 23

Appendix B-- Definitions of Abbreviations Used in Permit ....................................................... 26

Appendix C -- Algorithms for Emission Calculations................................................................. 27

Appendix D -- Regulatory Orders ............................................................................................... 28

### 3 INTRODUCTION AND LEGAL AUTHORITY

This Air Operating Permit is authorized under the Operating Permit Regulation, Chapter 173- 401 WAC. The provisions of this permit describe the emissions limitations, operating requirements, monitoring and recording requirements, and reporting frequencies for the permitted source.

Weyerhaeuser Company requires a Title V Air Operating Permit because it emits or has the potential to emit, one hundred tons per year or more of one or more air pollutants (WAC 173- 401-300(1)). North Pacific Paper Corporation (NORPAC) is included in this permit because it is a 50/50 joint venture between Weyerhaeuser Company and Nippon Paper Corporation, is physically contiguous to the Weyerhaeuser Company facility, and is under common control of the Weyerhaeuser Company. The terms ìaffected f acilityî or ìpermitted facilityî as used in this Permit refer to Weyerhaeuser Company and include NORPAC.

During the drafting of this permit Ecology has attempted to incorporate requirements using the exact language of the law, regulation or order. In some cases, this has not been possible. Where there is a difference in language, this difference is presented in this permit only for clarification of the underlying requirement. The legal requirement remains the underlying applicable requirement cited in the ìApplicable Requirementsî column of the tables and the citations contained in brackets at the end of each requirement. Any conflict between the permit and an underlying requirement will be resolved by referring to the cited applicable requirement. Unless otherwise stated, the effective date of referenced re gulations or statutes is that of the provision in effect on the date of permit issuance.

The Title V Air Operating Permit consists of all parts of this assembled document including all Appendices, but does not include the accompanying Support Document

The definition of terms contained in WAC 173-401-200, and as defined in all referenced regulations, apply to this permit unless otherwise defined in the permit.

Any federal test method referenced, unless specifically stated otherwise within the body of the permit, is that which is contained in 40 CF R Part 60, Appendix A. Any state test method referenced, unless specifically stated otherwise within the body of the permit is that which is contained in the ìEcology Source Test Manualî as of July 12, 1990.

### 4 EMISSION UNIT SPECIFIC REQUIREMENTS [WAC 173-401-600]

The emission units identified in conditions A through I are subject to the emission unit specific requirements set forth in conditions A through I. These units are also subject to the facility-wide applicable requirements. The associated monitoring, record keeping and reporting requirements for these limits are in the Facility-Wide section of this permit. Unless specified otherwise, the basis of authority for the type and frequency of monitoring imposed in conditions A through I is WAC 173-401-615.

The reference test method (RM) or compliance determination algorithm is identified under the column titled, ìMonitoring and Reportingî. The identified reference test method or compliance determination algorithm is that compliance determination method which is intended to be the default or absolute determinant of compliance. It may or may not also be the method by which ongoing compliance is indicated.

Refer to Appendix C for emission estimate algorithms. These algorithms set forth the manner by which emissions are calculated for those requirements for which the Reference Method itself does not directly result in an emission estimate. Unless otherwise required by the applicable requirement, minor modifications to the test method may be used with the advanced approval of Ecology. Failure to obtain prior written approval for any test changes may invalidate the use of the test result(s) for Title V compliance purposes.

The Permitted facility includes emission units that are subject to EPA New Source Performance Standards at 40 CFR Part 60 Subpart A and Subpart BB. These standards are set forth as generic stand-alone conditions in the section of the permit titled ìNSPS General Requirements.î Emission units subject to NSPS requirements cr oss reference the specific applicable NSPS

standards.

North Pacific Paper Corporation (NORPAC)

A. NORPAC ONP Baghouse

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### A.1 Particulate 0.005 gr/dscf At least every 5 years using reference test method EPA Method 5 (front half) or Method

17. Conduct a minimum of three test runs.

Submit annual emissions estimate. See Support Document Order No. DE 98AQ-I046



### A.2 Operations Not applicable Mainta in log of baghouse O&M activities. Order No. DE 98AQ-I046

### 5 A. NORPAC I and II (Principal sources of emissions are Rotary Valve Vents (9), Startup Scrubber Vent, Deink Spray Condenser Exhaust, Bleach Tower Exhaust (2), TMP Decker Exhausts, Paper Machine No. 1 Vacuum Vents, Wet End Vents and Exhausts, and Dryer Vents, Paper Machine No. 2 Vacuum Vents, Wet End Vents and Exhausts, and Dryer Vents.

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements



### A.3 VOCs 9,636 lbs/day The reference test method and ongoing compliance indicator is the summation of daily production rates multiplied by appropriate daily emission factors contained

in Table 1 of PSD 97-01 PSD-97-01 Condition 2



### A.4 VOCs 862 tons per year. (Total of approved annual

rate of emissions

identified in applicable requirements) The reference test method and ongoing compliance indicator is the summation of monthly calculated emission rates. Monthly emissions are calculated by multiplying monthly TMP and Paper Machine production values by appropriate emission factors from

Table 1 of PSD-97-01. PSD-97-01 Condition 3 (830 tons), Order DE 95AQ-I076 (6tons), Order DE 96AQ-I093 (26 tons)



### A.5 CO 84 tons/year. (Total of approved annual

rate of emissions

identified in applicable requirements) The reference test method and ongoing compliance indicator is the summation of monthly calculated emission rates over the calendar year. Monthl y emissions calculated by multiplying mont hly TMP II production values by appropriate emission factors from

Table 2 of PSD-97-01. 81 tons allowed by PSD97-01 Condition 4 affecting only TMP lines 5,6,7,8,9 and Paper Machine #2. 3 tons resulting from Order DE 96AQ-I093 affecting

all TMP lines.



### A.6 The Permittee shall conduct source test of the NORPAC I and II units for VOC and CO, to be performed by an independent testi ng firm per Conditions 5 and 6 of PSD -97-01.

A.7 Per Condition 7 of PSD-97-01, the Permittee shall maintain records of emissions calculations, which will include production rates, the quantities of high brightness and normal brightness pulp produced during the month, the approximate percentages wood species types pulped during the month, the number of hours each month that pulp was produced while the Reboiler was down and the appropriate emission factors from Tables 1 and 2 of PSD-97-01. Weyerhaeuser shall report the monthly cumulative total VOC and CO emissions, in units of the standard, to Ecology in the ìmonthly air report.î

A.8 The Permittee shall report each occurrence of excess emissions in accordance with

Condition 8 of PSD-97-01.

A. NORPAC III

A.9 The Permittee shall maintain records of gross production (ADMT) from, and natural gas (cubic feet) consumed by, #3 Paper Machine Air Cap Dryer System and use as applicable in estimating air contaminant emission rates per Condition 4 of Order DE 97AQ-I041.

