MDISP2 3 3 

Dispersion coefficients from internally calculated 

sigma v, sigma w using micrometeorological 

calculated variables 

MROUGH 0 0 PG σy and σz not adjusted for roughness 

MPARTL 1 1 No partial plume penetration of elevated inversion 

MTINV 0 0 Strength of temperature inversion computed from 

default gradients 

MPDF 0 0 PDF not used for dispersion under convective 

conditions 

MSGTIBL 0 0 Sub-grid TIBL module not used for shoreline 

MBCON 0 0 Boundary concentration conditions not modeled 

MFOG 0 0 Do not configure for FOG model output 

MREG 1 1 NO checks are made 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 230 

 December 17, 2007
CALPUFF Model Input Group 3: Species List-Chemistry Options. 

CSPEC Modeled1 Emitted2 

Dry 

Deposition3 

Output 

Group 

Number 

SO2 1 1 1 0 

SO4

-2 1 1 2 0 

NOx 1 1 1 0 

HNO3 1 0 1 0 

NO3- 1 0 2 0 

NH3 1 0 1 0 

PMC 1 1 2 0 

PMF 1 1 2 0 

EC 1 1 2 0 

SOA 1 1 2 0 

Notes: 1 0=no, 1=yes 

2 0=no, 1=yes 

3 0=none; 1=computed-gas; 2=computed-particle; 3=user-specified 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 231 

 December 17, 2007
CALPUFF Model Input Group 4: Map Projection and Grid Control Parameters. 

Parameter Default PCS Comments 

PMAP UTM LCC Map Projection 

NX - 228 Number of X grid cells in meteorological grid 

NY - 232 Number of Y grid cells in meteorological grid 

NZ - 10 Number of vertical layers in meteorological Grid

DGRIDKM - 4 Grid spacing (km) 

ZFACE - 

0, 20 40, 80, 

160, 320, 640, 

1200, 2000, 

3000, 4000 

Cell face heights in meteorological grid (m) 

XORIGKM - 1066.005 Reference X coordinate for SW corner of grid 

cell (1,1) of meteorological grid (km) 

YORIGKM - -686.004 Reference Y coordinate for SW corner of grid 

cell (1,1) of meteorological grid (km) 

IUTMZN - 17 UTM zone of coordinates 

IBCOMP - 88 X index of lower left corner of the computational 

grid 

JBCOMP - 61 Y index of lower left corner of the computational 

grids 

IECOMP - 218 X index of the upper right corner of the 

computational grid 

JECOMP - 200 Y index of the upper right corner of the 

computational grid 

LSAMP T F Sampling grid is not used 

IBSAMP - 0 X index of lower left corner of the sampling Grid

JBSAMP - 0 Y index of lower left corner of the sampling Grid

IESAMP - 0 X index of upper right corner of the sampling 

grid 

JESAMP - 0 Y index of upper right corner of the sampling 

grid 

MESHDN 1 1 Nesting factor of the sampling grid 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 232 

 December 17, 2007
CALPUFF Model Input Group 5: Output Options. 

Parameter Default PCS Comments 

ICON 1 1 Output file CONC.DAT containing concentrations is 

created 

IDRY 1 0 Output file DFLX.DAT containing dry fluxes is Created 

IWET 1 0 Output file WFLX.DAT containing wet fluxes is created 

IVIS 1 0 Output file containing relative humidity data is created 

LCOMPRS T T Perform data compression in output file 

IMFLX 0 0 Do not calculate mass fluxes across specific boundaries 

IMBAL 0 0 Mass balances for each species not reported hourly 

ICPRT 0 0 Print concentration fields to the output list file 

IDPRT 0 0 Do not print dry flux fields to the output list file 

IWPRT 0 0 Do not print wet flux fields to the output list file 

ICFRQ 1 1 Concentration fields are printed to output list file every hr 

IDFRQ 1 1 Dry flux fields are printed to output list file every 1 hour 

IWFRQ 1 1 Wet flux fields are printed to output list file every 1 hour 

IPRTU 1 3 Units for line printer output are in g/m3 for concentration 

and g/m2/s for deposition 

IMESG 2 2 Messages tracking the progress of run written to screen 

LDEBUG F F Logical value for debug output 

IPFDEB 1 1 First puff to track 

NPFDEB 1 1 Number of puffs to track 

NN1 1 1 Meteorological period to start output 

NN2 10 10 Meteorological period to end output 

CALPUFF Model Input Group 6: Sub-Grid Scale Complex Terrain Inputs. 

Parameter Default PCS Comments 

NHILL 0 0 Number of terrain features 

NCTREC 0 0 Number of special complex terrain receptors 

MHILL - 0 Input terrain and receptor data for CTSG hills input in 

CTDM format 

XHILL2M 1 1 Conversion factor for changing horizontal dimensions 

to meters 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 233 

 December 17, 2007
ZHILL2M 1 1 Conversion factor for changing vertical dimensions to 

meters 

XCTDMKM - 

0.0 

E+00 

X origin of CTDM system relative to CALPUFF 

coordinate system (km) 

YCTDMKM - 

0.0 

E+00 

Y origin of CTDM system relative to CALPUFF 

coordinate system (km) 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 234 

 December 17, 2007
CALPUFF Model Input Group 7: Dry Deposition Parameters for Gases. 

Species Default PCS Comments 

0.1509 0.1509 Diffusivity 

1000. 1000. Alpha star 

8.0 8.0 Reactivity 

0.0 0.0 Mesophyll resistance 

SO2

0.04 0.04 Henry’s Law coefficient 

0.1656 0.1656 Diffusivity 

1.0 1.0 Alpha star 

8.0 8.0 Reactivity 

5.0 5.0 Mesophyll resistance 

NOx

3.5 3.5 Henry’s Law coefficient 

0.1628 0.1628 Diffusivity 

1.0 1.0 Alpha star 

18.0 18.0 Reactivity 

0.0 0.0 Mesophyll resistance 

HNO3

8.0E-8 8.0E-8 Henry’s Law coefficient 

CALPUFF Model Input Group 8: Dry Deposition Parameters for Particles. 

Species Default PCS Comments 

SO4 0.48 0.48 Geometric mass mean diameter of SO4

-2 [μm] 

NO3 2.0 0.48 Geometric mass mean diameter of NO3

-

 [μm] 

PMC 2.0 0.48 Geometric mass mean diameter of PMC [μm] 

PMF 2.0 0.48 Geometric mass mean diameter of PMF [μm] 

EC 2.0 0.48 Geometric mass mean diameter of EC [μm] 

SOA 0.48 0.48 Geometric mass mean diameter of SOA [μm] 

(Geometric Standard Deviation for all species assumed to be 2.0 μm). 

CALPUFF Model Input Group 9: Miscellaneous Dry Deposition Parameters. 

Parameter Default PCS Comments 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 235 

 December 17, 2007
RCUTR 30 30 Reference cuticle resistance (s/cm) 

RGR 10 10 Reference ground resistance (s/cm) 

REACTR 8 8 Reference pollutant reactivity 

NINT 9 9 Number of particle size intervals for 

effective particle deposition velocity 

IVEG 1 1 Vegetation in non-irrigated areas is active 

and unstressed 

CALPUFF Model Input Group 10: Wet Deposition Parameters. 

Species Default PCS Comments 

3.21E-05 3.21E-05 Scavenging coefficient for liquid precipitation [s-1] SO2

0.0 0.0 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] 

SO4 3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

6.0E-05 6.0E-05 Scavenging coefficient for liquid precipitation [s-1] 

HNO3 0.0 0.0 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] NO3

3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

8.0E-05 8.0E-05 Scavenging coefficient for liquid precipitation [s-1] NH3

0.0 0.0 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] PMC 

3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] PMF 

3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] EC 

3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

1.0E-04 1.0E-04 Scavenging coefficient for liquid precipitation [s-1] OC 

3.0E-05 3.0E-05 Scavenging coefficient for frozen precipitation [s-1] 

CALPUFF Model Input Group 11: Chemistry Parameters. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 236 

 December 17, 2007
Parameter Default PCS Comments 

MOZ 1 1 Read ozone background concentrations from 

ozone.dat file (measured values). 

BCKO3 12*80 12*40 Background ozone concentration (ppb) 

BCKNH3 12*10 12*1.22 Background ammonia concentration (ppb) 

RNITE1 0.2 0.2 Nighttime NO2 loss rate in percent/hour 

RNITE2 2 2 Nighttime NOX loss rate in percent/hour 

RNITE3 2 2 Nighttime HNO3 loss rate in percent/hour 

MH202 1 1 Background H2O2 concentrations (Aqueous 

phase transformations not modeled) 

BCKH202 1 1 Background monthly H2O2 concentrations 

(Aqueous phase transformations not modeled) 

BCKPMF 1. 1. Fine particulate concentration for SOA Option 

(micrograms per cubic meter) 

OFRAC .2 .2 Organic fraction of fine particulate for SOA 

Option 

VCNX 50. 50. VOC/NOx ratio for SOA Option 

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Appendix L.10 - 237 

 December 17, 2007
CALPUFF Model Input Group 12: Dispersion/Computational Parameters. 

Parameter Default PCS Comments 

SYDEP 550 550 

Horizontal size of a puff in meters beyond 

which the time dependant dispersion equation 

of Heffter (1965) is used 

MHFTSZ 0 0 Do not use Heffter formulas for sigma z 

JSUP 5 5 Stability class used to determine dispersion 

rates for puffs above boundary layer 

CONK1 0.01 0.01 Vertical dispersion constant for stable 

Conditions 

CONK2 0.1 0.1 Vertical dispersion constant for neutral/stable 

conditions 

TBD 0.5 0.5 

Use ISC transition point for determining the 

transition point between the Schulman-Scire 

to Huber-Snyder Building Downwash scheme

IURB1 10 10 Lower range of land use categories for which 

urban dispersion is assumed 

IURB2 19 19 Upper range of land use categories for which 

urban dispersion is assumed 

ILANDUIN 20 * Land use category for modeling domain 

XLAIIN 3.0 * Leaf area index for modeling domain 

ZOIN -0.25 * Roughness length in meters for modeling 

Domain 

ELEVIN 0.0 * Elevation above sea level 

XLATIN -999 - North latitude of station in degrees 

XLONIN -999 - South latitude of station in degrees 

ANEMHT 10 10 Anemometer height in meters 

ISIGMAV 1 1 Sigma-v is read for lateral turbulence Data 

IMIXCTDM 0 0 Predicted mixing heights are used 

XMXLEN 1 1 Maximum length of emitted slug in 

meteorological grid units 

XSAMLEN 1 10 

Maximum travel distance of slug or puff in 

meteorological grid units during one sampling 

unit 

MXNEW 99 99 Maximum number of puffs or slugs released 

from one source during one time step 

MXSAM 99 99 Maximum number of sampling steps during 

one time step for a puff or slug 

BART Related Documentation 

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Appendix L.10 - 238 

 December 17, 2007
NCOUNT 2 2 

Number of iterations used when computing the 

transport wind for a sampling step that 

includes transitional plume rise 

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Appendix L.10 - 239 

 December 17, 2007
Parameter Default PCS Comments 

SYMIN 1 1 Minimum sigma y in meters for a new puff or 

slug 

SZMIN 1 1 Minimum sigma z in meters for a new puff or 

slug 

SVMIN .50 .50 Minimum lateral turbulence velocities (m/s) 

SWMIN 

0.20, 0.12, 

0.08, 0.06, 

0.03, 

0.016 

0.20, 0.12, 

0.08, 0.06, 

0.03, 

0.016 

Minimum vertical turbulence velocities (m/s) 

WSCALM 0.5 0.5 Minimum non-calm wind speeds (m/s) 

XMAXZI 3000. 3000. Maximum mixing height (m) 

XMINZI 50. 50. Minimum mixing height (m) 

SL2PF 10. 10. Maximum Sy/puff length 

PLXO 

0.07, 0.07, 

0.10, 0.15, 

0.35, 0.55 

0.07, 0.07, 

0.10, 0.15, 

0.35, 0.55 

Wind speed power-law exponents 

WSCAT 

1.54, 3.09, 

5.14, 8.23, 

10.80 

1.54, 3.09, 

5.14, 8.23, 

10.80 

Upper bounds 1s t 5 wind speed classes 

PGGO 0.020, 

0.035 

0.020, 

0.035 Potential temp gradients PG E & F (deg/km) 

CDIV 0.01 0.01 Divergence criterion for dw/dz (1/s) 

PPC 

0.5, 0.5, 

0.5, 0.5, 

0.35, 0.35 

0.5, 0.5, 

0.5, 0.5, 

0.35, 0.35 

Plume path coefficients (only if MCTADJ=3) 

NSPLIT 3 3 Number of puffs when puffs split 

IRESPLIT - 1900 Hour(s) when puff is eligible to split 

ZISPLIT 100 100 Previous hour’s minimum mixing height, m 

ROLDMAX 0.25 0.25 

Previous Max mixing height/current mixing 

height ratio, must be less than this value to 

allow puff to split 

NSPLITH 5 5 Number of puffs resulting from a split 

SYSPLITH 1.0 1.0 Minimum sigma-y of puff before it may Split 

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Appendix L.10 - 240 

 December 17, 2007
SHSPLITH 2.0 2.0 Minimum puff elongation rate from wind 

shear before puff may split 

CNSPLITH 1.0E-07 1.0E-07 Minimum species concentration before a puff 

may split 

EPSSLUG 1.0E-04 1.0E-04 Criterion for SLUG sampling 

EPSAREA 1.0E-06 1.0E-06 Criterion for area source integration 

DSRISE 1.0 1.0 Trajectory step length for numerical rise 

Algorithm 

Note: Values indicated by an asterisk (*) were allowed to vary spatially across the domain and 

were obtained from CALMET 

BART Related Documentation 

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Appendix L.10 - 241 

 December 17, 2007
CALPUFF Model Input Group 13: Point Source Parameters. 

Parameter Default PCS Comments 

NPT1 - 22 Number of point sources with constant stack 

parameters or variable emission rate scale factors 

IPTU 1 3 Units for point source emission rates are lb/hr 

NSPT1 0 0 Number of source-species combinations with 

variable emissions scaling factors 

NPT2 - 0 Number of point sources with variable emission 

parameters provided in external file 

CALPUFF Model Input Group 14: Area Source Parameters. 

Parameter Default PCS Comments 

NAR1 0 Number of polygon area sources 

IARU 1 3 Units for area source emission rates are lb/m2/s 

NSAR1 0 - Number of source species combinations with 

variable emissions scaling factors 

NAR2 - - Number of buoyant polygon area sources with 

variable location and emission parameters 

CALPUFF Model Input Group 15: Line Source Parameters. 

Parameter Default PCS Comments 

NLN2 - - Number of buoyant line sources with variable location 

and emission parameters 

NLINES - - Number of buoyant line sources 

ILNU 1 - Units for line source emission rates is g/s 

NSLN1 0 - Number of source-species combinations with variable 

emissions scaling factors 

MXNSEG 7 - Maximum number of segments used to model each line

NLRISE 6 - Number of distance at which transitional rise is 

computed 

XL - - Average line source length (m) 

HBL - - Average height of line source height (m) 

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Appendix L.10 - 242 

 December 17, 2007
WBL - - Average building width (m) 

WML - - Average line source width (m) 

DXL - - Average separation between buildings (m) 

FPRIMEL - - Average buoyancy parameter (m4/s3) 

CALPUFF Model Input Group 16: Volume Source Parameters. 

Parameter Default PCS Comments 

NVL1 - 9 Number of volume sources 

IVLU 1 3 Units for volume source emission rates is pounds per 

hour 

NSVL1 0 - Number of source-species combinations with variable 

emissions scaling factors 

IGRDVL - - Gridded volume source data is not used 

VEFFHT - - Effective height of emissions (m) 

VSIGYI - - Initial sigma y value (m) 

VSIGZI - - Initial sigma z value (m) 

CALPUFF Model Input Group 17: Discrete Receptor Information. 