### 6 Weyerhaeuser Company

KRAFT MILL

B. Fiberline (MCC Digester, No. 6 Bleach Plant, No. 8 MEE, High Solids Crystalizer, Washing and Screening facilities, Condensate Stripper)

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### B.1 CO 349 lbs/hour and 300 tons per year (measured at bleach plant scrubber stack and oxygen delignification vent) The Reference Test Method and initial compliance determinant is EPA RM 10 at the bleach plant scrubber outlet and oxygen delignification vent. See Support

Document. PSD 92-03 amendment 4 Condition 1, Order DE 92AQ I069



### B.2 TRS 5.0 ppmdv @ 10% O2, 12 hour avg. Reference Test Method and compliance indicated by continuous collection and

combustion of collected sources. Monitoring is accomplished through

Condition J.4. 40 CFR 60.283(a)(1)

for limit.



### B.3 Reserved for future use.

B.4 The preceeding fiberline units are subject to the NSPS requirements identified in the stand-alone generic NSPS section of this permit.

The following state-only requirement is not federally enforceable under the federal Clean Air Act and is applicable to Digester, multiple-effects evaporators, condensate stripper system :

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements



### B.5 TRS Treat noncondensible gas (NCG) to reduce TRS emission equal to reduction achieved by thermal oxidation in a lime kiln; install a backup
treatment system Record number of hours system vents each month. Report periods of untreated venting. WAC 173-405- 040(4)

### 7 C. Volatile Organic Liquid Storage Vessels. (This condition is generic to the recent Industrial Section pulp and paper Title V permits. It is not currently applicable to Weyerhaeuser as the Permittee states no tanks are in use on site meeting the applicable criteria. It becomes applicable if triggered.)

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### C.1 Recordkeeping Not Applicable The Permittee sh all keep records showing the dimensions and capacities of all storage vessels having capacities greater than or equal to 40 cubic meters that are used to store volatile organic liquids and for which cons truction, reconstruction, or modification commenced after July 23, 1984.

These records are to be kept for the life of each storage vessel. 40 CFR 60.116b (a) and (b)



### D. East Powerhouse Boilers (Officially Shutdown in 1998)

E. Hogged Fuel Boiler #11

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### E.1 Particulate 0.05 gr/dscf @ 7%

O 2

. EPA RM 5 is the reference test method. Sample quarterly using EPA RM 5 [note 1: the particulate emission limit is only applicable to the front half catch.] Report test results in next monthly report. WAC 173-400-091 for particulate limit implemented through Order DE 94AQ-I080.



### E.2a Particulate 0.2 gr/dscf @ 7% O 2 . EPA RM 5 is the reference test method. Sample quarterly using EPA Method 5. Report test results in next monthly report. WAC 173-405-040(5)(a)



### E.2b Particulate 0.10 lb per MMBtu EPA RM 5 is the reference test method. Sample quarterly using EPA Method 5. Report test results in next monthly report. Keep records of type and quantity of fuels

used. 40 CFR 60.42(a)(1)



### E.3a Opacity Average 20% for

more than 6

consecutive minutes in any 60 minute period, except for

emissions due to soot blowing or grate cleaning for up to 15

minutes in 8

consecutive hours. EPA RM 9 is the reference test method



### . Monitor continuously using an approved COM. Report excursions monthly.

Maintain COM in accordance with 40 CFR Part 60.13(d). WAC 173-405-040(6) for opacity limit.



### E.3b Opacity ≤ 20% except for one 6-minute period per

hour of not more than

27%. Reference Test Method is EPA RM

Method 9. Monitor continuously using a

COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 1. Report excursions monthly. 40 CFR 60.42(a)(2)

### 8 E.4 SO 2 1000 ppm @ 7% O 2 , hourly average. Reference Test Method is EPA RM 6. Ongoing compliance indicated by maintaining fuel oil sulfur content less than or equal to 2%. Record of sulfur content of each shipment will be maintained. See Support Document. WAC 173-405-040(11)(b)



### E.5 SO 2 0.80 lb per MMBtu (derived from liquid fossil fuel or liquid

fossil fuel and wood residue) Reference Test Method is EPA RM 6. Monitor continuously using a COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 or by fuel sampling and analysis as allowed by 40 CFR 60.45(b)(2). Keep records of type and quantity of fuels used. Report excursions monthly. 40 CFR 60.43(a)(1)



### E.6 SO 2 1.2 lb per MMBtu (derived from solid

fossil fuel or solid

fossil fuel and wood residue) Reference Test Method is EPA RM 6. Monitor continuously using a COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 or by fuel sampling and analysis as allowed by 40 CFR 60.45(b)(2). Keep records of type and quantity of fuels used. Report excursions monthly. 40 CFR 60.43(a)(2)



### E.7 SO 2 (0.8y +1.2z)/ (y +z) lb per MMBtu. (derived from burning a mixture of liquid and solid fossil fuel) Reference Test Method is EPA RM 6. Monitor continuously using a COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 or by fuel sampling and analysis as allowed by 40 CFR 60.45(b)(2). Keep records of type and quantity of fuels used. Report excursions monthly. 40 CFR 60.43(b) which also defines the variables y

and z.



### E.8 NOx 0.30 lb per MMBtu (derived from liquid fossil fuel or liquid

fossil fuel and wood residue) Reference Test Method is EPA RM 7. Monitor continuously using a continuous monitoring system that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 if required per 40 CFR 60.45(b)(3). Keep records of type and quantity of fuels used. Report excursions monthly. 40 CFR 60.44(a)(2)



### E.9 NOx 0.70 lb per MMBtu (derived from solid

fossil fuel or solid

fossil fuel and wood residue) Reference Test Method is EPA RM 7. Monitor continuously using a continuous monitoring system that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 if required per 40 CFR 60.45(b)(3). Keep records of type and quantity of fuels used. Report excursions monthly. If a COM is not required test performance once per permit term using RM 7. 40 CFR 60.44(a)(3)

### 9 E.10 NOx (0.30x + 0.70y)/(x + y) lb per MMBtu (derived from solid fossil fuel, liquid

fossil fuel and wood residue) Reference Test Method is EPA RM 7. Monitor continuously using a continuous monitoring system that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2 if required per 40 CFR 60.45(b)(3). Keep records of type and quantity of fuels used. Report excursions monthly. 40 CFR 60.44(b) which also defines the variables y

and z.



### F. Package Boiler (shutdown on Feb 28, 2000)(150,000 pounds/hour steam capacity).

G. Power Boilers 6, 7, 9

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements



### G.1 Particulate 0.1 gr/dscf @ 7%

O 2 Reference Test Method is EPA RM 5. Maintain records of type of fuel usage. See Support Document. WAC 173-405-040(5)(c)



### G.2 Opacity 20% for more than

6 consecutive minutes in any 60 minute period except for soot blowing per WAC 173-405-040(6) Reference Test Method is EPA RM Method 9. Perform visual opacity assessment shortly after startup at least once per week when firing oil. Record visual assessment. Report exceedances monthly. WAC 173-405-040(6)



### G.3 SO 2 1000 ppm @ 7%

O 2 hourly average. Reference Test Method is EPA RM 6. Ongoing compliance indicated by maintaining fuel oil sulfur content less than or equal to 2%. Record of sulfur content of each shipment will be maintained. See Support Document. WAC 173-405-040(11)



### H. Recovery Furnace No. 10 (as measured in the main stack)

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### H.1 PM 0.027 gr/dscf @

8% O 2

. Sample quarterly using reference test method DOE Method 5. Report average of three 1-hr runs monthly. PSD92-03 amend 4 Condition 2; Order DE 92 AQ-I069 for particulate

limit.


### H.2 PM 0.044 gr/dscf @

8% O 2

. Sample quarterly using reference test method DOE Method 5. Report average of three 1-hr runs monthly. Case-by-case MACT determination, 40 CFR 63.55(b)(4), proposed

MACT standard 40 CFR 63.862(a) and proposed monitoring 40 CFR 63.864(a)(2) (63 Fed. Reg. 18753, 18784 (April 15, 1998).

### 10 H.3 PM 0.10 gr/dscf @ 8%

O 2

. Sample quarterly using reference test method DOE Method 5. Report average of three 1- hr runs monthly. WAC 173-405-040(1)(a) and for particulate limit.



### H.4 PM 0.020 gr/dscf @

8% O 2 annually. The reference method is the averaging of the quarterly RM (DOE Method 5) tests. PSD92-03 amend 4 Condition 2 for particulatelimit; Order DE 92 AQI069.


### H.5 PM 252 tons per year The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD92-03 amend 4 Condition 2 for particulatelimit; Order DE 92 AQI069.


### H.6 PM 10 0.027 gr/dscf @

8% O 2

. Sample quarterly using reference test method DOE Method 5. Report average of three 1- hr runs monthly. See Support Document. PSD92-03 amend 4 Condition 3; Order DE 92 AQ-I069.



### H.7 PM 10 0.020 gr/dscf @

8% O 2 annually. The reference method is the averaging of the quarterly RM (DOE Method 5) tests. PSD92-03 amend 4 Condition 3; Order DE 92 AQ-I069.


### H.8 PM 10 252 tons per year The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD92-03 amend 4 Condition 3; Order DE 92 AQ-I069.



### H.9 Opacity 20% Reference Test Method is EPA RM Method

9. Monitor continuously using a COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 1. Report exceedances monthly. PSD92-03 amend 4 Condition 4; Order DE 92 AQ-I069.



### H.10 Opacity 35% Reference Test Method is EPA RM Method 9. See Condition H9 for ongoing monitoring. WAC 173-405-040(6) for

the limit.



### H.11 SO 2 75 ppm @ 8% O 2 , 3-hour average (when not using supplemental oil or when using supplemental oil and BLS firing rate > 120,000 lbs/hr). The compliance reference test method and ongoing monitoring method is the continuous

use of a CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2. Report results monthly. PSD92-03 amend 4 Condition 5.1; Order DE 92 AQ I069



### H.12 SO 2 500 ppm @ 8%

O 2 , 3-hour average (when BLS firing rate < 120,000 lbs/hr and firing supplemental oil). The compliance reference test method and ongoing monitoring method is the continuous

use a CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2. Report results monthly. PSD92-03 amend 4 Condition 5.2; Order DE 92 AQ I069



### H.13 SO 2 1000ppm @ 10%

O 2 , hourly avg (when firing oil) Reference Test Method is EPA RM 6. Ongoing compliance indicated by maintaining fuel oil sulfur content less than or equal to 2%. Record of sulfur content of each shipment will be maintained. See Support Document. WAC 173-405-040(11)(b)

### 11 H.14 SO 2 586 tpy + 0.036 tpy for each hr operation of the

NCG incinerator.

The combined

total not to exceed 884 tpy. The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD92-03 amend 4

Condition 5. Order DE 92 AQ I069



### H.15 TRS 5.0 ppmdv@8.0%

O 2 12-hr average Reference Test Method is EPA RM 16 or 16A. Ongoing compliance indicated by

continuous use of a CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 5. Report results monthly. PSD92-03 amend 4 Condition 6; Order DE 92 AQ I069, WAC 173-405- 040(1)(c), and for limit



### H.16 TRS 31 tpy The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD92-03 amendment 4 Condition 6; Order DE 92 AQ I069.



### H.17 NOx 140 ppmdv @

8.0% O 2 , 24 hr

average. Reference Test Method is EPA RM 7, 7A,7B, or 7E. Ongoing compliance indicated by continuous use of a CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. F and App. B, Perf. Spec. 2. Report results monthly. PSD92-03 amendment 4 Condition 7,Order DE 92 AQ I069.



### H.18 NOx 1,179 tpy annual

average The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD92-03 amend 4 Condition 7; Order DE 92 AQ I069.



### H.19 CO 1,000 ppmdv 1-hr

average Reference Test Method is EPA RM 10. Initial source testing; no on-going monitoring required by this permit . See Support Document for unit emissions history. PSD92-03 amend 4 Condition 8; Order DE 92 AQ-I069.



### H.20 CO 2,564 tpy The reference test method is set forth in Appendix C. Initial source testing; no ongoing monitoring required by this permit . See Support Document for unit emissions history. PSD92-03 amend 4 Condition 8; Order DE 92 AQ-I069.



### H.21 VOC 50 ppmdv 1-hr

average Reference Test Method is EPA RM 25, 25A,

or 25B. Initial source testing; no on-going monitoring required by this permit See Support Document for unit emissions history. PSD92-03 amend 4 Condition 9; Order DE 92 AQ-I069.



### H.22 VOC 201 tpy Reference Test Method is EPA RM 25, 25A,

or 25B. Initial source testing; no on-going monitoring required by this permit . See Support Document for unit emissions history. PSD92-03 amend 4 Condition 9; Order DE 92 AQ-I069.



### H.23 Temp. at
of

entrance
to No. 10

recovery boiler ESP ≤ 500 degrees F, hourly average Monitored continuously using thermocouple at ESP entrance. Report only exceedances of hourly average in monthly report. PSD -92-03 amend 4 Condition 10; Order 92AQ-I069

### 12 I. Smelt Dissolver Tank Vent

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements



### I.1 PM 0.20 lb/TBLS Sample quarterly using EPA Reference

Method 5 as the reference test method. Report test results in next monthly report. Case-by-case MACT determination, 40 CFR 63.55(b)(4), proposed

MACT standard 40 CFR 63.862(a) and proposed monitoring 40 CFR 63.864(a)(2) (63 Fed. Reg. 18753, 18784 (April 15, 1998).