Parameter Default PCS Comments 

NREC - 52 Number of non-gridded receptors 

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Appendix L.10 - 243 

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Appendix C 

CALPOST Configuration

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Appendix L.10 - 244 

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APPENDIX C – CALPOST Configuration 

The tables below identify the recommended CALPOST processor screening configurations for 

VISTAS BART modeling. 

Input Groups in the CALPOST Processor Control File. 

Group Description 

Applicable to 

BART Modeling 

0 Input and output file names Yes 

1 General Run Control Parameters Yes 

2 Visibility Parameters Yes 

3 Output Options Yes 

CALPOST Processor Input Group 1: General Run Control Parameters 

Parameter DEFAULT PCS Comments 

ISYR -- 2001 Starting year 

ISMO -- 1 Starting month 

ISDY -- 1 Starting day 

ISHR -- 0 Starting hour 

NPER -- 8760 Number of periods to process 

NREP 1 1 Process every hour of data? Yes = 1 

ASPEC -- VISIB Process species for visibility 

ILAYER 1 1 Layer/deposition code; 1 for CALPUFF 

concentrations 

A 0.0 0.0 Scaling factor, slope 

B 0.0 0.0 Scaling factor, intercept 

LBACK F F Add hourly background concentrations or fluxes?

LG F F Process gridded receptors? 

LD F T Process discrete receptors? 

BART Related Documentation 

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LCT F F Process complex terrain receptors? 

LDRING F F Report receptor ring results? 

NDRECP -1 -1 Select all discrete receptors 

IBGRID -1 -1 X index of LL corner of receptor grid 

JBGRID -1 -1 Y index of LL corner of receptor grid 

IEGRID -1 -1 X index of UR corner of receptor grid 

JEGRID -1 -1 X index of UR corner of receptor grid 

NGONOFF 0 0 Number of gridded receptor rows 

NGXRECP 1 0 Exclude specific gridded receptors, Yes = 0 

BART Related Documentation 

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Appendix L.10 - 246 

 December 17, 2007
 

CALPOST Processor Input Group 2: Species Processing Information 

Parameter Default PCS Comments 

RHMAX 98 95 Maximum RH (%) used in particle growth curve 

LVSO4 T T Compute light extinction for sulfate? 

LVNO3 T T Compute light extinction for nitrate? 

LVOC T T Compute light extinction for organic carbon? 

LVMPC T T Compute light extinction for coarse particles? 

LVMPF T T Compute light extinction for fine particles? 

LVEC T T Compute light extinction for elemental carbon? 

LVBK T F Include background in extinction calculation? 

SPECPMC PMC PMC Coarse particulate species 

SPECPMF PMF PM10 Fine particulate species 

EEPMC 0.6 0.6 Extinction efficiency for coarse particulates 

EEPMF 1.0 1.0 Extinction efficiency for fine particulates 

EEPMCBK 0.6 0.6 Extinction efficiency for coarse part. background 

EESO4 3.0 3.0 Extinction efficiency for ammonium sulfate 

EENO3 3.0 3.0 Extinction efficiency for ammonium nitrate 

EEOC 4.0 4.0 Extinction efficiency for organic carbon 

EESOIL 1.0 1.0 Extinction efficiency for soil 

EEEC 10.0 10.0 Extinction efficiency for elemental carbon 

MVISBK 2 6 

Method 6 for background light extinction: Compute 

extinction from speciated PM measurements. 

FLAG RH adjustment factor applied to observed & 

modeled sulfate and nitrate 

BEXTBTBK -- 10 Background extinction for MVISBK=1 (1/Mm) 

RHFRAC -- 10 Percentage of particles affected by RH 

RHFAC 12*value 

Depends 

on Class 

I Area 

Extinction coefficients for modeled and background 

hygroscopic species computed using EPA (2003) 

monthly RH adjustment factors 

BKSEC 0.02 0.02 Background elem. carbon extinct. coeff – east 

BKSO4 0.23 0.23 Background sulfate extinction coeff – east 

BKNO3 0.10 0.10 Background nitrate extinction coeff – east 

BART Related Documentation 

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Appendix L.10 - 247 

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BKPMC 3.00 3.00 Background coarse part. extinction coeff – east 

BKSOC 1.40 1.40 Background organic carbon extinct. coeff – east 

BKSSOIL 0.50 0.50 Background soil extinction coeff – east 

BKSEC 0.02 0.02 Background elem. carbon extinct. coeff – east 

BEXTRAY 10.0 10.0 Extinction due to Rayleigh scattering (1/Mm) 

BART Related Documentation 

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Appendix L.10 - 248 

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CALPOST Processor Input Group 3: Output Options 

Parameter DEFAULT PCS Comments 

LDOC F F Print documentation image? 

IPRTU 1 3 Print output units (μg/m3

) for concentrations and 

(μg/m2

/sec) for deposition 

L1HR T F Report 1 hr averaging times 

L3HR T F Report 3 hr averaging times 

L24HR T T Report 24 hr averaging times 

LRUNL T F Report run-length (annual) averaging times 

LT50 T F Top 50 table 

LTOPN F F Top ‘N’ table 

NTOP 4 4 Number of ‘Top-N’ values at each receptor 

ITOP 1,2,3,4 1,2,3,4 Ranks of ‘Top-N’ values at each receptor 

LEXCD F F Threshold exceedances counts 

THRESH1 -1.0 -1.0 Averaging time threshold for 1 hr averages 

THRESH3 -1.0 -1.0 Averaging time threshold for 3 hr averages 

THRESH24 -1.0 -1.0 Averaging time threshold for 24 hr averages 

THRESHN -1.0 -1.0 Averaging time threshold for NAVG-hr averages

NDAY 0 0 Accumulation period, days 

NCOUNT 1 1 Number of exceedances allowed 

LECHO F F Echo option 

LTIME F F Time series option 

LPLT F F Plot file option 

LGRD F F Use grid format instead of DATA format 

LDEBUG F F Output information for debugging? 

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Appendix L.10 - 249 

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Appendix D 

CLASS I Receptors in Lambert Conformal Coordinates 

BART Related Documentation 

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APPENDIX D – Class I Receptors in Lambert Conformal Coordinates 

Swanquarter Class I Area 

Lambert Conformal X (km) Lambert Conformal Y (km) Height (m) 

1857.33057 -305.922 0 

1858.06454 -305.752 1 

1857.12185 -305.023 1 

1857.85574 -304.852 1 

1856.91314 -304.123 0 

1848.63247 -305.093 0 

1844.75538 -305.04 0 

1856.49571 -302.324 0 

1857.22935 -302.154 1 

1857.96298 -301.984 1 

1861.63086 -301.131 1 

1862.36438 -300.96 1 

1863.83140 -300.619 1 

1864.56488 -300.448 1 

1846.01559 -303.801 1 

1850.41800 -302.784 1 

1854.08624 -301.935 0 

1854.81985 -301.765 0 

1855.55343 -301.595 1 

1856.28701 -301.425 1 

1857.02056 -301.255 1 

1857.75410 -301.084 1 

1860.68811 -300.402 0 

1861.42157 -300.232 1 

1862.15502 -300.061 1 

1862.88845 -299.89 1 

1863.62186 -299.719 1 

1845.07433 -303.071 0 

1845.80803 -302.902 1 

1847.27540 -302.563 1 

1848.74271 -302.224 1 

BART Related Documentation 

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Appendix L.10 - 251 

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Swanquarter Class I Area 

Lambert Conformal X (km) Lambert Conformal Y (km) Height (m) 

1856.07830 -300.525 1 

1856.81177 -300.355 1 

1857.54523 -300.185 1 

1859.74551 -299.674 0 

1860.47891 -299.503 1 

1861.21 -299.332 1 

1843.4 -302.509 0 

1844.13 -302.34 1 

1844.87 -302.171 1 

1848.53 -301.324 0 

1849.27 -301.155 1 

1856.6 -299.456 1 

1857.34 -299.286 1 

1858.8 -298.945 1 

1859.54 -298.774 1 

1848.33 -300.425 1 

1856.39 -298.556 1 

1858.59 -298.045 1 

1859.33 -297.875 1 

1859.12 -296.976 1 

1859.85 -296.805 1 

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NORTH CAROLINA 

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 

DIVISION OF AIR QUALITY 

BEST AVAILIBLE RETROFIT TECHNOLOGY 

PRELIMINARY DETERMINATION 

FOR 

BLUE RIDGE PAPER PRODUCTS 

CANTON, HAYWOOD COUNTY 

NORTH CAROLINA 

THIS REVIEW WAS PERFORMED BY THE 

AIR PERMITS SECTION 

IN ACCORDANCE WITH 15A NCAC 2D .0543 

“BEST AVAILIBLE RETROFIT TECHNOLOGY” 

October 10, 2007 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 280 

 December 17, 2007
Blue Ridge Paper Products BART determination 

TABLE OF CONTENTS

Section Page

1.0 Introduction .................................................................................................................... 3 

1.1 BART Determination ......................................................................................... 3 

2.0 General Description......................................................................................................... 5 

2.1 BART Affected Units ......................................................................................... 5 

2.2 BART Exemption Modeling Analysis ............................................................... 6 

3.0 Regulatory Analysis ........................................................................................................ 8 

 3.1 Federal BART Applicability and Required Analyses................................8 

 3.2 North Carolina BART Applicability....................................................9 

 3.3 Required Air Quality Permits............................................................9 

4.0 Best Available Retrofit Technology Analysis................................................................. 10 

4.1 Summary ............................................................................................................. 10 

 4.2 BART Analysis Overview............................................. ..................................... 10 

 4.3 BART Analysis for Recovery Boilers................................................................. 13 

 4.3.1 BART Analysis for NOx emission control.............................................. 13 

 4.3.2 BART Analysis for SO2 emission control.............................................. 15 

 4.4 BART Analysis for Smelt Dissolving Tanks ...................................................... 17 

 4.4.1 BART Analysis for SO2 and PM emissions control............................... 17 

 4.4.2 Bart Analysis for NOx emission control................................................. 18 

 4.5 BART Analysis for Black Liquor Oxidation System.......................................... 18 

 

Response to EPA and NPS Comments on BART Permit Application ....... ........... APPENDIX A 

NCASI Corporate Correspondents Memorandum on Retrofit controls ....... ........... APPENDIX B 

Public Notice for BART Title V Air Permit Modification .......................... ........... APPENDIX C 

Draft Air Permit Language ........................................................................... ........... APPENDIX D 

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3 

SECTION 1.0 

INTRODUCTION 

The Blue Ridge Paper Products (BRPP) Canton facility is a bleached kraft pulp mill producing 

bleached kraft softwood and hardwood pulp, paper and paperboard. Existing sources include: 

five power boilers, a batch digester and brownstock washer system, two recovery boilers, black 

liquor evaporator system, turpentine recovery system, two lime kilns, a chlorine dioxide 

generator, two pulp bleaching systems, three paper machines and a paperboard dryer. The 

facility is a Title V facility and operates under air permit 08961T08. BRPP submitted a BART 

evaluation Permit Application to the North Carolina Department of Environment and 

Environmental Resources Division of Air Quality Division of Air Quality (NCDAQ) on 

November 16, 2007. 

The requirements for Best Available Retrofit Technology (BART) are set forth in 15A NCAC 

2D .0543 “Best Available Retrofit Technology.” This rule, currently State-Only enforceable, 

implements the BART provisions of 40 CFR 51.301 for emission sources that may cause or 

contribute to any visibility impairment in a mandatory Class I federal areas as determined using 

40 CFR 51, Subpart P. “BART-eligible” sources are those sources built between 1962 and 1977 

that have the potential to emit more than 250 tons per year of one or more visibility-impairing 

compounds including sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and 

volatile organic compounds (VOCs), and that fall within 26 industrial source categories 

(including Kraft pulp and paper manufacturing). A review of the emission sources found that 

there were five emission sources that were BART eligible: Recovery Boiler 10, Recovery Boiler 

11, No. 10 smelt dissolving tank, No. 11 smelt dissolving tank, and the Black Liquor Oxidation 

System. 

Under the authority of 15A NCAC 2D .0543(c), a BART-eligible source can be exempted from 

the BART requirements based on dispersion modeling demonstrating that the source cannot 

reasonably be anticipated to cause or contribute to visibility impairment in a Class I area. The 

emissions from these sources were modeled using CALPUFF to determine if the emissions from 

the BART eligible emission sources contributed to perceptible visibility impairment to Class I 

areas. The results of this modeling indicated that there was a significant impact from these 

sources to the Great Smokey Mountains and the Shining Rock Class I areas. Since these 

emission sources could not be otherwise exempted from BART, a BART analysis was 

conducted in accordance with the requirements set forth in 15A NCAC 2D .0543. 

1.1 BART Determination

The NCDAQ has made the determination that BART for the affected emission sources is no 

additional controls. Therefore, the NCDAQ proposes to issue an air permit with a specific permit 

condition that notes that the permittee has satisfied all of the requirements for BART and that no 

additional controls are necessary. The remainder of this report contains a review by NCDAQ of 

the demonstration and analyses presented by Blue Ridge Paper Products. The response to EPA 

and the National Park Service comments on the BART Permit application may be found in 

Appendix A. Appendix B contains the NCASI Corporate Correspondents Memorandum on 

BART Related Documentation 

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Appendix L.10 - 282 

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4 

retrofit controls. 

BART will be implemented through a modification to Blue Ridge Paper Products Title V air 

permit. The Title V air permit application implementing BART must undergo adequate public 

participation. The NCDAQ solicits and encourages participation by the general public, industry, 

and other affected persons. Specific public notice requirements and a 30-day public comment 

period are required before the NCDAQ can take final action on this application. Appendix C 

contains a copy of the public notice. The draft air permit language implementing the BART 

requirements may be found in Appendix D. 

BART Related Documentation 

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5 

SECTION 2.0 

2.1 BART Affected Units 

 “BART-eligible” sources are those sources built between 1962 and 1977 that have the potential 

to emit more than 250 tons per year of one or more visibility-impairing compounds including 

sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and volatile organic 

compounds (VOCs), and that fall within 26 industrial source categories (including Kraft pulp and 

paper manufacturing). The Blue Ridge Paper Canton Mill has 5 BART-eligible units: 

• No. 10 Recovery Furnace (10REC): The No. 10 Recovery furnace has a nominal black 

liquor solids firing rate of 121,000 pounds of black liquor solids per hour and can fire fuel oil 

during start-up, shutdown, and malfunction (SSM) at a nominal heat input rate of 

382 MMBtu/hr. The unit is controlled by an electrostatic precipitator. This unit is subject to 

MACT standards at 40 CFR 63, Subpart MM, and its PM emissions are approximately 10 

percent of the single source recovery furnace limit of 0.044 gr/dscf. The unit was 

constructed in 1964. 

• No. 11 Recovery Furnace (11REC): The No. 11 Recovery furnace was constructed in 1973 

and has a nominal black liquor solids firing rate of 121,000 pounds of black liquor solids per 

hour and can fire fuel oil during start-up, shutdown, and malfunction (SSM) at a nominal 

heat input rate of 382 MMBtu/hr. The unit is controlled by an electrostatic precipitator. This 

unit is subject to MACT standards at 40 CFR 63, Subpart MM, and its PM emissions are 

approximately 15 percent of the single source recovery furnace limit of 0.044 gr/dscf. 

• No. 10 Smelt Dissolving Tank (10SDT): This smelt dissolving tank serves the No. 10 

Recovery Furnace and was installed in 1964. This unit is controlled by a chevron mist 

eliminator. This unit is subject to MACT standards at 40 CFR 63, Subpart MM. 

• No. 11 Smelt Dissolving Tank (11SDT): This smelt dissolving tank serves the No. 11 

Recovery Furnace. This unit is controlled by a chevron mist eliminator. This unit is subject 

to MACT standards at 40 CFR 63, Subpart MM. The unit was constructed in 1973. 