### I.2 Reserved



### I.3 PM 0.30 lb/TBLS Sample quarterly using EPA Reference

Method 5 as the reference test method. Report test results in next monthly report. WAC 173-405-040(2)



### I.4 PM 10 0.120 lb/TBLS Sample quarterly using EPA Reference

Method 5 as the reference test method. Report test results in next monthly report. PSD92-03 amend 4
Condition 14; 

### Order DE 92 AQ-I069 for PM 10 limit.



### I.5 PM 10 62.0 tons per year The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD 92-03 amend 4 Condition 14; Order DE 92 AQ-I069.



### I.6 Opacity 20 % for more

than 6 consecutive minutes in any 60 minute period. EPA Reference Method 9 is the reference test

method. PSD 92-03 amend 4 Condition 15; Order DE 92 AQ-I069 for opacity limit.



### I.7 Opacity Average 35% for

more than 6

consecutive minutes in any 60 minute period. EPA Reference Method 9 is the reference test

method. WAC 173-405-040(6)



### I.8 TRS 0.0168 lb/TBLS Sample quarterly using EPA RM 16 or 16A. Report average of three 1-hr runs in monthly report. After limit exceedance, sample monthly until limit met for three consecutive months then resume quarterly tests. PSD 92-03 amend 4 Condition 16; Order DE 92AQ-I069.



### I.9 Black Liquor

Feed Rate Not applicable Record Black Liquor (TBLS) feed rate. PSD 92-03 amend 4 Condition 16; Order DE 92AQ-I069.



### I.10 TRS 9.0 tpy The reference test method is set forth in Appendix C. Report annual emissions in January air report of following year. PSD 92-03 amend 4 Condition 16; Order DE 92AQ-I069.

### 13 J. Noncondensible Gas (NCG) Collection & Treatment

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements J.1 Opacity 20%, 6 minute avg in any sixty minute period. None because exhaust is vented to RF stack. WAC 173-405-040(6)

J.2 TRS ñ High

Conc.

NCG (Digester;
evaporator s; foul

condensate stripping) Treat by

incineration or its equivalent. Continuously monitor and record high concentration NCG venting from high concentration NCG header vent to recovery boiler stack (i.e., not being treated in incinerator or kiln). Report times, duration and causes of venting in monthly air report. PSD 92-03 amend 4 Condition 11, WDOE 92AQ I069

J.3 TRS ñ

Low Conc.

NCG (Chip bin;

blow tanks;

brownstoc k press,

filtrate tanks,; O2 delig.;

black liquor tanks D-J) Treat by

incineration or its equivalent. Continuously monitor and record low concentration NCG venting from chip bin, fiberline roof vent, 24î standpipe, and conbined LC-NCG vent to recovery boiler stack (i.e., not being treat ed in incinerator). Report times, duration and causes of venting in monthly air report. PSD 92-03 amend 4 Condition 11, WDOE 92AQ I069

J.4 TRSñ NCG (All sources

listed in J.2 and J.3) Incinerator performance: 5.0 ppmdv @ 10%

O 2 , 12 hour avg. Reference Test Method is EPA Method 16 or 16A. Compliance indicated by maintaining 12 hour average combustion temperature at the point of incineration ≥ 1350 F. PSD 92-03 amend 4 Condition 12; Order DE 92 AQ I069

J.5 TRSñNCG,

NSPS Units (Digester, flash tanks, blow tanks,

brownstock washing, MEE #8, HSC, Foul

Condensate Stripper) Incinerator /Kiln performance while combusting NCG

from NSPS units:

a. Incinerator

Combustion temp >1200F

for at least 0.5

second

b. Lime Kiln

TRS ≤ 8 ppmdv @ 10% O 2 , 12 hour average (see Section K) a. Continuously monitor combustion temperature. Excess emissions defined as ìall periods in excess of 5 minutes and their duration during which the combustion temperature at the point of incineration is less than 1200Fî. Report time, cause and duration of excess emission periods monthly.

b. Lime Kiln: See Condition K.7 for monitoring requirement. 40 CFR 60.283(a)(1) 

### ( iii)

for limit at incinerator. 40 CFR 60.284(b)(1) for temperature monitoring

Lime Kiln requirements

cited in Condition K.

J.6 Reserved

### 14 J.7 SO 2 300 ppm @ 7%

O 2 hourly avg.

. Reference Test Method is EPA Method 6. Compliance indicated by maintaining hourly average scrubber pH above 6.5. Record pH continuously. Report exceedances monthly. PSD 92-03 amend 4 Condition 13; Order DE 92 AQ I069

J.8 SO 2 1000ppm @ 7%

O 2 , hourly avg. Reference Test Method is EPA Method 6. Compliance indicated by maintaining hourly average scrubber pH above 6.0. Record pH continuously. Report exceedances monthly. WAC 173-405-040(11)(b)

J.9 

### Reserved for future use.

J.10 Reserved for future use.

J.11 The NCG collection and treatment system is subject to the NSPS requirements identified in the stand-alone generic NSPS section of this permit.

K. Lime Kiln

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### K.1

.a PM 0.035 gr/dscf @

10% O 2 (gas fired) 0.07 gr/dscf @

10% O 2 oil fired. Sample quarterly using reference test method EPA Method 5. Report average of three 1-

hour tests. Order DE 95AQ-I035 for particulate limit.



### K.1

.b PM 0.067 gr/dscf @

10% O 2 Same as above. Case-by-case MACT determination, 40 CFR 63.55(b)(4), proposed

MACT standard 40 CFR 63.862(a) and proposed monitoring 40 CFR 63.864(a)(2) (63 Fed. Reg. 18753, 18784 (April 15, 1998).


### K.2 PM 0.067 gr/dscf @

10% O 2 (gas)

. 0.13 gr/dscf @

10% O 2 (liquid fossil fuel) Sample quarterly using reference method EPA Method 5. Report average of three 1-hour

tests. WAC-173-405-040(3)(a), 40 CFR 60.282(a)(3)



### K.3 Reserved for future use.



### K.4 Reserved for future use.



### K.5 Opacity Average 25% for

more than 6

consecutive minutes in any 60 minute period. EPA Test Method 9 is reference test method. Monitor continuously using a COM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. B, Perf. Spec. 1. Report exceedances monthly. Order DE 95AQ-I035



### K.6 Opacity Average 35% for

more than 6

consecutive minutes in any 60 minute period. EPA Test Method 9 is reference test method. See Condition K5 for ongoing monitoring. WAC 173-405-040(6)

### 15 K.7 TRS 8.0 ppmdv @ 10%

O 2 , 12 hour avg. EPA Test Method 16 or 16A is reference test method. Monitor continuously using a CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. B, Perf. Spec. 5. Report results monthly. DE 95AQ-I035 and 40 CFR 60.283(a)(5) for limit. 40 CFR 60.284(a)(2) for

CEM. 40 CFR 60.284(c)(1),(3) for monitoring. 40 CFR 60.284(d)(2) for reporting except that

excess emissions reported monthly.


### K.8 O2 Not Applicable Record 12 hour average on daily basis. 40 CFR 60.284(c)(2) for monitoring


### K.9

a SO 2 500ppm @ 10%

O 2 , hourly avg. Sample at Ecologyís request using reference test method EPA RM 6 or 6A. Report results monthly. See Condition K.9b for minimum O&M requirements intended to indicate compliance. WAC 173-405-040(11)(a)



### K.9

b No usage of pulp mill evaporator condensates to wash lime mud. Minimize introduction of sulfur compounds in washing of lime mud. See Support Document for emission history.



### K.10 The Lime Kiln is subject to the NSPS requirements identified in the stand-alone generic NSPS section of this permit.

K.11 Reserved for future use.

K.12 The following state-only requirement is not federally enforceable under the federal

Clean Air Act:

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements K.12a TRS 80 ppm as H2S for

no more than 3

consecutive hours in any one day Monitor continuously using an approved CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. B, Perf. Spec. 5. Report test results monthly. WAC 173-405-040(3)(b)

K.12b TRS 20 ppm @ 10% O 2 on daily avg. Monitor continuously using an approved CEM that conforms to 40 CFR Pt. 60 (July 1, 1992), App. B, Perf. Spec. 5. Report test results monthly. WAC 173-405-040(3)(c)



### L. Slaker Vent Scrubber Stack

Parameter Limit (shall not exceed) Monitoring & Reporting Applicable Requirements


### L.1 Particulate 0.07 gr/dscf EPA Test Method 5 is the reference test

method. See Condition L.3 for minimum monitoring and reporting requirements intended to indicate compliance with the particulate limit. WAC 173-400-110 and Order DE 95 AQ I035.for the particulate limit.

### 16 L.2 Opacity Average 25% for

more than 6

consecutive minutes in any 60 minute period. DOE Test Method 9B is the reference test

method. See Condition L.3 for minimum monitoring and reporting requirements intended to indicate compliance with the particulate limit. WAC 173-400-110 and Order DE 95AQ-I035 for the opacity limit.



### L.3 Maintain water flow ≥ 50 gpm on a daily average. Maintain scrubber nozzle pressure ≥ 23 psi. Monitor scrubber water flow continuously. Monitor and record pressure monthly. Whenever daily average water flow is less than 50 gpm, the permittee shall immediately, but no later than 24 hours, take corrective action to bring the parameter within prescribed range. Whenever monitored pressure value is less than 23 psi, the permittee shall as soon as practical, but no later than 30 days, take corrective action to bring the parameter within prescribed range. Failure to take correctiv e action is a violation of WAC 173-405-040(10) and may be a violation of the underlying appli cable requirement. Report exceedances and corrective action taken in monthly report.



### NSPS GENERAL REQUIREMENTS

Affected Units under NSPS NSPS Genera l Requirement Applicable Requirement

B (MCC Digester, No. 8 MEE, High solids crustalizer, washing and screening facilities, condensate stripper),

E (PB #11), J (NCG Collection/Treatment System),

and K (Lime Kiln) Operate affected units consistent with good air pollution control practices for minimizing emissions. 40 CFR 60.11(d)

B (MCC Digester, No. 8 MEE, High solids crustalizer, washing and screening facilities, condensate stripper),

E (PB #11), J (NCG Collection/Treatment System),

and K (Lime Kiln) Concealing an emission that

would be a violation is prohibited. 40 CFR 60.12

E (PB #11), J (NCG Collection/Treatment System),

and K (Lime Kiln) Operate and maintain CEMs as required. 40 CFR 60.13

B (MCC Digester, No. 8 MEE, High solids crustalizer, washing and screening facilities, condensate stripper),

E (PB #11), J (NCG

Collection/ Treatment System ), and K (Lime Kiln) Notification, Recordkeeping,

and Credible Evidence. 40 CFR 60.4(a), 40 CFR 60.4(b), 40 CFR 60.11(c) and (g).

National Emission Standards for Hazardous Air Pollutants, 40 CFR Part 63 Subpart A and S

### 17 The Permitted source includes emission units that are subject to EPA National Emission Standards for Hazardous Air Pollutants, 40 CFR Part 63 Subpart A and S.

1. The Permittee shall timely submit initial notification reports concerning MACT applicablity. 40 CFR 63.9(b)(2); 40 CFR 63.455(a).

2. The Permittee shall timely submit and update a non-binding control strategy report for a kraft pulping system specified in 40 CFR 63.440( d)(1) or a bleaching system specified in 40 CFR 63. 440(d)(3)(iii). 40 CFR 63.455(b).

3. The Permittee shall timely comply with the applicable provisions contained in 40 CFR Part 63 Subparts A and S at such time as compliance is required.

FACILITY-WIDE GENERAL REQUIREMENTS [WAC 173-401-600]

These generally applicable requirements apply facility-wide, including insignificant emission units or activities. Insignificant emission units or activities, however, are not subject to monitoring, testing, recordkeeping, reporting, or compliance certification requirements.

1. The permittee cannot vary the rate of emission of a pollutant according to atmospheric conditions or ambient concentrations of that pollutant, except as directed according to air pollution episode regulations. [WAC 173-400-205]

2. The permittee shall not cause or permit emission of any contaminant if it is detrimental to the health, safety, or welfare of any person, or causes damage to property or business. [WAC 173-400-040(5)]

3. The permittee shall not install or use any means that conceal or mask an emission of an air contaminant that would otherwise violate provisions in this permit. [WAC 173-400- 040(7);]

4. The permittee shall take reasonable precautions to prevent the release of air contaminants from emission units engaged in material handling, construction, demolition, or any other operation that is a source of fugitive emissions. Reasonable precautions include but are not limited to application of water to paved areas and debris piles as necessary to control fugitive dust or the timely removal or coverage of material piles. [WAC 173-400- 040(3)(a)]

5. The permittee shall take reasonable precautions to prevent fugitive dust from becoming airborne and maintain and operate the source to minimize emissions. Reasonable precautions include but are not limited to application of water to paved areas and debris

### 18 piles as necessary to control fugitive dust or the timely removal or coverage of material piles.[WAC 173-400-040(8)(a)]

6. The following condition is state-only and is not federally enforceable under the Clean Air Act: No deposit of particulate matter beyond property line so as to interfere unreasonably with use and enjoyment. [WAC 173-400-040(2)]

7. The following condition is state-only and is not federally enforceable under the Clean Air Act: Any person causing odor which may unreasonably interfere with use & enjoyment of property must use recognized good practice and procedures to reduce odors to a reasonable minimum. [WAC 173-400-040(4)]

8. The permittee may not cause or allow the emission of a plume from any emission unit other than a kraft recovery furnace, smelt dissolver tank, or lime kiln, which has an average opacity greater than 20% for more than 6 consecutive minutes in any 60 minute period except as provided in WA C 173-405-040(6). [WAC 173-405-040(6)]

9. Except where specific requirements are defined elsewhere, the Permittee shall assure compliance with conditions 1 through 8 by recordkeeping of actions taken by the permittee in response to complaints received by the permittee or of possible noncompliance noticed by the facility staff in day to day operations. The permittee shall assess the validity of each complaint and commence corrective action, if warranted, as soon as possible but no later than 3 working days of receiving the complaint. The permittee shall keep records of the following: complaints received; the assessment of validity; and what, if any, corrective action is taken in response to the complaint.