• Black liquor oxidation system (BLOX): The black liquor oxidation system precedes the 

two recovery furnaces and is in place to reduce Total Reduced Sulfur (TRS) emissions from 

the recovery furnaces by oxidizing the black liquor. This system is controlled by a 

Regenerative Thermal Oxidizer (RTO) and wet scrubber; therefore, the RTO scrubber stack 

parameters and emission rates were included in this analysis. This unit is subject to MACT 

standards at 40 CFR 63, Subpart S, via 40 CFR 63.94, Equivalency by Permit. The BLOX 

system was originally installed in 1964. 

These units are part of the mill’s chemical recovery system, which is an integral part of the Kraft 

pulping process. Although the recovery furnaces do produce steam for process operations, their 

primary purpose is chemical recovery, and are collectively controlled below the chemical 

recovery source MACT emission limits set forth in 40 CFR 63 Subpart MM. In addition, the 

BLOX will be controlled by a regenerative thermal oxidizer (RTO) to reduce HAP emissions 

under MACT Subpart S, followed by a wet scrubber to minimize SO2 emissions from 

combustion of sulfur compounds in the BLOX gases in order to not be considered a signicicant 

BART Related Documentation 

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Appendix L.10 - 284 

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6 

modification under NSR PSD. Therefore, the 5 BART-eligible emission units at the Blue Ridge 

Canton Mill are already well-controlled units. 

2.2 BART exemption modeling analysis 

The first step of the BART process was to determine if any of the affected BART-eligible 

sources could be exempted based on their contribution to visibility impacts on Class I areas. 

According to 40 CFR Part 51, Appendix Y, a BART-eligible source is considered to “contribute” 

to visibility impairment in a Class I area if the modeled 98th percentile change in deciviews1

 (dv) 

is equal to or greater than the “contribution threshold.” The contribution threshold is understood 

to be 0.5 deciview and a threshold of 1.0 deciview is understood to cause visibility impairment. 

Any BART-eligible source determined to cause or contribute to visibility impairment in any 

Class I area is subject to a BART evaluation. 

Blue Ridge submitted a modeling protocol to NCDAQ on January 31, 2006. The objective of the 

modeling protocol was to obtain approval from NCDAQ on the modeling procedures that were 

used to conduct the BART exemption modeling for the Blue Ridge Canton Mill. The protocol 

incorporated guidance developed by VISTAS for conducting a BART modeling analysis and 

proposed a more refined line-of-sight modeling approach. The protocol presented detailed 

explanations of both modeling procedures. However, the BART determination was based on the 

VISTAS modeling protocol. The results of the exemption modeling of the combined BART 

eligible units are shown in the following table. 

Summary of Exemption Modeling Results for BART Eligible Sources at the Canton 

Mill 

Delta Deciview (dv)1

Class I Area Standard (VISTAS) Approach 

Shining Rock 2.887 

Great Smoky Mountains 0.764 

Linville Gorge 0.155 

Joyce Kilmer 0.134 

Cohutta 0.095 

1 – Delta deciview as compared to natural conditions. 

 

1 Deciview means a measurement of visibility impairment. A deciview is a haze index derived from calculated light 

extinction, such that uniform changes in haziness correspond to uniform incremental changes in perception across 

the entire range of conditions, from pristine to highly impaired. The deciview haze index is calculated based on the 

following equation (for the purposes of calculating deciview, the atmospheric light extinction coefficient must be 

calculated from aerosol measurements): 

Deciview haze index=10 lne(bext/10 Mm−1

). 

Where bext=the atmospheric light extinction coefficient, expressed in inverse megameters 

(Mm−1

). 

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Appendix L.10 - 285 

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Blue Ridge Paper Products BART determination 

7 

The results of the exemption modeling indicate that, since the emissions from the BART eligible 

emission sources exceed the 0.5 dv contribution threshold for two Class I areas, a BART 

evaluation must be conducted for each of the five emission sources. 

BART Related Documentation 

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Appendix L.10 - 286 

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8 

SECTION 3.0 

REGULATORY ANALYSIS 

 

3.1 Federal BART Applicability and Required Analysis 

The Clean Air Act established goals for visibility in many national parks and wilderness areas. 

Through the 1977 amendments to the Clean Air Act, Congress set a national goal for visibility as 

“the prevention of any future, and the remedying of any existing, impairment of visibility in 

mandatory Class I Federal areas which impairment results from manmade air pollution.” The 

Amendments required EPA to issue regulations to assure “reasonable progress” toward meeting 

the national goal. The Class I Areas affected by this facility are the Shining Rock and the Great 

Smoky Mountains National Parks. 

One of the principal elements of the visibility protection provisions of the Clean Air Act 

addresses installation of best available retrofit technology (BART) for certain existing sources. 

“BART-eligible” sources are those sources built between 1962 and 1977 that have the potential 

to emit more than 250 tons per year of one or more visibility-impairing compounds including 

sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and volatile organic 

compounds (VOCs), and that fall within 26 industrial source categories (including Kraft pulp and 

paper manufacturing). 

The BART requirements are found in 40 CFR 51.308(e) “Best Available Retrofit Technology 

(BART) requirements for regional haze visibility impairment.” In addition, the final BART 

implementation and guidance (40 CFR Part 51, Appendix Y) published on July 6, 2005 and 

allow for a BART evaluation for any BART-eligible source that “emits any air pollutant which 

may reasonably be anticipated to cause or contribute to any impairment of visibility” in any 

mandatory Class I federal area. The guidance (Appendix Y) must only be followed by states for 

large fossil fuel fired electric steam generators, but is otherwise optional for other potential 

BART units. 

According to Appendix Y, a BART-eligible source is considered to “contribute” to visibility 

impairment in a Class I area if the modeled 98th percentile change in dv is equal to or greater 

than the “contribution threshold.” The contribution threshold is understood to be 0.5 deciview 

and a threshold of 1.0 deciview is understood to cause visibility impairment. Any BART-eligible 

source determined to cause or contribute to visibility impairment in any Class I area is subject to a 

BART evaluation. 

Based on the results of the BART evaluations, States will develop Regional Haze State 

Implementation Plans (SIPs). States must submit plans to implement the Regional Haze Rule for 

EPA review and approval by January 2008. 

BART Related Documentation 

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Appendix L.10 - 287 

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9 

3.2 North Carolina BART Applicability 

The BART requirements are implemented through 15A NCAC 2D .0543 “Best Available 

Retrofit Technology.” This rule implements the BART provisions of 40 CFR 51.301 for 

emission sources that may cause or contribute to any visibility impairment in a mandatory Class 

I federal area as determined using 40 CFR 51, Subpart P. There five emission sources that are 

BART eligible: Recovery Boiler 10, Recovery Boiler 11, No. 10 smelt dissolving tank, No. 11 

smelt dissolving tank, and the Black Liquor Oxidation System. 

Under the authority of 15A NCAC 2D .0543(c), a BART-eligible source may be exempted from 

the BART requirements based on dispersion modeling demonstrating that the source cannot 

reasonably be anticipated to cause or contribute to visibility impairment in a Class I area. The 

results of this modeling indicated that there was a significant impact from these sources to the 

Great Smokey Mountains and the Shining Rock Class I areas. Since these emission sources 

could not be otherwise exempted from BART, a BART analysis was conducted in 

accordance with the requirements set forth in 15A NCAC 2D .0543. 

3.3 Required Air Quality Permits 

The BART requirements, if any, will be implemented through the Title V permitting process. 

Since BART will not be required for any of the BART-eligible sources, the Title V permit will 

be modified to indicate that there are no applicable BART requirements for the BART-eligible 

emission sources at Blue Ridge Paper products. 

BART Related Documentation 

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Appendix L.10 - 288 

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10 

SECTION 4.0 

BEST AVAILABLE RETROFIT TECHNOLOGY ANALYSIS 

4.1 Summary 

The sources subject to the Best Available Retrofit Technology (BART) requirements include the 

two recovery boilers, their associated smelt dissolving tanks, and the BLOX. This section 

presents the BART analyses for these emission sources, since they could not be otherwise 

exempted based on emission modeling. This BART evaluation has concluded that BART for all 

of these emission sources are the existing emission control systems. 

4.2 BART Analysis Overview 

BART is defined as follows [40 CFR 51.301]: 

“Best Available Retrofit Technology (BART) means an emission limitation based on the degree 

of reduction achievable through the application of the best system of continuous emission 

reduction for each pollutant which is emitted by an existing stationary facility. The emission 

limitation must be established, on a case-by-case basis, taking into consideration the technology 

available, the costs of compliance, the energy and non-air quality environmental impacts of 

compliance, any pollution control equipment in use or in existence at the source, the remaining 

useful life of the source, and the degree of improvement in visibility which may reasonably be 

anticipated to result from the use of such technology.” 

The BART analysis was conducted with consideration of the six requirements identified above 

and the five steps identified in 40 CFR 51 Appendix Y “Guidelines for BART Determinations 

Under the Regional Haze Rule.” Again, these guidelines are not the exclusive means of defining 

BART for facilities other than Electric Generating Units. However, they provide a convenient 

structure to consider. 

• Step 1—Identify All Available Retrofit Control Technologies, 

• Step 2— Eliminate Technically Infeasible Options, 

• Step 3— Evaluate Control Effectiveness of Remaining Control Technologies, 

• Step 4— Evaluate Impacts and Document the Results, and

• Step 5—Evaluate Visibility Impacts. 

Each of these steps is discussed in further detail in the sections presented below. 

4.2.1 Step 1 – Identify All Available Retrofit Control Technologies 

Appendix Y to 40 CFR 51 defines an available retrofit control option as an air pollution control 

technology with a practical potential for application to the emissions unit and the regulated 

pollutant under evaluation. Technologies available for compliance with Best Available Control 

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Appendix L.10 - 289 

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11 

Technology (BACT) or Lowest Achievable Emission Rate (LAER) regulations should be 

included as part of the BART analysis. Furthermore, technologies that are evaluated should 

include existing controls for the source category in question as well as the transfer of controls 

that have been applied to similar source categories and gas streams. However, control 

technologies which have not yet been applied to full scale operations are not required to be 

included in the evaluation. 

Potentially applicable control technologies can be grouped into one of three categories: 

• Pollution Prevention. As stated in the regulation this is “use of inherently lower-emitting 

processes/practices, including the use of control techniques (e.g., low-NOX burners) and 

work practices that prevent emissions and result in lower "production-specific" emissions.” 

• Add-on Control Technologies. “Use of (and where already in place, improvement in the 

performance of) add-on controls, such as scrubbers, fabric filters, thermal oxidizers and 

other devices that control and reduce emissions after they are produced.” 

• Combinations of the previous two categories. 

Sources that were used to determine the potentially applicable control technologies for the Blue 

Ridge BART analysis include the Environmental Protection Agency’s RACT/BACT/LAER 

Clearinghouse (RBLC), control technology vendors, and information supplied by the National 

Council for Air and Stream Improvement (NCASI). 

4.2.2 Step 2 – Eliminate Technically Infeasible Options 

Step 1 of the BART analysis identifies all of the control technologies that are potentially 

available for the BART eligible emission units. In step 2 of the analysis this list is further 

refined to include only those technologies that are technically feasible. Appendix Y of 40 CFR 

51 defines a technically feasible control technology as: 

“Control technologies are technically feasible if either (1) they have been installed and 

operated successfully for the type of source under review under similar conditions, or (2) 

the technology could be applied to the source under review. Two key concepts are 

important in determining whether a technology could be applied: "availability" and 

"applicability." ...a technology is considered "available" if the source owner may obtain 

it through commercial channels, or it is otherwise available within the common sense 

meaning of the term. An available technology is "applicable" if it can reasonably be 

installed and operated on the source type under consideration. A technology that is 

available and applicable is technically feasible.” 

Control technologies that are deemed technically infeasible in this step of the evaluation must 

include specific data stating that the technology is either commercially unavailable or outline the 

specific circumstances which preclude is application. Facilities may demonstrate that a 

particular technology is infeasible due to “unresolvable technical difficulties with applying the 

control to the source (e.g., size of the unit, location of the proposed site, operating problems 

related to specific circumstances of the source, space constraints, reliability, and adverse side 

effects on the rest of the facility).” 

Implications of cost effectiveness should not be included in this step of the analysis. 

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Appendix L.10 - 290 

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12 

4.2.3 Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies 

Control technologies determined to be technically feasible in step 2 of the analysis are further 

evaluated in step 3. The two main issues in step 3 of the process are as follows: 

• Making sure that you express the degree of control using a metric that ensures an “apples to 

apples” comparison of emissions performance levels among options, and 

• Giving appropriate treatment and consideration of control techniques that can operate over a 

wide range of emission performance levels. 

The analysis should be based on the maximum level of control that a technology is capable of 

achieving. 

4.2.4 Step 4 – Evaluate Impacts and Document the Results 

For the control technologies determined to be commercially available and technically feasible, 

the affected facility must conduct the following analyses to select the control technology that 

meets the requirements of BART. 

The analysis evaluates four impacts that would potentially result from the installation of a control 

technology. 

Impact analysis part 1: Costs of compliance, 

Impact analysis part 2: Energy impacts,

Impact analysis part 3: Non-air quality environmental impacts, and 

Impact analysis part 4: Remaining useful life. 

Appendix Y to 40 CFR 51 presents detailed guidance for conducting the evaluation of each 

potential impact. The analysis presented later in this section for each available and technically 

feasible control technology identified for the BART eligible emission units follows these 

guidelines. 

4.2.5 Step 5 – Evaluate Visibility Impacts 

Once the facility has completed the steps outlined above and an available, technically feasible 

control technology has been selected, then the visibility improvements are evaluated in this final 

step. 

Baseline emissions and the visibility impacts are compared to the predicted visibility impacts 

from the emission sources with the control technology installed. If the net visibility 

improvement is less than that which would contribute to visibility impairment (as defined in the 

preamble to Appendix Y) then there is no need for the facility to implement the control 

technologies because the resulting visibility impacts would be negligible. 

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Appendix L.10 - 291 

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13 

4.3 BART Analysis for Recovery Boilers 

Blue Ridge operates two recovery furnaces at the Blue Ridge Canton Mill. Each unit is 

permitted to fire 121,000 pounds of black liquor solids per hour. The units are capable of firing 

fuel oil during startup, shutdown, and malfunction. Each unit is currently equipped with an 

electrostatic precipitator (ESP), and the emissions from each of these units exceed the PM 

control requirements of 40 CFR 63, Subpart MM (MACT II). 

It is important that the use and function of the recovery furnace in the pulp and paper process is 

properly understood. The recovery furnace performs the following functions: 

• Evaporates residual moisture from the black liquor solids, 

• Combusts organic constituents in the black liquor, 

• Reduces oxidized sulfur compounds to sulfide, 

• Recovers inorganic chemicals (smelt) in molten form. This smelt is dissolved in the smelt 

dissolving tanks and returned to the process, 

• Conditions the products of combustion to minimize chemical carryover, and 

• Generates additional steam for mill processes. 

The primary purpose of a recovery furnace is not to produce steam, but for chemical recovery 

that is inherent to the operation of the Kraft pulping process with steam a byproduct. 

The recovery furnaces emit PM, SO2, and NOx. Each of these units are equipped with an ESP 

that exceeds the particulate emission requirements of 0.044 gr/dscf at 8% O2 for MACT 40 CFR 

63 Subpart MM. Recent stack testing performed to demonstrate compliance with MACT 

Subpart MM showed particulate emissions of 0.004 gr/dscf at 8% O2 for No. 10 Recovery 

Furnace and 0.007 gr/dscf at 8% O2 for No. 11 Recovery Furnace. Therefore, potential retrofit 

control technologies for particulate matter emissions from the recovery furnaces were not further 

evaluated since the units are already equipped with the most stringent controls and the operation 

of these controls is required by the facility’s Title V Operating Permit. 

4.3.1 BART Analysis for NOx emission control

Compared to a typical power boiler, emissions of NOx from a recovery furnace are generally 

quite minimal. The minimal NOx emissions can be attributed to four main mechanisms within 

the furnace. 