10. The emission of sulfur dioxide from any emissions unit other than a recovery furnace or lime kiln shall not exceed 1,000 parts per million for an hourly average, corrected to 7% oxygen for combustion units. [WAC 173-405-040(11)]

11. Where this permit specifically requires continuous monitoring, the source shall, consistent with the requirements of Ecologyís Source Test Manual, calibrate, maintain and operate equipment for continuously monitoring and recording the emissions specified. The source may be temporarily exempted from monitoring and reporting requirements during periods of monitoring syst em malfunctions, provided that the source shows to Ecology's satisfaction that the malfunction was unavoidable and is being repaired as expeditiously as practicable. [WAC 173-400-105(5)(h)].

Ecology recognizes that monitoring data may be lost for legitimate reasons. The permittee shall make every reasonable effort to acquire, maintain, and recover valid monitoring data. Except where an applicable requirement contains more stringent provisions, permittee shall recover valid monitoring data and recordkeeping for at least 90% of the averaging periods during each month or, if no averaging period is used, collected during each month, in which this permit requires monitoring of a process or parameter. The 10% allowance is contingent on the permittee providing an acceptable explanation for the loss of monitoring data. [WAC 173-401-615]

### 19 12. The Permittee shall at all times, including periods of abnormal operation and upset conditions, to the extent practicable, maintain and operate any affected facility, including associated air pollution control equipment, in a manner consistent with good air pollution control practice. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to Ecology which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [WAC 173-405- 040(10);]

13. Chemical Accidental Release Program ñ This stationary source, as defined in 40 CFR section 68.3, is subject to part 68, the accidental release prevention regulations. This stationary source shall submit a risk management plan (RMP) by the date specified in section 68.10. [40 CFR Part 68]

14. Ozone Protection - The Permittee shall comply with the applicable standards for recycling and emissions reductions pursuant to 40 CFR Part 82, Subpart F. a. Persons opening appliances for maintenance, service, repair or disposal must comply with the required practices pursuant to ß 82.156. b. Equipment used during the maintenance, service, repair or disposal must comply with the standards for recycling and recovery equipment pursuant to ß 82.158. c. Persons performing maintenance, service, repair or disposal of appliances must be certified by an approved technician certification program pursuant to ß 82.161. d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with recordkeeping requirements pursuant to ß 82.166. ("MVAC-like appliance" is defined at ß 82.152.) e. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to ß82.156. f. Owners/operators of appliances normally containing 50 or more pounds or refrigerant purchased and added to such appliances must do so in compliance with ß82.166.

15. Reserved for future use.

16 The generally applicable requirements that apply to IEUs are WAC 173-405-040(5), WAC 173-400-050(1)&(3), and WAC 173- 400-060. [WAC 173-401-530(2)(b)]

17. The Permittee will continue to comply with applicable requirements with which the Permittee is in compliance. WAC 173-401-630(3) and 510(2)(h)(iii)(A)

The Permittee will meet applicable requirements that become effective during the permit term on a timely basis. WAC 173-401-630(3) and 510(2)(h)(iii)(B)

18. Volatile Organic Liquid Storage Vessels - The Permittee shall keep records showing the dimensions and capacities of all storage vessels having capacities greater than or equal to 40 cubic meters that are used to store volatile organic liquids and for which construction,

### 20 reconstruction, or modification commenced after July 23, 1984. These records are to be kept for the life of each storage vessel. [40 CFR 60.116b (a) and (b)]

19. Reserved for future use.

20. The following condition is state-only and is not federally enforceable under the Clean Air Act. The permittee cannot burn used oil not meeting standards prescribed in RCW 70.94.610(1). [RCW 70.94.610]

21. The permittee must comply with 40 CFR sections 61.145 and 61.150 and WAC 173-400- 075 if asbestos-containing material is present above specified quantities in a facility being demolished or renovated. [40 CFR Part 61, Subpart M]

MONITORING, RECORDKEEPING & REPORTING

Monitoring Requirements [WAC 173-401-630(5)(b).]

22. Unit-Specific Requirements. The permittee shall conduct routine monitoring of emissions in accordance with the program of monitoring or testing required for specific emission units in conditions A through L of this permit. [WAC 173-405-072].

23. Unavoidable Excess Emissions. This condition applies, where applicable, to excess emissions that are claimed to be unavoidable pursuant to WAC 173-400-107. The permittee may include in its reports demonstrations that excess emissions were unavoidable, consistent with the requirements of WAC 173-400-107. The permittee shall have the burden to prove that deviations from permit terms were unavoidable. Excess emissions that are unavoidable are excused and are not subject to penalty. [WAC 173- 400-107]

24. Reserved for Future Use

25. Reserved for Future Use

Recordkeeping Requirements

26. The permittee shall keep records of any periodic and continuous monitoring required by this permit. These records shall include the following, where applicable:

a. The date, place as defined in requirement, and time of sampling or

measurement; b. The date(s) analysis were performed; c. The company or entity that performed the analysis; d. The analytical techniques or methods used; e. The results of such analysis;

### 21 f. The operating conditions existing at the time of sampling or measurement. [WAC 173-401-615(2)(a); WAC 173-400-105]

27. The permittee shall keep records describing changes made at the source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from those changes. [WAC 173-401-724(5).]

28. The permittee shall retain records of all required monitoring data and support information for a period of 5 years from the date of monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. [WAC 173-401-615(2)(c)]

29. The permittee shall maintain a contemporaneous record of any deviation from the requirements of this permit. [WAC 173-401-615(3)(b).]

Reporting Requirements [WAC 173-401-520, -615(3), & -710]

30. In addition to any emission unit specific reporting requirements identified below, emission unit specific reporting requirements are identified in conditions A through I.

31. Report within 15 days of the end of each month average daily production of air-dried unbleached pulp. [WAC 173-405-072(4)]

32. Monitoring reports required by this permit must be submitted to Ecology within 15 days of the end of each calendar month. [WAC 173-405-072]. The reports must clearly identify all instances of deviations from permit requirements. [WAC 173-401-615(3)(a)]

33. Submit an inventory of emissions from the source each year no later than 105 days after the end of the calendar year; maintain records of information necessary to substantiate any reported emissions. [WAC 173-400-105(1)]

34. The permittee shall promptly submit a report of any deviations from permit conditions. [WAC 173-401-615(3)(b).]

a. For purposes of this permit, submitting a report "promptly" means the following: (a) if the deviation presents a potential threat to human health or safety, the report shall be made as soon as possible but no later than 12 hours after the discovery of the deviation; (b) for other deviations, "promptly" means that the deviations are identified in the respective monthly report.

b. Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken. [WAC 173-401-615(3)]]. The permittee may include in its reports demonstrations that excess emissions were unavoidable, consistent with the requirements of WAC 173-400-107.