• The as-fired nitrogen content of most black liquor solids is less than 0.2% by weight. 

• The temperature profiles within the furnace generally do not promote the formation of 

thermal NOx. 

• The introduction of combustion air within the furnace is staged. 

There are several NOx control technologies that are potentially applicable to combustion sources 

based on reviews of similar processes and a review of the RBLC database. 

1. Low NOx Burners (LNB) – The use of low NOx burners is a demonstrated technology 

installed on many fossil-fuel combustion sources. However, this is not a demonstrated 

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Appendix L.10 - 292 

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14 

technology for a recovery furnace. Black liquor has a large amount of water. 

Consequently, the drying, pyrolysis, and char burning of liquid droplets occurs over an 

extended trajectory from the liquor guns to the char bed. Therefore, the benefits of a low 

NOx burner would not be realized in a recovery furnace. Furthermore, the recovery 

furnace is already equipped with primary, secondary, and tertiary air which provides 

inherent NOx control. 

2. Flue Gas Recirculation (FGR) – FGR involves the recirculation of a portion of the 

exhaust gas back into the combustion zone of the furnace. This control technology is 

aimed toward minimizing the formation of thermal NOx. However, as previously stated 

thermal NOx emissions from a recovery furnace are minimal. Therefore, installation of 

this control technology would not result in significant NOx reductions and is not 

considered further. 

3. Water Injection – This control technology is generally applied to natural gas-fired boilers 

for the control of NOx emissions. The introduction of water droplets into the combustion 

zone of a recovery furnace could lead to an explosive condition inside the unit. 

Therefore, water injection is not technically feasible. 

4. Add-on NOx Controls – This category involves the evaluation of both Selective NonCatalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR). In the SNCR 

process, urea or ammonia would be injected into the recovery furnace. No long-term 

evaluations have been conducted for a SNCR installation on a recovery furnace. Since 

the primary purpose of the recovery furnace is chemical recovery there are concerns that 

the introduction of additional chemicals into the process could have a harmful effect on 

the quality of the smelt produced. 

SCR involves passing the exhaust stream over a catalyst to reduce NOx emissions. The 

SCR system can either be installed prior to the ESP (High Dust application) or after the 

ESP (either hot side or cold side). The problem associated with this control technology 

involves possible catalyst fouling from entrained particulate if the unit were installed 

prior to the ESP. If the SCR were installed after the ESP, the gas stream will be too cool 

to effectively react with the NOx without flue gas reheating. Therefore, both of these 

options are considered technically infeasible. 

5. Staged Combustion – This involves adding a quaternary zone of combustion air within 

the recovery furnace. There have been limited demonstrations of this technology on a 

short-term basis. A 20-40% reduction in NOx emissions was observed. Therefore, this 

control technology is the only option identified as technically feasible for NOx reduction 

from recovery furnaces and has been evaluated further as part of the BART process. 

Mill personnel investigated the potential installation of quaternary air within each recovery 

furnace along with the installation of new liquor fuel guns. Cost estimates provided by Mill 

personnel indicate that the total capital costs associated with the modification would be 

approximately $9 million for both furnaces. In addition to the capital and installation costs, each 

recovery furnace would be out of service for one month while the modification was being made. 

Therefore, during these periods, the pulp mill could only operate at one-half capacity and the 

mill would have to purchase dry furnish at a cost of approximately $23.1 million in order to 

maintain paper production. Therefore, the total costs associated with the implementation of this 

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Appendix L.10 - 293 

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15 

control technology on both furnaces are $32.1 million. The annualized costs for NOx removal 

were estimated to be $3,839,996 for each recovery boiler. 

Based on an expected NOx reduction efficiency of 40% (a reduction of 230 tons per recovery 

furnace), the cost effectiveness per ton of NOx removed using quaternary air would be 

approximately $16,700 per ton. 

There are no additional impacts anticipated from the modification (i.e., water, additional power, 

etc.). 

The anticipated visibility impacts from a 40% reduction in NOx emissions from the recovery 

furnaces were estimated to be a 0.371 deciview improvement over the current conditions. The 

cost of this retrofit would be extremely high, at $44,994/ton/dv. 

The number of days with an estimated visibility greater than 0.5 deciview impact at the baseline 

operating conditions was estimated to be 86 days at Shining Rock and 18 days at Great Smoky 

Mountains. The installation of quaternary air in the recovery furnaces would only slightly 

reduce the number of days greater than 0.5 deciview impact at Shining Rock to 82 days and 15 

days at Great Smoky Mountains. 

Based on the above analysis, theNCDAQbelieves that the installation of NOx reduction controls 

for the recovery furnaces is not economically feasible. 

4.3.2 BART Analysis for SO2 emission control 

The inlet loading of sulfur is significant, normally in the range of 3-5% by weight. One of the 

primary purposes of the recovery furnace is to recover and convert oxidized sulfur compounds to 

sulfide. The majority of this sulfur is contained in the smelt leaving the furnace; however, a 

small fraction of the compound can be emitted in the form of SO2. There are a number of factors 

which are thought to influence the formation of SO2 in the recovery furnace; however, a direct 

relationship has not been established. 

A review of the RBLC database shows that there are no add-on control technologies that have 

been installed solely for the control of SO2 emissions. 

An additional source of information on emissions controls is the National Council of Air and 

Stream Improvement (NCASI) Corporate Correspondents Memorandum CC 06-014 entitled 

“Retrofit Control Technology Assessment for NOx, SO2, and PM Emissions from Kraft Pulp and 

Paper Mill Unit Operations.” A copy of this memorandum is included in Appendix D. As the 

environmental control reference organization for the pulp and paper manufacturers, NCASI 

follows the industry closely and is aware of the control measures that are currently employed. 

This document further iterates that there are no control measures specific to SO2 employed by 

the pulp and paper industry on recovery furnaces. According to NCASI, the few wet scrubbers 

that have been installed on recovery furnaces in the pulp and paper industry have been installed 

for additional particulate control following an ESP (e.g., for PSD avoidance), although there is 

some residual SO2 removal from the units. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 294 

 December 17, 2007
Blue Ridge Paper Products BART determination 

16 

However, the installation of a wet scrubber following the ESP on a recovery furnace is 

technically feasible, although it would be a complicated and costly retrofit for the recovery 

furnaces at the Blue Ridge Canton Mill. Once a technically feasible control technology has been 

determined, it is necessary to begin evaluating the additional impacts as described in step 4 of the 

BART procedures. 

The first impact to be evaluated is the potential cost associated with the installation of the 

scrubber. Vendors were contacted by the mill for a similar project and given information 

regarding the composition of the gas stream and the estimated volumetric flow rate. The cost of 

a wet scrubber was obtained from Monsanto Enviro-Chem. Based on this budgetary capital cost 

estimate, additional expenses associated with installation of the device were estimated. The 

source of these estimates is both historical mill experience and EPA’s Control Cost Manual. It is 

important to note that the Blue Ridge Canton Mill was originally constructed in 1905, and 

subsequent modifications have left the facility extremely “land-limited.” The ESPs for the two 

furnaces are located on the top of the recovery building, but there is no room on the roof of this 

building for two scrubbers. Therefore, the installation of a new scrubber on each recovery 

furnace would require extensive piping and ductwork modifications. The closest location to the 

recovery furnaces for the possible installation of a scrubber would require over 300 feet of 

stainless steel ductwork including a bridge to elevate the ductwork over roadways. Additionally, 

a new fan would be required to move the exhaust through the new ductwork and scrubber to 

overcome the additional pressure loss. Not only would there be capital costs associated with the 

installation of a fan, but the current power distribution system is operating at maximum capacity 

and a new switch gear would be required. 

The expenses associated with the wet scrubber includes capital costs associated with the 

purchase and installation of the new equipment and the cost associated with the purchase of pulp 

to replace lost production during the period of construction. The capital costs for the installation 

of a wet scrubber achieving 90% SO2 removal from a recovery boiler was estimated to be 

$26,293,000, and annualized costs at $6,897,430. The cost effectiveness per ton of SO2 removed 

was estimated at $13,643 per ton. Incremental cost effectiveness per ton of pollutant removed 

was not calculated because only one control technology has been identified as technically 

feasible. 

Operation of a wet scrubber will have an impact on energy consumption and will have secondary 

environmental impacts to the air, water, and soil. Operation of the scrubber will require 

additional electricity. This power would either be generated onsite or be purchased from the grid 

and would have an associated air emissions impact from either the onsite boilers or the power 

generation facility located nearby. In addition, the wet scrubber system will require additional 

water usage and will generate gypsum (calcium sulfate) that will require solid waste disposal. 

As outlined in the BART evaluation process, the final step that must be conducted is the 

evaluation of potential improvements to visibility. 

The results of the visibility analysis resulting from the installation of wet scrubbers on the 

recovery boilers and the current configuration for the smelt dissolving tanks and the BLOX 

system demonstrates that the installation of wet scrubbers on the recovery furnaces does not 

result in a visibility improvement at the Shining Rock Class I area. This scenario actually causes 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 295 

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Blue Ridge Paper Products BART determination 

17 

a higher delta deciview impact than the modeled current conditions. The number of days with an 

estimated visibility greater than 0.5 deciview at the baseline operating conditions was 86 days at 

Shining Rock and 18 days at Great Smoky Mountains. The installation of wet scrubbers would 

actually increase the number of days greater than 0.5 deciview impact at Shining Rock to 91 

days. However, a slight decrease may be seen at Great Smoky Mountains with only 9 days 

greater than 0.5 deciview impact. 

Based on the fact that the installation of a wet scrubber for SO2 control is not economically 

feasible and would result in only a marginal visibility improvement at one Class I area and 

a degradation in visibility at another, retrofit controls are not warranted for SO2 emissions 

from the recovery furnaces. 

4.4 BART Analysis for Smelt Dissolving Tanks 

The smelt generated in the recovery furnaces is discharged into a tank where large chunks are 

broken into smaller pieces by a steam jet. Weak wash water is added to the vessel to create 

green liquor which is further processed in the causticizing system to create white liquor for reuse 

in the pulping process. There are minimal emissions of NOx, SO2, and particulate from the smelt 

dissolving tanks. Blue Ridge Paper does not have site-specific NOx and SO2 measurements from 

the smelt tanks, but is using published emission factors from NCASI Technical Bulletin 884 to 

estimate emissions of these compounds. As no combustion occurs in the smelt tanks, NCASI 

believes that the small emissions of NOx and SO2 sometimes measured may be a result of 

oxidation of ammonia emissions within the NOx analyzer and oxidation of sulfur in the smelt 

during smelt-water explosions. Each unit is currently equipped with a chevron mist eliminator 

for reduction of emissions of particulate and complies with MACT standards for PM. 

4.4.1 Bart Analysis for SO2 and PM Emissions 

A review of the RBLC database indicates that smelt dissolving tanks located at other pulp and 

paper facilities utilize proper operation and wet scrubbers for the minimization of particulate and 

SO2 emissions. However, emissions from these units are minimal and are emitted at relatively 

low velocities which limits the control technologies that are technically feasible. Blue Ridge 

personnel have investigated improvements to the current control system design that involve 

installation of “micro mist” nozzles to improve the PM control efficiency. Capital costs 

associated with the scrubber upgrades for a 50% removal in both PM and SO2 are estimated at 

$250,000 per scrubber, with an annualized cost of $197,862. The estimated cost effectiveness 

for 50% SO2 control is $301,160/ton SO2 removed. The estimated cost effectiveness for 50% 

PM control is $13,862. 

As was done for the previously evaluated technically feasible control technologies, the visibility 

improvements that may be obtained from modifications to the current smelt tank scrubbers was 

investigated. A 50 percent improvement over current SO2 and PM emissions would result in a 

0.029 deciview improvement could be seen after modifying the scrubbers. The cost is 

$10,384,813/ton/dv for SO2 and $478,016/ton/dv for particulate. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 296 

 December 17, 2007
Blue Ridge Paper Products BART determination 

18 

The number of days with an estimated visibility greater than 0.5 deciview impact at the baseline 

operating conditions is 86 days at Shining Rock and 18 days at Great Smoky Mountains. The 

installation of micromist scrubbers on the smelt tanks would only minimally reduce the number 

of days greater than 0.5 deciview impact at Shining Rock to 79 days and 17 days at Great Smoky 

Mountains. 

Based on the above analysis, the NC DAQ believes that the installation of retrofit controls on the 

smelt dissolving is not economically feasible. 

. 

4.4.2 BART Analysis for NOx emission control 

There are no control technologies to reduce NOx emissions that are available for installation on a 

smelt dissolving tank. A review of the RBLC database shows that only proper operation and 

good recovery furnace combustion techniques have been determined as BACT for NOx

emissions from smelt tanks. NCASI is not aware of any smelt tanks with NOx controls installed. 

Therefore, no further evaluation was conducted for NOx control technologies for the smelt 

dissolving tanks. 

4.5 BART Analysis for Black Liquor Oxidation System 

On April 15, 1998, the EPA promulgated National Emission Standards for Hazardous Air 

Pollutants (NESHAP) from the Pulp and Paper Industry (40 CFR 63, Subpart S). Under 

40 CFR 63.94, the North Carolina Department of Environment and Natural Resources (NC 

DENR) requested approval from EPA to implement alternative requirements in the form of 

permit terms and conditions instead of the requirements in 40 CFR 63, Subpart S. This alternate 

process is called equivalency by permit (EBP). The EPA has approved this request with an 

effective date of June 11, 2004. Blue Ridge Paper submitted an application on June 17, 2004 to 

request approval of an alternate compliance approach to that required in 40 CFR Subpart S for 

the high-volume, low-concentration (HVLC) sources (referred to as MACT I, Phase 2). 

This alternate compliance approach, which was approved by EPA on March 10, 2005, will allow 

the Blue Ridge Canton Mill to achieve a greater level of hazardous air pollutant (HAP) emission 

reduction, additional significant environmental benefits such as total reduced sulfur (TRS) 

compound emissions reductions, and community/industrial economic sustainability results not 

achieved under 40 CFR 63.443. 

 

 

In lieu of controlling pulp mill HVLC sources under 40 CFR 63.443, the Blue Ridge Canton Mill 

received authorization to achieve a greater level of HAP reduction by controlling emissions from 

the black liquor oxidation (BLOX) system in a new regenerative thermal oxidizer (RTO) 

equipped with a wet scrubber for SO2 control. The modeled SO2 emissions represent the vendorguaranteed emission rate at the scrubber outlet. PM and NOx emissions are minimized by proper 

operating of the RTO and combustion of natural gas as auxiliary fuel, and no further controls are 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 297 

 December 17, 2007
Blue Ridge Paper Products BART determination 

19 

feasible. The construction of the RTO/Scrubber has been completed and the equipment they 

were fully operational prior to the MACT compliance date of April 17, 2007. 

DAQ has determined that no further analysis of control technologies is required because the unit 

is already equipped with the most stringent controls as required by the MACT standards and 

permit limits are in place to ensure these controls are operated properly. Therefore, DAQ has 

determined that BART for the BLOX is no further controls.

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 298 

 December 17, 2007
APPENDIX A 

Response to EPA and NPS Comments on BART Permit Application 

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URS Corporation 

1600 Perimeter Park Drive, Suite 400 

Morrisville, North Carolina 27560 

Tel: 919.461.1100 

Fax: 919.461.1415

February 28, 2007 

Mr. Don Van der Vaart, PE, PhD 

North Carolina Department of Environment and Natural Resources 

Division of Air Quality 

1641 Mail Service Center 

Raleigh, North Carolina 27699 

Reference: Blue Ridge Paper Products, LLC 

 Canton, North Carolina 

 BART Control Technology Evaluation 

Dear Don: 

On behalf of Blue Ridge Paper Products, LLC (Blue Ridge), URS Corporation (URS) is 

pleased to submit the following responses to comments made by interested parties 

reviewing the Best Available Retrofit Technology (BART) Control Technology 

Evaluation submitted to the North Carolina Division of Air Quality (NCDAQ) on 

November 16, 2006. 

To facilitate review of our responses, we have included the commenter’s statement 

followed by our response in italics. Comments addressed in this correspondence include 

the following: 

1. January 31, 2007 letter from Kay T. Prince of the United States 

Environmental Protection Agency. 

2. February 7, 2007 letter from John Bunyak of the National Park Service, Air 

Resources Division. 

Once you have had the opportunity to review our responses, please do not hesitate to 

contact me at (919) 461-1520 with any additional questions or comments. 

Sincerely, 

Randall K. Taylor, CCM, QEP 

Air Program Manager 

CC: Paul Dickens, Blue Ridge 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 315 

 December 17, 2007
 1 

Enclosure No. 1 

1. EPA Comment - Pollution Prevention (P2) Options

When identifying all available retrofit control technologies, the "Guidelines 

for BART Determinations under the Regional Haze Rule" (BART 

Guidelines) clarify that consideration should be given not only to add-on 

controls but also improvement in the performance of existing controls and 

P2. The analysis does not discuss the facility's evaluation of any P2 options 

for the five BART-eligible units, with the exception of installation of 

quaternary air on each recovery furnace (RF). 

Blue Ridge Paper Response 

The BART-affected units at Blue Ridge Paper Products Inc. (Blue Ridge) 

are Recovery Furnaces No. 10 and 11, Smelt Dissolving Tanks No. 10 and 

11, and the Black Liquor Oxidation System. It is important to note that the 

very nature of these units is pollution prevention. The Kraft pulping 

process seeks to maximize chemical and energy recovery from the pulping 

process. By maximizing the recovery of color materials and lignin present 

in the wood fiber, the facility is minimizing the amount of fossil fuel 

combustion required to meet the steam and energy demands of the mill. 

Furthermore, in conducting research on the control technologies available 

for the BART-affected units, Blue Ridge relied on information compiled by 

the National Council for Air and Stream Improvement (NCASI) through 

Corporate Correspondents Memorandum CC 06-014 entitled “Retrofit 

Control Technology Assessment for NOx, SO2, and PM Emissions from 

Kraft Pulp and Paper Mill Unit Operations.” As the environmental control 

reference organization for the pulp and paper manufacturers, NCASI 

follows the industry closely and is aware of the control measures that are 

currently employed. The technologies identified in this memorandum were 

evaluated for applicability none of which included pollution prevention 

technologies. 

The comments provided by EPA also focused on information available in 

"Assessment of Control Options for BART Eligible Sources," prepared by 

NESCAUM, for the Mid-Atlantic/Northeast Visibility Union Regional 

Planning Organization. Review of this document only identified one 

additional control option for the reduction of sulfur dioxide from the 

Recovery Furnaces. That option is to reduce liquor sulfidity in the black 

liquor solids. Sulfidity is the ratio of Na2S to the active alkali, where active 

alkali is the sum of sodium hydroxide and Na2S. The Blue Ridge recovery 

cycle has been balanced with a target sulfidity of 24-26%. Reducing the 

liquor sulfidity can adversely affect pulp quality and the cooking reaction 

rate. Therefore, reducing liquor sulfidity is not a viable option for the Blue 

Ridge Mill. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 316 

 December 17, 2007
 2 

2. EPA Comment - Process Changes to Reduce Formation of Emissions from 

RFs

Although Table 4-1 indicates that several Kraft pulp and paper mills utilize 

good combustion control practices to minimize sulfur dioxide (SO2)

emissions from their RFs, there is no discussion of what options may exist 

for making process changes, such as improved furnace design and operation, 

to limit the formation of SO2 in each RF. An effective approach to 

minimizing the formation of SO2 in the RFs would be to practice high dry 

solids firing combined with a modern air system to promote efficient 

mixing. Examples of process changes which have been demonstrated are 

identified in section 5.3.1 of "Assessment of Control Options for BART 

Eligible Sources," prepared by NESCAUM, for the Mid-Atlantic/Northeast 

Visibility Union Regional Planning Organization: 

http://www.nescaum.org/documentslbart-resource-guide/. These examples 

include optimizing liquor and combustion air properties and firing patterns 

to maintain uniform temperatures in the lower part of the RF in order to 

reduce SO2 emissions, and reducing liquor sulfidity to reduce SO2

emissions from the RFs. 

Blue Ridge Paper Response

The referenced document indicates that SO2 emissions from a recovery 

furnace are dependent on the following: sulfidity, heating value, solids 

content, combustion air and liquor firing patterns, furnace design features, 

furnace load, auxiliary fuel use, and stack gas oxygen content. As 

mentioned in the response to comment No. 1, the Blue Ridge recovery cycle 

has been balanced with a target sulfidity of 24-26%. Reducing the liquor 

sulfidity can adversely affect pulp quality and the cooking reaction rate. 

Therefore, reducing liquor sulfidity is not a viable option for the Blue Ridge 

Mill. 

The recovery furnace design at Blue Ridge includes direct contact 

evaporators (DCE) proceeded by Black Liquor Oxidation (BLOX) for 

recovery furnace odor control. In this configuration, the design dry solids 

firing rate in the recovery furnace is 60 to 65 percent. There is a about a 5 

percent loss of Btu heating value in the black liquor due to BLOX. Newer 

and larger capacity recovery furnaces use non-contact evaporators (NCE), 

do not have the BLOX process and have a design dry solids firing rate of 70 

to 75 percent. These newer NCE recovery furnaces include quaternary air 

and may have a lower NOx emission rate than the DCE recovery furnaces 

at Blue Ridge Paper. Conversion from DCE to NCE involves an entire 

furnace rebuild and reconfiguration is not a practical upgrade option. For 

the recovery furnace configuration at Blue Ridge Paper, the design dry 

solids firing rate is optimized. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 317 

 December 17, 2007
 3 

Modifications that would change the firing pattern and maintain uniform 

temperatures in the lower part of the recovery furnace are very similar to 

the changes proposed for the installation of quaternary air and new liquor 

guns for the reduction of NOx emissions. Total capital investment for the 

modification was in excess of thirty million dollars and the reduction in 

sulfur dioxide emissions from the change would be minimal. The majority 

of sulfur entering a recovery furnace leaves with the smelt. 

3. EPA Comment: Control Option Alternatives

The document states that installation of add-on SO2 controls on the RFs 

results in lower stack heights and a higher modeled delta deciview (dv) than 

current conditions due to decreased dispersion associated with scrubber' 

exhaust characteristics. (Executive Summary) We believe this may be due 

to the effects of cooling the exhaust stream. The analysis does not discuss 

whether good engineering practice (GEP) was considered in the 

development of the new stack height for this SO2 control. 

Blue Ridge Paper Response 

As stated in the document, the increased delta deciview from the 

installation of a scrubber on the recovery furnace exhaust is due to a cooler 

plume. A GEP analysis was performed for the facility including the 

modeled scrubber stack and all stack heights included in the modeling 

analyses meet the GEP modeling requirements. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 318 

 December 17, 2007
 4 

4. EPA Comment - Lost Production Costs

 

There is no indication of whether the facility considered ways to mitigate 

costs attributed to "Lost Production" listed in Table 4-2 (pulp purchase of 

$5,390,000 plus $975,843 for lost power generation per RF) and Table 4-4 

($11,550,000 for pulp purchase for 30 days downtime per RF). For 

example, the effects on costs in Tables 4-2 and 4-4 if potential controls 

were installed during an already planned plant shutdown for maintenance, 

or when one of the RFs is off-line, should be addressed. Also, it is unclear 

why one month is needed for each RF retrofit to install a quaternary air 

system, which results in significant lost production costs of purchased pulp 

in Table 4-4. 

Blue Ridge Paper Response

The recovery furnaces at Blue Ridge are scheduled for a 5-day shutdown 

once per year. Additionally, each unit undergoes a one-day shutdown 

every 15 to 20 weeks. Each of the recovery furnaces routinely operates at 

maximum capacity to meet the production demands of the mill; therefore, 

there are not significant blocks of time to conduct the modification when 

one unit is off-line. 

The installation of quaternary air would also require installation of new 

liquor guns to improve fuel bed distribution and the furnaces must also 

undergo a complete rebalancing of the air system. The air system is 

currently run by a forced-draft steam turbine fan that was originally 

installed with the recovery furnace. This technology will require 

additional time to obtain optimum air flows. Furthermore, all of the 

modifications must be completed when the recovery furnace is shut-down, 

unlike the installation of a scrubber system, where many of the components 

can be fabricated prior to shutting down the recovery furnace. 

The recovery furnace is the heart of the Kraft pulping process. The black 

liquor recovery process is continuous and the storage capacity to continue 

pulp operations during a recovery furnace outage is very limited – one day 

a most. When a recovery furnace goes down, black liquor is not recovered 

and the pulping process stops. This is the reason that during an extended 

recovery furnace outage, Kraft pulp is not manufactured. To keep paper 

machines running, dry furnish Kraft pulp must be purchased from outside 

sources, at a significant cost premium compared to slush pulp manufactured 

on-site. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 319 

 December 17, 2007
 5 

EPA Comment

When major work is done at a pulp and paper mill, the mill can often 

increase production significantly prior to and following the shutdown to 

offset any lost production. It is not clear whether the facility considered this 

possibility and its effects on the lost production costs. 

Blue Ridge Paper Response

As previously mentioned, the recovery furnaces at Blue Ridge are 

consistently operated at maximum capacity to meet current production 

demands. Therefore, it would not be possible to operate the units at an 

increased rate prior to and following the planned shutdown. 

Furthermore, as mentioned in Comment No. 3, the available capacity for 

black liquor storage is limited to a maximum of one-day, thereby limiting 

the potential operating scenarios. 

EPA Comment

To minimize lost power generation costs listed in Table 4-2, it is not clear 

whether the facility considered achieving some additional power 

generation from its power boilers during the retrofit period to offset the 

losses. The mill has five power boilers and generally a pulp and paper mill 

with multiple power boilers does not operate all the boilers at maximum 

capacity at the same time. 

Blue Ridge Paper Response

When a recovery furnace is down, approximately 300,000 lbs per hour of 

lost steam production from burning black liquor solids must be 

supplemented by burning additional coal in the mills power boilers and by 

buying additional power from the commercial grid. Blue Ridge generates 

most, but not all, of its electrical power needs. When steam production is 

down during a recovery furnace outage, the mix of mill generated and 

purchased power changes. Steam production is shifted from electrical 

power generation to the paper machines and more electricity is purchased 

from the commercial grid. The cost of lost power generation in the cost 

estimates represents the additional cost to supply the energy needs of the 

Canton Mill paper machines when free steam energy from burning black 

liquor solids is not available due to recovery furnace outage. 

5. EPA Comment - Contingency Costs in Table 4-2

In Table 4-2, the contingency factor of 15 percent should be justified. It is 

our understanding that a factor no higher than 10 percent would be 

considered acceptable for wet scrubber installation on a RF at a pulp and 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 320 

 December 17, 2007
 6 

paper mill, and would be consistent with standard industry practice. Also, 

since this is a "turnkey" installation, it is unclear why such a high 

contingency factor is projected. Since no distinct retrofit factor is identified, 

it is possible that the facility may have merged the retrofit factor with the 

contingency factor, resulting in the 15 percent contingency factor used in 

Table 4-2. The EPA Air Pollution Control Cost Manual (Cost Manual), 

EPA/452/B-02-001, January 2002, distinguishes between the contingency 

and retrofit factors and recommends keeping them separate as follows. A 

retrofit factor should be reserved for those items directly related to the 

demolition, fabrication, and installation of the control system, and should 

not be double-counted again as part of a contingency factor. In this case, the 

additional ductwork, new stack, fan, and switch gear should be assigned to 

the retrofit factor since they are a necessary part of installing this control on 

an existing unit. A contingency factor should be applied to only those items 

that could incur a reasonable but unanticipated cost increase (i.e., outside of 

the contractor's control), and are not directly related to the retrofit factor 

elements just described. (See pages 2-28 to 2-30 in subsection 2.5.4.2 of 

Chapter 2, Cost Estimation: Concepts and Methodology," (dated January 

2002) in Section 1 of the Cost Manual.) 

Blue Ridge Paper Response

The contingency factor presented in Table 4-2 did include the retrofit factor. 

Please refer to Attachment 1 of this correspondence for an updated 

calculation of costs associated with the installation of a wet scrubber on a 

single recovery furnace. As stated in EPA’s Cost Control Manual: 

“Probably the most subjective part of a cost estimate occurs when the 

control system is to be installed on an existing facility. Unless the 

original designers had the foresight to include additional floor space 

and room between components for new equipment, the installation of 

retrofitted pollution control devices can impose an additional expense to 

“shoe-horn” the equipment into the right locations.” 

“The magnitude of the retrofit factor varies across the kinds of estimates 

made as well as across the spectrum of control devices. At the study 

level, analysts do not have sufficient information to fully assess the 

potential hidden costs of an installation. At this level, a retrofit factor of 

as much as 50 percent can be justified.”

EPA Comment

The contingency factor calculations in Table 4-2 are not based on the 

correct line item costs and need to be redone. The factor was applied to the 

scrubber "installation cost," additional ductwork, new stack, fan, and switch 

gear, and lost power generation. This is incorrect for two reasons. First, the 

"installation cost" listed for the wet scrubber appears to also include the cost 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 321 

 December 17, 2007
 7 

of the equipment. The contingency factor should be applied to the 

purchased equipment costs. However, installation costs are not to be 

included in contingency factor calculations. This should be corrected. 

The second reason the calculations are incorrectly applied is that the "14 

days lost power generation" cost of $975,843 should not be included in the 

"contingency" cost calculations. The Cost Manual describes contingencies 

as a category that covers unforeseen costs that may arise, such as delays 

encountered in start-up and increases in field labor costs. (See page 2-5, of 

Chapter 2, "Cost Estimation: Concepts and Methodology," (dated January 

2002) in Section 1 of the Cost Manual.) The lost power generation cost in 

Table 4-2 refers to power that cannot be produced during the 14-day retrofit 

period for each RF, which is a planned event, not an unforeseen cost. We 

note that lost production in terms of pulp purchase correctly does not appear 

to be included in the contingency cost calculations. 

Blue Ridge Paper Response

The terminology used in line one of the calculations was revised to make it 

clearer. The cost shown is indeed the purchased equipment cost. In 

responding to these comments, vendors were contacted to provide 

additional information for the exact situation at Blue Ridge. All of the 

correspondence is included in Attachment 1 to this letter and the costs are 

outlined in the revised Table 4-2. Furthermore, the contingency percentage 

was not applied to purchased electrical costs in the revised calculations. 

EPA Comment - RF Wet Scrubber Cost Considerations

Table 4-2 describes costs with wet scrubber installation on one of the RFs. 

Given the relatively high nature of costs for the modifications to existing 

ductwork and installation of a new stack, fan, and switch gear (totaling to 

$11,945,605), consideration should be given to other, more cost effective 

options. For example, the feasibility and cost effectiveness of moving the 

road or other buildings to allow closer location of the wet scrubbers and 

avoid extensive ductwork could be considered. 

Blue Ridge Paper Response

To assist in understanding the unique situation at Blue Ridge, we have 

included an aerial photograph of the site. As you will note, the mill is 

located in the heavy industrial area within the Town of Canton. Mill 

property is extremely limited and the options proposed in the comments are 

not feasible. The roads cannot be moved due to fire regulations and there 

are no buildings to be moved. 

BART Related Documentation 

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Appendix L.10 - 322 

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Figure No. 1 – Overview of the Canton Mill 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 323 

 December 17, 2007
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Figure No. 2 – Overview of Canton Mill Recovery Furnaces 

EPA Comment

It would be helpful to have more information on the design of the wet 

scrubber analyzed. We are aware of at least one kraft pulp mill (i.e., the 

James River Camas Mill in Washington State) that has installed a crossflow, packed bed scrubber following the RF electrostatic precipitator 

(ESP) as part of an energy recovery system. At that mill, caustic (sodium 

hydroxide or NaOH) is added to the scrubber liquid and the mill has 

claimed SO2 reductions as a result. It is not clear whether the facility has 

considered installing a similar system. 