### 22 35. Certification of truth, accuracy and completeness. Any application form, report or compliance certification required to be submitted by this permit or by Chapter 401 WAC shall contain certification by a responsible official of truth, accuracy and completeness. Where the permit requires reporting more frequently than once every 3 months the responsible officialís certification need only be submitted once every 3 months covering all required reporting since the date of the last certification. 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. [WAC 173-401-520.]

36. All reports and renewal applications required by this permit shall be submitted to:

Department of Ecology

Industrial Section

P.O. Box 47706 Olympia, WA 98504-7706

37. Compliance Certification. The permittee shall submit a report to the Department of Ecology and to EPA Region 10 12 months after the effective date of this permit and every year thereafter, within 45 days after the close of the year that the certification covers, certifying compliance with the terms and conditions contained in this permit. The term ìyearî means a consecutive 365 day period and does not refer to a calendar year. The certification shall describe the following:

a. the permit term or condition that is the basis of the certification; b. the compliance status; c. whether compliance was continuous or intermittent; and d. the methods used for determining compliance. [WAC 173-401-630(5)]

The permittee is not required to certify compliance for insignificant emission units or activities. [WAC 173-401-530(2)(d)]

STANDARD TERMS & CONDITIONS

38. Duty to Comply. The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of chapter 70.94 RCW and, for federally enforceable provisions, a violation of the FCAA. Such violations are grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. [WAC 173-401-620(2)(a).]

39. Need to Halt or Reduce Activity Not a Defense. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the

### 23 permitted activity in order to maintain complia nce with the conditions of this permit. [WAC 173-401-620(2)(b).]

40. Permit Actions. This permit may be modified, revoked, reopened, and reissued or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. [WAC 173-401- 620(2)(c).]

41. Property Rights. This permit does not conve y any property rights of any sort, or any exclusive privilege. [WAC 173-401-620(2)(d).]

42. Duty to Provide Information. The permittee shall furnish to the permitting authority, within a reasonable time, any information that the permitting authority may request in writing 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 permitting authority copies of records required to be kept by the permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA administrator along with a claim of confidentiality. Permitting authorities shall maintain confidentiality of such information in accordance with RCW 70.94.205. [WAC 173-401-620(2)(e).]

43. Permit Fees. The permittee shall pay fees as a condition of this permit in accordance with the permitting authority's fee schedule. Failure to pay fees in a timely fashion shall subject the permittee to civil and criminal penalties as prescribed in chapter 70.94 RCW. [WAC 173-401-620(2)(f).]

44. Emissions Trading. No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for in this permit. [WAC 173-401-620(2)(g).]

45. Severability. If any provision of this permit is held to be invalid, all unaffected provisions of the permit shall remain in effect and be enforceable. [WAC 173-401- 620(2)(h).]

46. Permit Appeals. This permit or any conditions in it may be appealed only by filing an appeal with the pollution control hearings board and serving it on the permitting authority within thirty days of receipt pursuant to RCW 43.21B.310. This provision for appeal in this section is separate from and additional to any federal rights to petition and review under ß 505(b) of the FCAA. [WAC 173-401-620(2)(i).]

47. Permit Continuation. This permit is issued for a 5 year term; however, this permit and all terms and conditions contained therein, including any permit shield provided under WAC 173-401-640, shall not expire until the renewal permit has been issued or denied if a timely and complete application has been submitted. An application shield granted pursuant to WAC 173-401-705(2) shall remain in effect until the renewal permit has been

### 24 issued or denied if a timely and complete application has been submitted. [WAC 173- 401-620(2)(j).]

48. Inspection and Entry. Upon consent of the permittee or upon presentation of credentials and other documents as may be required by law, the Department of Ecology or an authorized representative shall be allowed to: (1) Enter the source; (2) Have access to and copy at reasonable times any records that must be kept under this permit; (3) Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and (4) As authorized by WAC 173-400-105 and the FCAA, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the permit or other applicable requirements. [WAC 173-400-105(4); WAC 173-401-630(2).]

PERMIT SHIELD

Compliance with the conditions in this permit is deemed to constitute compliance with applicable requirements as contained in this permit on which the term or condition is based, as of the date the permit is issued. [WAC 173-401-640(1).]

The Department of Ecology has determined that the requirements listed in Appendix A to this permit do not apply to the facility, as of the date the permit is issued, for the reasons specified. [WAC 173-401-640(2)].

Appendix A. Permit Shield/Inapplicable Requirements

The following requirements do not apply to the facility as of the date of permit issuance for the

reasons indicated:

CITE BRIEF DESCRIPTION REASON

40 CFR Part 60 Subpart Da,

Standards of Performance for Electric Utility Steam Generators (construction or

modification commenced after 9/18/78) applies to the following types of generating

units for which construction or modification commenced after September 18, 1978: generating greater than 250 MMBtu/Hr Facility does not have this emission unit.

40 CFR Part 60 Subpart Db, Standards of

Performance for IndustrialCommercial-Institutional Steam Generating Units (construction or

modification commenced after 7/19/84) applies to the following types of generating

units for which construction or modification commenced after July 19, 1984: generating greater than 29MW (100MMBtu/Hr) Facility does not have this emission unit.

### 25 40 CFR Part 60 Subpart Dc,

Standards of Performance

for Small IndustrialCommercial-Institutional Steam Generating Units applies to the following types of generating

units for which construction or modification commenced after June 9, 1989: generating greater than 10 MMBtu/Hr and less than 100

MMBtu/hr Facility does not have this emission unit.

40 CFR ß60.110a Subpart Kb, Standards of Performance for Storage Vessels for Petroleum Liquids with a capacity greater than 40,000 gallons and for which construction is commenced after May 18, 1978. Fuel oil tanks at the site have not been modified since the applicability date. All

other tanks are either below the size applicability criteria or do not contain volatile organic liquids. 40 CFR 63, Subpart Q as amended through 9/8/94 No chromium based water treatment chemicals may be used in industrial process cooling towers The facility does not use chromium based

water treatment chemicals

SWAPCA Order of Approval 78-302 as amended through 1/16/78 approval to operate Pacific Lamination We yerhaeuser does not own or operate this

source

SWAPCA Order of Approval 78-3015 as amended through 2/2/78 approval to operate Pacific Lamination We yerhaeuser does not own or operate this

source

WAC 173-400-040(3)(b) emissions unit identified as a significant

contributor to nonattainment must use

reasonable and available control methods to

control emissions of contaminants for which area is designated nonattainment The facility is not in a special

control/nonattainment area

WAC 173-400-040(8)(b) Sources of fugitive dust identified as significant contributors to a PM-10

nonattainment area must use RACT to control fugitive dust emissions. The facility is not in a special

control/nonattainment area

WAC 173-400-070 as amended through 2/19/91 emission standards for certain source categories The facility is not in this source category and hogged fuel boilers regulated under 173-405

WAC

WAC 173-400-100 Registration Registration required for listed sources, excluding sources subject to the operating permit program, after EPA grants interim or final approval to the state program. Facility is subject to the operating permit program; EPA has granted interim approval for the state program.

WAC 173-400-105(6) Applies to sour ces that are not subject to operating permit program. Facility is subject to the operating permit

program.
WAC 173-400-151 Retrofit requirements for visibility protection BART required for sources to which significant visibility impairment of a Class 1 area is reasonably attributable. Facility has not been identified as a source impacting a Class I area.

WAC 173-405-040(1)(b) as amended through 2/1/95 [STATE ONLY, NOT

FEDERALLY ENFORCEABLE] 17.5 ppm daily average TRS limit for recovery furnaces constructed before 1/1/70 and recovery furnaces with direct contact
evaporators RF #10 built after 1/1/70 without direct
contact evaporator

Chapter 173-410 WAC; Sulfite Pulping Mills facility is not a sulfite pulping mill

Chapter 173-433 WAC as amended through 2/3/93; Solid Fuel Burning Devices Applies to wood stoves and fireplaces. facility does not operate such devices

WAC 173-435-050(2) no open fires during an air pollution epis ode Facility does not conduct open burning.

Chapters 173-470, 474, 475, 480, 481 WAC Ambient Air Quality Standards AAQS apply to airsheds, not individual

sources

### 26 Chapter 173-490 WAC Emission Standards and Controls for Sources

of VOCs The facility is not in a special

control/nonattainment area



### APPENDIX B

Definitions of Abbreviations Used in Permit

AAQS ambient air quality standard ADMT air dry metric ton

avg average BACT Best available control technology BART Best available reasonable technology BDMT bone dry metric ton BL black liquor BLS black liquor solids

BTU British thermal unit

CEM continuous emission monitor

CO carbon monoxide DOE Department of Ecology dscf dry standard cubic foot EPA Environemtnal Protection Agency ESP electrostatic precipitator

FCAA Federal Clean Air Act gpm gallons per minute gr grain HAP hazardous air pollutant IEU insignificant emission unit kg kilogram lbs pounds

LM lime mud MACT maximum available control technology

MMBTU million British thermal units NOx oxides of nitrogen NCG noncondensible gas NSPS new source performance standards PM particulate matter PM-10 particulate matter less than 10 microns in diameter ppm parts per million ppmdv part per million dry volume RF, RB recovery furnace, recovery boiler RACT Reasonable available control technology

RM Reference method SERP source emission reduction plan SIP state implementation plan SO2 sulphur dioxide
tpy tons per year

### 27 TRS total reduced sulphur TSP total suspended particulate

U.S.C. United States Code VOC volatile organic compound WAC Washington Administrative Code

### 28 Appendix C Algorithms for Emissions Calculation The Permittee may use an equivalent alternative method with written approval by Ecology

Permit Conditions E.2b, E.5, E.6, E.7, E.8, E.9, E.10 Particulate Matter, SO2, NOx (mass per fuel heat input)

= (Concentration * Air Flow Rate * Unit Conversion Factor )/ Heat Input

Concentration, EPA RM 5 or DOE RM 5. RM6, or RM7 as specified in the respective condition, gives results in terms of gr/dscf or lbs/ft3. Air Flow is calculated per specified RM 5. Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. Heat Input is calculated by multiplying the measured steam ing rate by the rated efficiency of the boiler. The boiler manufacturerís rated efficiency is 64.23%. If future performance tests demonstrate a different efficiency, that may be used to calculate heat input after consultation with the Department of Ecology.

Permit Conditions H.5, H.8, I.5 Particulate Matter (mass per time)

= Concentration * Air Flow Rate * Unit Conversi on Factor * Black Liquor Solids Firing Rate * Black Liquor Solids Fired

Concentration, whether EPA RM 5 or DOE RM 5 as speci fied in the respective condition, gives results in terms of gr/dscf. Air Flow is calculated per specified RM 5. Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains.

Black Liquor Solids Firing Rate is the average firing rate during the stack test. Blck Liquor Solids Fired is the total t ons fired over the period in question.



### Permit Condition H.13, J.9 SO2 (mass per time) Permit Condition H.15, I.10 TRS (mass per time) Permit Condition H.17 NOx (mass per time)

= concentration x air flow x natural gas law conversion x black liquor solids firing rate * black liquor solids fired

Concentration is in terms of ppmdv at standard cond itions. It is derived either from average CEM values over the period of the particulate testing (e .g. SO2 on the Recovery Boiler) or from stack testing using specified RM (e.g. TRS on the smelt dissolver tank vent). Air Flow is calculated per specified particul ate test from the respective emission unit. Natural Gas Law Conversion is case specific. It converts ppm to mass per volume of air and is dependent on the molecular weight of the specific pollutant.

Black Liquor Solids Firing Rate is the average firing rate during the stack test. Blck Liquor Solids Fired is the total t ons fired over the period in question.

### 29 Permit Conditions I.3, I.4 Particulate Matter (mass/mass BLS)

= (Concentration x Air Flow Rate x Unit Conversion Factor x Time Adjustment)/ Black liquor solids firing rate

Concentration is in terms of gr/dscf . Air Flow is calculated per specified RM 1 and 2. Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. Time Adjustment is case specific and is dependent on the flow rate time unit. For example, if the flow rate from a RM 1 and 2 was in terms of dscfm and the black liquor firing rate is in hours then the time adjustment would be 60 minutes/hour. Black liquor solids firing rate is the ìas-firedî firing rate average for the test period. The firing rate is in terms of mass per time.

Permit Condition I.8 TRS (mass per BLS)

= (TRS(mass) x Air Flow Rate x Unit Conversion Factor x Time Adjustment)/ Black liquor solids firing rate

TRS mass is converted from Method 16 or 16a concentration in terms of ppm by multiplying by the respective MW of the four TRS compounds for Method 16 or by the MW of

SO2 for Method 16A. Air Flow is calculated as specified in RM 1, 2, 3 & 4. Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. Time Adjustment is case specific and is dependent on the flow rate time unit. For example, if the flow rate from a RM 1 and 2 was in terms of dscfm and the black liquor firing rate is in hours then the time adjustment would be 60 minutes/hour. Black liquor solids firing rate is the ìas-firedî firing rate average for the test period. The firing rate is in terms of mass per time.

Appendix D -- Regulatory Orders

The Orders containing applicable requirements reflected in this Permit are presented here in Appendix D in the chronological order listed below.

PSD-92-03 Amendment 4 Order No. DE 98AQ-I046

PSD 97-01 Order No. DE 95AQ-I035 Order No. DE 96AQ-I093 Order No. DE 95AQ-I076 Order No. DE 97AQ-I041 Order No. DE 94AQ-I080