Blue Ridge Paper Response

There are many scrubber configurations commercially available. We have 

evaluated the MECS Reverse Pulse Jet system. While the cost for the 

scrubber itself is significant, the largest cost contribution is from the 

installation of ductwork to route the exhaust to the unit and modifications 

to the fan and switch gear. These costs would be approximately the same 

no matter the scrubber design. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 324 

 December 17, 2007
 10 

EPA Comment

There is no discussion indicating whether the facility considered use of 

caustic as the scrubbing reagent instead of limestone. Kraft pulp mills have 

a relatively inexpensive supply of caustic available since it is used in the 

cooking liquor, which can make caustic more economical than limestone. 

Also, the use of caustic eliminates the material handling and space 

requirements associated with lime or limestone systems. Lime and 

limestone processes produce a sludge which requires dewatering and 

landfilling. Wet caustic processes produce a neutral pH solution which can 

be pumped to the existing mill wastewater treatment system for disposal. 

Thus, the estimated annual costs would be greatly reduced by using a 

caustic scrubber instead. 

Blue Ridge Paper Response

Annual reagent costs for the use of limestone in the scrubber have been 

estimated at less than $10,000 dollars per year and landfill disposal costs 

are also less than $10,000 dollars per year. As stated previously, the 

capital investment required for the installation of a scrubber is the primary 

driver making the option economically infeasible. However, to address 

concerns raised in the comments, the revised scrubber cost estimate has 

been estimated assuming a caustic solution is used in the unit. 

However, all of the caustic required for the scrubber must be purchased 

and a vessel to store the material must be installed. The Blue Ridge mill is 

caustic limited due to lime kilns that are undersized. The mill already buys 

caustic for make-up in the white liquor system. 

EPA Comment

We suggest that the State closely evaluate the electricity costs for the RF 

scrubber. For example, the basis for the 746 kilowatt-hours used in Table 

4-2 should be discussed. Other considerations should include the assumed 

pressure drop of the scrubber, and what portion of the electricity costs are 

associated with the use of limestone rather than caustic (e.g., limestone 

preparation and slurry mix system, gypsum filter system, etc.). 

Blue Ridge Paper Response

The fan rating is estimated at 1,000 hp. Mill specific electricity costs are 

$319.00 per hp-yr. 

7. EPA Comment - RF Quaternary Air System Cost Considerations 

The capital cost estimate of $9 million (includes quaternary air and new 

liquor guns for both RFs) cited on page 4-7 and detailed per RF in Table 4-4 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 325 

 December 17, 2007
 11 

seems extremely high. In 2001, the American Forest and Paper Association 

(AF&PA) commissioned BE&K Engineering to develop emissions control 

cost estimates for a variety of scenarios at pulp and paper mills, including 

the addition of a quaternary air system for reducing NOx emissions from a 

RF. The model RF was larger than the RFs at Blue Ridge. Based on the 

AF&PA analysis, the capital cost for the quaternary air system was 

$624,000 per furnace. Disregarding differences in size and base years, the 

total cost would be approximately $1.2 million for two RFs, which is 

considerably less than the $9 million quoted on page 4-7. It would be 

helpful if Blue Ridge could provide an estimate just for the addition of the 

quaternary air system, omitting the costs of the new liquor guns, to provide 

for a better comparison of costs. 

Blue Ridge Paper Response

The cost estimate for the installation of quaternary air on the recovery 

furnaces is an estimate provided by an outside vendor. In order to achieve 

the discussed NOx reductions, quaternary air alone would not be sufficient. 

The liquor guns must also be replaced to improve fuel bed distribution. 

Furthermore, the furnaces must also undergo a complete rebalancing of the 

air system after the modification. The air system is currently run by a 

forced-draft steam turbine fan that was originally installed with the 

recovery furnace. This older technology will be more costly to balance 

than current systems. 

The original Kraft pulp recovery furnace installations at Blue Ridge had 2-

stage combustion. These are medium-sized furnaces by today’s standards, 

but at the time of installation in the 1960s and early 1970s these were large, 

state of art units. The furnaces were upgraded for BLOX and for tertiary air 

in the 1980s. The tertiary air upgrade was complex and took most of the 

space available for any future upgrade to combustion staging. Champion 

International, the predecessor company to Blue Ridge, studied various 

options for combustion control improvements to the Canton Mill recovery 

furnaces in the 1980s. The cost of various upgrade options were estimated 

including quaternary air and alternative configuration black liquor fuel 

guns. However, the upgrade to tertiary air and BLOX that were undertaken 

were the only practical modifications for the size and configuration of these 

furnaces. 

In preparation for BART, Blue Ridge worked with Jansen Technologies, a 

recovery furnace combustion consulting firm, to develop order of magnitude 

cost estimates for addition of quaternary air and alternative configuration 

black liquor fuel guns. The available Champion International engineering 

evaluations from the 1980s were reviewed and the previous conclusions 

were validated - addition of quaternary air is not a simple add-on as 

suggested by EPA comments. Addition of quaternary air to the existing Blue 

Ridge recovery furnaces will require removing all the existing combustion 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 326 

 December 17, 2007
 12 

air staging equipment, modifying and moving the existing combustion air 

ports in the furnace (all ASME code vessel welding) and reinstallation of the 

existing along with new combustion air ductwork and fans. New 

combustion air controls are necessary. The design considerations for 

changing black liquor fuel guns are similar. This is not a simple swap out 

of equipment. Alternative black liquor fuel guns will require a complete 

reworking of the recovery furnaces above the smelt bed. New fuel gun 

combustion controls are also required. 

The order of magnitude cost of $4.5 million each ($9 million total) for 

retrofit of the Blue Ridge recovery furnaces to quaternary air and 

alternative fuel guns is based on the above considerations developed by 

Blue Ridge in consultation with Jansen Technologies. Please note that this 

value is only the construction portion of the cost, lost production and lost 

power generation are additional costs to obtain total capital investment. 

The time estimate for retrofit of one month per recovery furnace is also 

based on this engineering review. The retrofit is not a simple add-on or 

swap out of equipment. Retrofit will require a major reworking of the entire 

furnace combustion air and liquor firing equipment and controls. 

8. EPA Comment - Supporting Documentation for Cost Analyses

To aid review of the document, we suggest that the vendor quotes, data 

estimates, and relevant portions of the presentation identified in the cost 

references [1], [6], [7] in Tables 4-2 be included in this document. Also, it 

is unclear where the e-mail described in Reference 1 of Table 4-2 is 

located in the documentation so we were unable to review this reference. 

Blue Ridge Paper Response

Due to the limited time we had to prepare the BART evaluation, the best 

information available at the time was used preparing the original cost 

analysis. Attachment 1 to this letter contains an updated Table 4-2 with 

more detailed information and copies of more recent vendor 

correspondence. 

EPA Comment

Reference 7 of Table 4-2 indicates that costs for wet scrubber installation 

are based on a vendor quote for an "original recovery furnace," which does 

not appear to be either of the RFs subject to this BART analysis. Although 

the facility adapted the cost estimate to the size of the No. 10 RF, we 

question why the facility did not seek a vendor quote for wet scrubber 

installation specific to the RFs subject to this BART analysis (i.e., No. 10 

and No. 11). We recommend that a copy of the quote be included in the 

documentation to provide information such as what year the quote for the 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 327 

 December 17, 2007
 13 

original RF was received. 

Blue Ridge Paper Response

Because of time constraints in the preparation of the original document, it 

was not possible to obtain a vendor quote for the specific installation at 

Blue Ridge. However, in responding to these comments we have contacted 

vendors and included their correspondence in Attachment 1 to this letter. 

EPA Comment

Reference 7 of Table 4-2 also states that, "Cost was escalated using EPA's 

0.6 rule ... " The "0.6 rule" referenced is to be used for a rough estimate 

calculation of costs only and should not be relied upon for this BART 

analysis to estimate installation costs of the wet scrubber. Also, we are not 

aware that the "0.6 rule" is part of an EPA document. However, the book, 

Plant Design and Economics for Chemical Engineers by Peter and 

Timmerhaus (Fifth Edition) does discuss this "rule of thumb" and calls it the 

"six-tenths-factor" rule. (Peters, Max S., Timmerhaus, Klaus and West, 

Ronald. Plant Design and Economics for Chemical Engineers, Fifth 

Edition, McGraw-Hill, 2002, p. 169.) 

Blue Ridge Paper Response

While the six-tenths rule may not be correctly described as an “EPA Rule,” 

the concept is frequently used in EPA documents. Furthermore, the Cost 

Control Manual states the following: 

“Study-level estimates are acceptable for regulatory development 

because they represent a compromise between the less accurate orderof-magnitude and the more accurate estimate types.” 

A “study” level estimate is defined as a cost estimate with an uncertainty of 

+/- 30%. Therefore, it is Blue Ridge’s position that without having sitespecific design data which would be costly to obtain, the use of the sixtenths factor to adjust costs is appropriate since the purpose of this effort is 

regulatory applicability. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 328 

 December 17, 2007
 14 

9. EPA Comment - Capital Recovery Factor (CRF) Calculations

The facility should justify its capital recovery cost assumptions of an 

equipment life of 10 years with an interest rate of 15 percent listed under 

"Indirect Annual Costs" in Tables 4-2, 4-4, and 4-6. For capital recovery 

costs on wet scrubbers for acid gas, the EPA Cost Manual and EPA’s 

Technical Support Document: Chemical Recovery Combustion Sources at 

Kraft and Soda Pulp Mills (EPA-453/R-96-012, October 1996) presume a 

CRF based on a 15- year control equipment life and an interest rate of seven 

percent. Note that changing the assumptions about equipment life and 

interest rates to this presumptive value significantly decreases the 

annualized cost estimates. 

Blue Ridge Paper Response

Please refer to the following excerpt from page 2-13 of EPA’s Cost Control 

Manual: 

“Analysts use the interest rate to estimate the time value of money. It 

can be thought of as a return on investment or the cost of borrowing. 

The interest rate employed in this Manual differs from that used in nongovernmental financial analyses. It represents a social interest rate

established by the Office of Management and Budget (OMB) for the 

comparison of public policy issues. 

OMB sets the social interest rate for governmental analyses and it is 

currently set at seven percent. 

However, the social rate of interest is not appropriate for industry. 

When choosing between alternative air pollution control devices, the 

industrial planner must not only take into consideration the costs of 

each device, they must also understand how the cost of each device fits 

into the financial structure of their business. Furthermore, a number 

of air regulations allow sources of pollution to petition for extensions on 

deadlines, variances from the regulation, or exemption from installing 

control devices, based upon the economic impact that equipment would 

have upon the source. In these cases, the source may find it useful to 

apply their own interest rate to the calculation of control costs. 

Common interest rates used by industry and accepted by the EPA for 

source petitions include the business’ current borrowing rate, the 

current prime rate, and other acceptable industrial rates of return.”

The application of a 7% interest rate is not appropriate for this 

analysis, and furthermore, the EPA Cost Control Manual does not 

require the use of 7% as discussed above. The 15% rate is being used 

to account for the project costs as well as for the lost capital available for 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 329 

 December 17, 2007
 15 

funding other projects that could have positive return on investment at the 

mill. The recovery furnaces are currently more than 40 years old, 

assuming a useful life of 15 years would not be appropriate for this 

application. Therefore, all calculations have been completed using 10 

years. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 330 

 December 17, 2007
 16 

Enclosure 2 

1. EPA Comment

Table 5-1 indicates a 31.25-meter decrease in the stack heights for the No. 

10 and 11 RFs' stack for Scenarios 2 and 5. It is unclear why a decrease in 

stack height is required or if this is a typographical error. Also, the analysis 

does not discuss whether GEP was considered in the development of the 

new stack height for this SO2 control. According to Table 5-1, the modeled 

location of the stacks has not changed from the current location. Table 5-4 

indicates that the maximum visibility impact has shifted slightly to another 

geographical location in the Shining Rock and Great Smoky Mountain 

Class I areas. With decreased SO2 emissions from installation of the 

scrubber, the expected result is that the visibility impact should also 

decrease. The analysis should provide more discussion on how and where 

the visibility increases occurred in the Class I areas in addition to providing 

the maximum delta visibility impact and explain why a decrease in stack 

heights is necessary. 

Blue Ridge Paper Response

The new scrubber location proposed is approximately 300 feet from the 

current recovery furnace exhaust location. Since the CALPUFF model is 

evaluating long-range transport effects, moving the stack 300 feet on the 

property would have a negligible impact on long-range transport. The 

stack height selected is based on the design of the new RTO stack height and 

the cost to install this stack was used in the cost analysis for the scrubber. 

The cost to install the new stack at the modeled stack height is $8,147,189. 

The cost to install a 300 foot stack would be $15,750,000. This would 

further decrease the cost effectiveness of the scrubber from $12,177 per ton 

to $15,372 per ton. 

It should be noted that while SO2 emissions from the recovery furnaces are 

lower after the installation of a scrubber, the resulting exhaust plume is 

emitted at a much lower temperature, thereby causing a reduction in 

dispersion. 

2. EPA Comment

The NOx emissions used in the baseline (i.e., Scenario 1) modeling was 

based on a February 1999 stack test. There is no discussion of why data 

from this year was used to the exclusion of data from other years. Such 

discussion should include such items as stack test data availability from 

other years and how this ensures that the maximum 24-hr emission rate for 

the 2001-2003 period was developed. We encourage the State to review 

these data to ensure the assumptions supporting the emission rates are 

correct and the supporting documentation is submitted. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 331 

 December 17, 2007
 17 

Blue Ridge Paper Response

The best available data regarding emissions of NOx from a recovery 

furnace were used in the analysis. Stack testing was only conducted at the 

facility during 1999 and no subsequent testing has been required. This 

emission factor is the same value as is used in the preparation of the Annual 

Air Emissions Inventory. 

The other known source of NOx emissions data from recovery furnaces 

comes from NCASI Technical Bulletin No. 884. However, the test data 

presented in this document is the result of only one test run and is lower 

than the value used in the modeling. Therefore, this data was excluded 

from the BART evaluation. 

3. EPA Comment 

A vendor guarantee was used to set the emission rate for the black liquor 

oxidation system (BLOX) regenerative thermal oxidizer (RTO) provided in 

Table 5-2 (reference 3). We suggest that the referenced guarantee be 

included in the document and recommend that the State carefully evaluate 

this rate in conjunction with the specified operating parameters to ensure 

appropriate values are being used in the BART modeling. 

Blue Ridge Paper Response

Blue Ridge Paper submitted an application on June 17, 2004 to request 

approval of an alternate compliance approach to that required in 40 CFR 

Subpart S for the high-volume, low-concentration (HVLC) sources (referred 

to as MACT I, Phase 2). This alternate compliance approach was approved 

by EPA on March 10, 2005. All the referenced vendor guarantee 

information was submitted along with the Equivalency-by-Permit 

application. This is located in the NCDAQ files, however, Blue Ridge could 

provide another copy if needed. 

4. EPA Comment 

It may appear that the visibility improvements from the various control 

scenarios assessed do not indicate a desired level of benefit at two of the 

five Class I areas, but the other three Class I areas being affected by the 

facility could also be considered in the determination. 

Blue Ridge Paper Response

There are five (5) Class I areas within 300 km of the milll: Shining Rock, 

Linville Gorge, Cohutta, Joyce Kilmer/Slickrock, and the Great Smoky 

Mountains. Shining Rock is located approximately 11 kilometers south of 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 332 

 December 17, 2007
 18 

the mill, the Great Smoky Mountains National Park is 22 kilometers west, 

Linville Gorge is 89 kilometers northeast, Joyce Kilmer/Slickrock is 

99 kilometers west southwest, and Cohutta is located approximately 161 

kilometers southwest of the mill. 

The BART exemption modeling submitted to the NCDAQ on April 27, 2006 

indicated that modeled values would be greater than 0.5 dv at the Great 

Smoky Mountains and Shining Rock. Modeled values were less than 0.5 dv 

at the other Class I areas and are deemed insignificant based on EPA’s 

guidance regarding single source contribution values. Given that there are 

five control option scenarios that required modeling for the BART 

evaluation, modeling was performed for the two Class I areas where 

previous modeling indicated values greater than 0.5 dv. 

5. EPA Comment 

Addition of a wet scrubber should also reduce fine particulate matter 

(PM2.5), including condensable PM, which is not controlled by the ESP. 

The impact of additional PM control achieved by the scrubber (for scenario 

2) should be considered. The modeling results presented indicate fine PM 

has a limited impact on the modeled extinction (i.e., 9.51 percent and 18.6 

percent of the modeled extinction for the baseline and Scenario 2 

conditions, respectively, for Shining Rock). Also, the PM emissions are 

based on the most recent compliance test. These data likely represent the 

best ESP operating conditions, which may not be representative of ongoing 

emissions. 

Blue Ridge Paper Response

Installation of a wet scrubber on the recovery furnaces would follow the 

electrostatic precipitators already installed on the units. Appendix Y to 40 

CFR 51 states the following: 

“If you find that a BART source has controls already in place which are 

the most stringent controls available (note that this means that all 

possible improvements to any control devices have been made), then it is 

not necessary to comprehensively complete each following step of the 

BART analysis in this section. As long as these most stringent controls 

available are made federally enforceable for the purpose of 

implementing BART for that source, you may skip the remaining 

analyses in this section, including the visibility analysis in step 5.” 

Recent stack testing performed to demonstrate compliance with MACT II 

showed emissions of 0.004 gr/dscf at 8% O2 for No. 10 Recovery Furnace 

and 0.007 gr/dscf at 8% O2 for No. 11 Recovery Furnace. The purpose of 

the stack test was to demonstrate compliance with MACT emission limits at 

a level that represents at least 90 percent of capacity. Therefore, during the 

test, the mill was operated at high capacity and Blue Ridge continues to 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 333 

 December 17, 2007
 19 

operate the recovery furnaces under the conditions during the test to ensure 

on-going compliance. 

Therefore, potential retrofit control technologies for particulate matter 

emissions from the recovery furnaces was not further evaluated since the 

units are already equipped with the most stringent controls and the 

operation of these controls is required by the facility’s Title V Operating 

Permit. 

Although the installation of a scrubber would provide some additional 

particulate control, the loading to the device would be minimal as shown by 

the test results provided above, therefore, the additional particulate control 

from the scrubber would be minimal. 

6. EPA Comment

The State might consider giving a second look at the model inputs for 

PM emissions and the resulting visibility impacts for baseline conditions 

and scenarios No 2 and No 5 for two reasons. One reason to reconsider 

the PM inputs into the modeling is that the PM emissions are based on 

the most recent compliance test (as noted above in item number 5). 

These data likely represent the best ESP operating conditions, which 

may not be representative of ongoing emissions. 

Another reason to possibly reconsider the PM data and modeled impacts 

is that there are ongoing discussions taking 'place between EP A and the 

pulp and paper industry (AF&P NNCASI) related to measurement of 

PM2.5 emissions. The current use of EPA Method 202 by the industry 

appears to be underreporting PM2.5 emissions, specifically condensable 

PM2.5. In some cases, the condensable PM is analyzed to determine the 

elemental composition and it is assumed that all of the sulfates found in 

the condensable PM are "artifacts" resulting from conversion of SO2 to 

sulfates (i.e., to SO3 and then to H2SO4). The reported condensable PM 

is "corrected" by subtracting the sulfate fraction from the total 

condensable PM emissions. This "correction" results in biasing the 

measured emissions low. It is not clear whether this type correction was 

done for the reported emissions used in this modeling analysis. The State 

may want to clarify how EP A Method 202 was used in the measurement 

of PM2.5 emissions. For more information on this method, go to: 

http://www .epa.gov/ttn/emc/methods/method202.html. 

Blue Ridge Paper Response

The particulate test values used for the modeling analyses are in 

accordance with North Carolina Division of Air Quality guidance for 

Annual Air Emissions reporting purposes. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 334 

 December 17, 2007
 20 

7. EPA Comment

Modeling performed at 1-km grid resolution - Page 2-4 of the November 

16, 2006 submission to NC DAQ notes that comments received from NC 

DAQ on March 7, 2006, related to the modeling protocol specific to the 

Blue' Ridge Canton Mill 'states that "the 12-km screening approach 

should not be used. At a minimum, the 4-km CALMET data should be 

used and a refinement to l-km may be necessary." This comment matches 

page 48 of the VISTAS Protocol document, which says that sourcereceptor distances less than about 50 km may require grid resolution less 

than l-km if complex terrain effects are likely to be important. More 

refined digital elevation model (DEM) data are also required. Complex 

terrain effects should be important in western North Carolina both within 

the Class 1 areas of concern and between the source and each of these 

areas. Although the BART control technology report omits the 12-km 

screening, it appears to report on only a 4-km grid resolution instead of 

the finer resolution recommended. It is not clear whether consideration 

was given to revising the modeling using a l-km CALMET grid. 

Blue Ridge Paper Response

The BART modeling was performed in accordance with a modeling 

protocol approved by the North Carolina Division of Air Quality. 

8. EPA Comment

Results tables specified in the VISTAS Protocol - The VISTAS Protocol 

provides standard table formats for presenting modeling results. There 

should be a table showing number of days and number of receptors with 

impact greater than 0.5 dv for each Class 1 area, and for each year, number 

of days and number of receptors with impact greater than 1.0 dv for each 

Class 1 area for the entire 3-yr period, and the maximum 24-hr impact 

during the 3-yr period. These tables were provided in the October 2006 

BART Exemption Modeling Report, but have not been included in the 

November 16, 2006, document. It is suggested that similar tables be 

included in the determination report. Also, documentation that addresses the 

development of the baseline modeling should be included in the 

determination report. This may be in the BART exemption modeling report. 

It is suggested that the complete October 2006 BART Exemption Modeling 

Report be included as an appendix to the determination report. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 335 

 December 17, 2007
 21 

Blue Ridge Paper Response

The April 27, 2006 BART Exemption Modeling Report has been previously 

submitted to NCDAQ. The October 2006 date used by EPA in the 

comment above appears to be a typographical error. Additional copies 

may be provided upon request. 

9. EPA Comment

Deciview Thresholds - The document states in several places that “... the 

change in modeled visibility impact...is less than the 1 deciview threshold of 

human perception for changes in visibility.” This statement implies that the 

controls are not considered to make enough of an improvement in visibility 

at the Class I areas identified in the report. We note, however, that there is 

no bright line for evaluating in the BART determination analysis the degree 

of visibility improvement that is considered significant enough to warrant 

BART controls. Rather, a State has flexibility in setting absolute thresholds 

and determining the weight and significance to be assigned to each BART 

factor. (See 70 FR 39170, 1st col., July 6, 2005.) Also, this statement does 

not recognize that a source may be contributing to visibility impairment at a 

Class I area. 

Blue Ridge Paper Response

The Regional Haze Rule defines “visibility impairment” as “any humanly

perceptible change in visibility from that which would have existed under 

natural conditions” (see Federal Register Vol. 64, No. 126, page 35764). 

EPA states numerous times in the preamble and the rule that these 

thresholds are humanly perceptible thresholds (see Federal Register 

Vol. 70, No. 128, page 39119, footnote 28 and page 39120, footnote 32). 

This is the basis for using human perception in the report. 

In order to evaluate the various control scenarios as part of the BART 

evaluation, the change in visibility was determined for the mill as compared 

to natural conditions as required by the BART rule. Thus, since we are 

required by the BART rule to evaluate the impact that our emissions would 

have on natural visibility conditions at each Class I area, it must be 

assumed that no other sources of air emissions would exist other than those 

from sources at the mill for the purpose of the analysis. According to 40 

CFR Part 51, Appendix Y, an individual BART-eligible source is considered 

to “contribute” to visibility impairment in a Class I area if the modeled 98th

percentile change in dv is equal to or greater than the “contribution 

threshold.” The contribution threshold is 0.5 deciview. Since the modeled 

change in visibility for each control scenario is less than the 0.5 dv 

contribution threshold as compared to natural conditions, it is appropriate 

to state that a control scenario would not result in a humanly perceptible 

change as compared to natural conditions. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 336 

 December 17, 2007
 22 

Furthermore, the existing regional haze in the subject Class I areas is on the 

order of 35 dv. Based on the modeling analyses performed in the BART 

evaluation, the greatest change in visibility is 0.383 dv. This would be less 

than a 1% reduction in regional haze as compared to existing regional haze 

conditions. Based on the magnitude of costs for the control scenarios with 

minimal improvement in visibility, BART would be no further controls. 

 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 337 

 December 17, 2007
 23 

Enclosure 3 

EPA Comment - Below are clarifications we wish to note on certain 

statements in the text. (The location of the text in the document is 

identified in parentheses.) 

1. BACT Cost Effectiveness Comparisons (Section 1.2, P.1-1; cover letter, 

P.I) The document makes the following statement: "As a comparison, 

costs from $3,000 to $5,000 per ton of emissions reduction are generally 

considered cost prohibitive for BACT evaluations." The Agency has not 

established cost effectiveness values considered cost prohibitive in 

regulation or policy. Also, these BACT cost effectiveness numbers may 

not be directly applicable for use in the BART cost analysis as BACT 

costs can apply to a new source adding on controls, whereas BART costs 

for retrofit technology may need to be weighed differently. The State will 

identify what costs are reasonable or not. Where data are available, we 

recommend use of a comparative approach for costs, I.e., compare cost 

effectiveness numbers to a similar facility which operates with controls 

under similar conditions. Another way of stating this is as follows. 

If comparable emissions units are operating with controls, the 

owner of the BART-affected unit should show why control costs are 

prohibitive for the BART-affected unit, even though they are 

acceptable for similar controlled units in operation. 

Blue Ridge Paper Response

The BACT costs per ton of emissions was provided to help provide a 

benchmark for comparing cost estimates developed for the BART 

analysis. The report does not state that the same costs should be applied 

to the BART evaluation. 

2. BART-Eligibility Descriptions (Section 2.2, P.2-2; Section 3.1, P. 3.1) 

Potential to Emit (PTE) Thresholds: The PTE threshold provided for 

BART-eligible sources should be corrected to read, “ ... the potential to 

emit more than 250 tons per year or more ..." (See 40 CFR 51.301, 

"Definitions," Existing stationary facility.) 

Blue Ridge Paper Response

Blue Ridge acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. 

3. Due date for Regional Haze SIPs (Section 2.2, P. 2-3) 

The document identifies a due date for Regional Haze SIPs of January 

2008. To clarify, the due date for Regional Haze SIPs specified in the 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 338 

 December 17, 2007
 24 

Regional Haze regulations at 40 CFR 51.308 (b) is: “ ... no later than 

December 17,2007.” 

Blue Ridge Paper Response

Blue Ridge acknowledges the requested change. If the North Carolina 

Division of Air Quality requests a complete amended document then the 

change will be incorporated into the text. We would note that this is 

only an editorial change, both statements are correct as written. 

4. Line-of-Sight (LOS) 

(a) The document refers to a proposed LOS approach in several 

places and presents data for comparison on page 2-5. We recommend 

excluding LOS documentation since, as the report indicates, this 

specific approach is not appropriate for BART modeling purposes. 

(b) The document provides selected definitions from 40 CFR 51. We wish 

to clarify that the definitions provided in Section 2.1 for Line-of-Sight 

(LOS) and Just Noticeable Change are not from the Definitions section of 

the Regional Haze regulations (40 CFR 51.301, “Definitions”). 

Blue Ridge Paper Response

Blue Ridge continues to maintain that the line-of-sight approach is the 

technically appropriate refined method for evaluating visibility impacts for 

BART exemption modeling when comparing a single source to the humanly 

perceptible change value of 1 deciview. Furthermore, this is consistent 

with the definition and scientific basis of a deciview. An approximate one 

(1.0) deciview change was defined by Pitchford and Malm (1992) as a 

“just noticeable change” to a human when the background visual range 

equals the line-of-sight (LOS) of the observer. According to L. Willard 

Richards in “Use of the Deciview Haze Index as an Indicator for Regional 

Haze,” if a shorter LOS distance than the background visual range 

(natural conditions) is used in performing the calculations then a higher 

extinction value, or deciview, is needed to cause a “just noticeable 

change.” In other words, when the LOS is less than the background visual 

range, then it would require a higher deciview value in order to be a “just 

noticeable change.” Thus, in order to more accurately compare the impact 

of a single source on a Class I area for comparison to the deciview 

thresholds, the deciview change would need to be calculated along the 

human line-of-sight that is equal to the background visual range as 

opposed to a single receptor point in the Class I area. The modeling we 

included in the BART evaluation calculates the change over a shorter 

distance than the background visual range and thus overestimates the 

impact that the BART eligible units have on each Class I area. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 339 

 December 17, 2007
 25 

5. Permit Changes (Section 4.2, PA-4) 

The document asserts that the electrostatic precipitators (ESPs) on each RF 

exceed the Maximum Achievable Control Technology (MACT) standard 

for particulate matter (PM), and that this level of control is already 

required in the facility's Title V operating permit. The BART Guidelines 

say if the most stringent control available is adopted, it must be made 

federally enforceable for purposes of BART. Thus, the SIP and potentially 

the facility's permit must be modified to include a statement that these 

controls and operating conditions on the two recovery furnaces also serve 

to satisfy BART for PM. 

Blue Ridge Paper Response - The submitted document included a request to 

incorporate “no further controls” as BART into the Title V operating 

permit for Blue Ridge. 

6. References (Tables 4-2, 4-4, 4-6) 

The EPA Cost Manual references for Tables 4-2, 4-4, and 4-6 are confusing 

as written, which made it difficult to find the appropriate citations. Chapter 

1, December 1995, is cited in the EPA Cost Manual in these cost references. 

Since there are presently nine chapters labeled "Chapter 1" in the Cost 

Manual dated January 2002, we suggest that these references be clarified to 

include the relevant section and chapter title. This will enable reviewers to 

find the referenced portions of the document. In this case, the relevant items 

we suggest to include in these Cost Manual references are italicized as 

follows: “EPA Air Pollution Control Cost Control Manual, sixth edition 

(January 2002), EPA 452-02-001, Section 5.2, Chapter 1, "Wet Scrubbers 

for Acid Gas,” December 1995." (The current EPA Cost Manual is 

available at: http://www.epa.gov/Ittncatc1/products.htm/#cccinfo.) 

Blue Ridge Paper Response - The cost estimate for the installation of a 

scrubber on the recovery furnaces has been revised and is included in 

Attachment 1 to this correspondence. 

7. Table 4-1 – “Summary of RBLC Database for SO2 Control Technologies” 

It appears that the following four "RACT/BACT/LAER (RBLC)" 

Clearinghouse entries of facilities with SO2 controls on their RFs were 

either inadvertently omitted from Table 4-1 or slightly different search 

criteria may have been used. We used the following search criteria: default 

time span of 10 years back, Process Type: 30.211 "Kraft Recovery 

Furnaces/Boilers," Pollutant: “SOx”. For completeness, we suggest 

including these entries if they were omitted in error. The following control 

descriptions are included here for your convenience: 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 340 

 December 17, 2007
 26 

• LA-0201, Weyerhaeuser Company, Red River Mill facility (Proper 

Boiler Design and Operation); 

• LA-0207, International Paper Co, Mansfield Mill (Proper Design, 

Good, Combustion Practices, Firing Low Sulfur Fuel, and a 10% 

Annual Capacity Factor for Fossil Fuels); 

• MS-0078, Georgia Pacific Corporation, Monticello Mill (Combustion 

Control and Furnace Design); and 

• NC-0108, International Paper, Roanoke Rapids Mill (Furnace 

Design and Combustion optimization). 

Based on the RBLC search we performed, it also appears that certain 

RBLC entries with a “No Controls Feasible” label are not included in 

Table 4-1. We are unclear as to the reason for this. For completeness, we 

suggest that the table could either include all or exclude all facilities with a 

“No Controls Feasible” label. 

Blue Ridge Paper Response - Please refer to the sixth entry in Table 4-1. 

Summary of RBLC Database for SO2 Control Technologies Installed on 

Recovery Furnaces, this line contains the NC-0108 entry that is referenced 

above as a missing entry. Entries LA-0201 and LA-0207 are shown in the 

RBLC database as a draft determination, therefore,e these entries were not 

included. Entry MS-0078 did not appear in our original search of the 

database. But as described above, the control method is proper 

combustion and design of the furnace. This entry does not change the 

conclusions drawn in the report. 

8. Visibility Impact Thresholds (Section 4.1.5, P. 4-3) 

Section 4.1.5 provides a summary of Step 5 of the BART Guidelines. The 

second paragraph of this section states: “If the net visibility improvement is 

less than the humanly perceptible change, then there is no need for the 

facility to implement the control technologies because the resulting 

visibility impacts would be negligible.” The BART Guidelines do not make 

such an assertion. Rather, the Guidelines provide flexibility to the States 

with setting thresholds and weighing each of the BART factors. (See 70 FR 

39170, 1st col., July 6, 2005.) All of the statutory factors should be used in 

the determination of whether or not BART controls are needed. Visibility 

improvement based on modeling results is only one of the factors that 

should be assessed in this decision. 

Blue Ridge Paper Response - Blue Ridge acknowledges the comment but 

does not feel a modification to the report text is warranted. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 341 

 December 17, 2007
 27 

9. 22nd highest values for the two worst-case years (Section 5.8. P. 5-7) 

Page 5-7 of the document states that a spreadsheet was used to determine 

the 22nd highest values for the two worst-case years. The 98th percentile 

value for an individual year is the 8th highest value, so it is unclear why the 

report references the 22nd highest value. This appears to be a typographical 

error. 

Blue Ridge Paper Response - This is a typographical error in the report; 

the 8th highest value was the reported modeling result. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 342 

 December 17, 2007
 28 

National Park Service Comments 

NPS General Comments 

On the last page of the Introduction, BRP states: “...the change in modeled 

visibility impact...is less than the 1 deciview threshold of human perception for 

changes in visibility...Therefore, BART is no further controls.” Further, page 

4-3 states, “If the net visibility improvement is less than the humanly 

perceptible change, then there is no need for the facility to implement the 

control technologies because the resulting visibility impacts would be 

negligible.” We acknowledge that “visibility improvement that would result 

from controlling the emissions” is one of the factors in a BART analysis. 

However, the BART decision should not be based on perceptibility. Because 

BRP’s position is contrary to EPA Guidance, we ask that BRP show us the basis 

for this assertion. 

Blue Ridge Paper Response 

The BART evaluation was performed as described in Appendix Y to 40 CFR 51. 

The following 5-step process was utilized to conduct the case-by-case BART 

analysis. The five steps are: 

• Step 1—Identify All Available Retrofit Control Technologies, 

• Step 2— Eliminate Technically Infeasible Options, 

• Step 3— Evaluate Control Effectiveness of Remaining Control 

Technologies, 

• Step 4— Evaluate Impacts and Document the Results, and 

• Step 5—Evaluate Visibility Impacts. 

NPS Comment - We have the following comments regarding Table 4-2 which 

presents a cost/benefit analysis for controlling SO2 from the recovery furnaces: 

• BRP refers to a vendor quote for the scrubber installation – that should 

be provided. 

• While we believe it is legitimate to account for the costs of lost 

production and make-up, we would like to see the actual calculations to 

support these very large numbers. 

• BRP refers to a 7/19/06 vendor e-mail for the installation of a new fan 

and ductwork – that should be provided. 

• The reference for the cost of new switch gear installation is missing and 

should be provided. 

• If waste caustic is available from the bleach plant – if there is one – it 

could be used as the scrubbing reagent, thus reducing reagent and 

disposal costs – this should be investigated. 

• The Capital Recovery Factor is inflated. The OAQPS Control Cost 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 343 

 December 17, 2007
 29 

Manual recommends 7% interest over a 15-year life, not the 15% over 

ten years used by BRP. 

• BRP should document the 90% scrubber efficiency assumption – it 

seems low. 

Blue Ridge Paper Response - Attachment 1 to this correspondence includes a 

copy of the quote received from MECS (formerly Monsanto Enviro-Chem). Also 

include in this Attachment is a revised Table 4-2. This table clearly delineates 

all of the inputs for determining lost production. All of the costs for new fan 

and ductwork are also clearly defined in the revised table. 

Blue Ridge is currently limited by the amount of caustic available for the mill. 

Material must be purchased and brought on site for make-up. However, in 

order to present a conservative estimate of costs, the revised scrubber 

calculations have assumed a caustic scrubbing medium in lieu of limestone. 

Please refer to the detailed response to Comment No. 9 from Enclosure No. 1. 

This comment outlines the appropriateness of using a 15% interest rate and a 

10-year life. 

Sulfur dioxide emissions from a recovery boiler are not consistent, emission 

levels tend to run in “spikes.” Since there is not a steady loading of sulfur 

dioxide to the scrubber, the efficiency of the unit will not be maximized. 

Therefore, Blue Ridge feels that the use of 90% control is appropriate. 

NPS Comment - We have the following comments regarding Table 4-4 which 

presents a cost/benefit analysis for controlling NOx from the recovery furnaces: 

• BRP should provide documentation to support its cost estimates. 

• While we believe it is legitimate to account for the costs of lost 

production and make up, those costs should not be included in the base 

for estimating Indirect Annual Costs. 

• The Capital Recovery Factor is inflated. The OAQPS Control Cost 

Manual recommends 7% interest over a 15-year life, not the 15% over 

ten years used by BRP. 

• BRP should document the 40% control efficiency assumption. 

The costs associated with lost production are accounted in the Indirect 

Installation Cost. The Indirect Installation Cost in turn is a component of the 

Total Capital Investment; therefore these costs are incorporated into the capital 

recovery factor. 

Please refer to the detailed response to Comment No. 9 from Enclosure No. 1. 

This comment clearly outlines the appropriateness of using a 15% interest rate 

and a 10-year life. 

The 40% control efficiency has been documented in the submittal based on 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 344 

 December 17, 2007
 30 

information provided by the National Council for Air and Stream Improvement. 

Please refer to Corporate Correspondents Memorandum CC 06-014 entitled 

“Retrofit Control Technology Assessment for NOx, SO2, and PM Emissions 

from Kraft Pulp and Paper Mill Unit Operations.” In fact, the memorandum 

indicates that the installation of quaternary air reduces NOx emissions by 20-

40%. Therefore, we have been conservative in our inclusion of 40%. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 345 

 December 17, 2007
 31 

Attachment 1 

Revised Cost Estimate 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 346 

 December 17, 2007
Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recovery Furnace No. 10 or 11 - REVISED

Direct Costs (Material and labor involved in actual installation of the facility)

1. Cost of Scrubber (including scrubber, major mechanical components, instrumentation, and structural steel)

$3,888,000.00 (Please refer to the attached e-mail from Cristina Kulczycki of MECS [formerly Monsanto Enviro-Chem])

2. Modifications to Existing Ductwork and New Stack

Material 

($/given) Cost4

 ($) Delivered Cost 

($)

300 ft $11,011.00 $3,303,300.00 $3,567,564

50 ft $11,011.00 $550,550.00 $594,594

6,240 ft $59.40 $370,656.00 $400,308

1,040 ft $59.40 $61,776.00 $66,718

75 tons $3,960.00 $297,000.00 $320,760

13 tons $3,960.00 $49,500.00 $53,460

$8,147,189

$13,150,594

1 - Recent unit pricing from first quarter 2006 for materials for 2205 SS material is $6.05/lb with a plate density of 35lb/ft2

2 - Recent unit pricing from first quarter 2006 for materials, unit price of $1.98/lb for CS

3 - Typical ductwork is supported on framing that is about 2 - 3 tons of material total at each support location, with the supports spaced 10 to 15' apart. 

4 - Cost is FOB Indiana, Freight is assumed 5%, Taxes 3%

3. New ID Fan

$772,200.00 ID Fan (approximately 1000 HP, with 4160 motor)

Cost of fan is $715,000 FOB in Indiana, Freight is estimated at 5%, Taxes at 3%.

4. New Switch Gear

$500,000.00

Direct Installation Costs (Expenses not directly involved with material and labor of actual installation)

1. Retrofit Cost Considerations

0.15 Retrofit Factor

Factor is applied to the ductwork costs shown in Item No. 2 above. 

$750,510.68 Retrofit Cost Consideration

Structural framing for ductwork support, 50' high

Structural framing for inlet ductwork support, 50' high

External stiffeners for outlet ductwork, 30lb/ft shapes2

Total Capital Investment is the sum of the total direct cost, the total direct installation costs (including retrofit cost considerations) and the indirect 

installation costs. 

Total Cost for Modifications to Existing Ductwork and New Stack

The current power distribution system is operating at maximum capacity 

and a new switch gear would be required to operate a new fan. Cost was 

provided by Mill personnel.

As shown in the attached quote, we are conservatively using the low-end of the cost estimate ($6,000,000-$14,000,000) to ensure that our numbers are 

representative of the conditions at Blue Ridge. Based on information provided by the vendor, we have then multiplied this value by 60% to obtain capital 

investment of the identified components. Freight is estimated at 5%, Taxes at 3%.

External stiffeners for inlet ductwork, 30lb/ft shapes2

Outlet ductwork to scrubber , 13'x13' x 50' long, 2205 SS1

Inlet ductwork to scrubber , 13'x13' x 300' long, 2205 SS1

Alloy Fabricated Materials - Ductwork Given Information

Stack, 100 ft tall, 12' dia. (erected price, including foundations)

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 347 

 December 17, 2007
Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recovery Furnace No. 10 or 11 - REVISED

Indirect Installation Costs

1. Lost Pulp Production

$550.00 $/ton, Cost to Purchase Dry Pulp

700 ton/day/furnace, Production Capacity

14 days, Total Recovery Furnace Outage Time to Install Scrubber

$5,390,000.00 Total Lost Production Costs

2. Lost Power Production

786.5 MMBtu/hr, Heat Input Rating of Recovery Furnace

0.293 Watts/Btu/hr, Conversion Factor

230.5 Mw, Capacity of Single Recovery Furnace

30% Conversion from Mw to Mwe (heat energy to electric energy)

69.15 Mwe, Electric Energy Provided by Recovery Boiler

$0.067 $/Kw-hr, Cost to Purchase Electricity from the Grid

$0.025 $/Kw-hr, Cost to Manufacture Electricity

$0.042 $/Kw-hr, Incremental Cost of Purchased Power

$975,842.92 Total Cost Associated with Lost Power Production

Total Capital Investment

$3,888,000.00 Cost of Scrubber

$13,150,594 Total Cost for Modifications to Existing Ductwork and New Stack

$772,200.00 New ID Fan

$500,000.00 New Switch Gear

$750,510.68 Retrofit Cost Considerations

$5,390,000.00 Total Lost Production Costs

$975,842.92 Total Cost Associated with Lost Power Production

$25,427,147.42 Total Capital Investment

Annual Operating Costs

Direct Annual Costs, DC, Operating

$28.00 $/hr, Operator Labor Rate

1 hr/Shift, Operator Labor Dedicated to Operating Scrubber

$35.00 $/hr, Supervisor Labor Rate

0.15 hr/Shift, Supervisor Labor Dedicated to Operating Scrubber

1,095 Shifts/yr, Assumes 3 shifts per day, 365 days per year

$30,660.00 $/yr, Operator Labor

$5,748.75 $/yr, Supervisor Labor

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 348 

 December 17, 2007
Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recovery Furnace No. 10 or 11 - REVISED

Direct Annual Costs, DC, Maintenance

$28.00 $/hr, Maitenance Labor Rate

1 hr/Shift, Maitenance Labor 

1,095 Shifts/yr, Assumes 3 shifts per day, 365 days per year

$30,660.00 $/yr, Maintenance Labor

$30,660.00 Maintenance Materials

Direct Annual Costs, DC, Utilities

$319.00 $/hp-yr, Mill Specific Electricity Cost

1,000 hp, Approximate Size of New Fan

$319,000.00 $/yr, Annual Energy Cost

10 gal/min, Minimum Flow Rate through Scrubber

$0.09 $/1000 gal, Cost of Mill Water

$473.04 $/yr, Water Cost

$280,000.00 $/yr, Caustic Cost Provided via MECS in 2/14/07 Phonecon

$697,201.79 Total Direct Annual Operating Costs

Indirect Annual Costs, Overhead

60% Percent of Annual Direct Costs (Excluding Utilities)

$58,637.25 $/yr, Overhead Costs

Indirect Annual Costs, Administration, Property, and Insurance

2% Administration Costs, Percent of Total Capital Investment

1% Property Costs, Percent of Total Capital Investment

1% Insurance Costs, Percent of Total Capital Investment

$1,017,085.90 $/yr, Administrative, Property, and Insurance Costs

Indirect Annual Costs, Capital Recovery Factor

15% Interest Rate

10 yrs, Payback Period

 Capital Recovery Factor = i ( 1+ i) ^ n / ((1+i)^ n-1) ; i= interest rate , n= years

0.1725 Capital Recovery Factor 

$4,386,182.93 $/yr, Capital Recovery

$5,461,906.08 Total Indirect Annual Operating Costs

$6,159,107.87 Total Annual Operating Costs

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 349 

 December 17, 2007
Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recovery Furnace No. 10 or 11 - REVISED

Cost Effectiveness

128.3 lb/hr, SO2 Emission Rate from Each Scrubber

8760 hr/yr, Annual Operating Hours

561.954 ton/yr, Annual Potential SO2 Emissions

90% Reduction by Scrubber

505.76 ton/yr, SO2 Reductions from Scrubber

$12,177.96 $/ton, Cost Effectiveness of Scrubber Installation

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 350 

 December 17, 2007
"KULCZYCKI, CRISTINA R 

[STL]" 

<CRISTINA.R.KULCZYCKI@

MECSGLOBAL.COM>

02/19/2007 02:48 PM

To <Cynthia_Winston@URSCorp.com>

cc

bcc

Subject RE: Quote for Recovery Boiler SO2 Control System

History: This message has been replied to.

Hi Cynthia,

Enclosed is some preliminary vessel sizing and utility information for

the scrubber that we discussed last week.

Is there anything else that you need from me at this point?

Thanks,

Cristina

-----Original Message-----

From: KULCZYCKI, CRISTINA R [STL] 

Sent: Thursday, February 15, 2007 2:11 PM

To: 'Cynthia_Winston@URSCorp.com'

Subject: RE: Quote for Recovery Boiler SO2 Control System

Cynthia,

There is no money for ductwork in the estimate.

Are you asking what the split is on equipment versus installation? If

so, it depends on which items you put in installation and which items

you put in equipment. We generally say that equipment is about 60% of

the total installed cost.

Thanks,

Cristina

-----Original Message-----

From: Cynthia_Winston@URSCorp.com [mailto:Cynthia_Winston@URSCorp.com] 

Sent: Thursday, February 15, 2007 1:59 PM

To: KULCZYCKI, CRISTINA R [STL]

Subject: RE: Quote for Recovery Boiler SO2 Control System

Cristina - Thank you for the prompt response!!

Could you please clarify the portion of the cost associated only with

the scrubber, instruments, piping (not to include ductwork routing the

gas to the scrubber), and structural steel.

Again thank you for your assistance!!

Cyndi

Cynthia Winston, P.E.

URS Corporation

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 351 

 December 17, 2007
1600 Perimeter Park Drive, Suite 100

Morrisville, North Carolina 27560

(919) 461-1230 - Phone

(919) 461-1415 - Fax

 This e-mail and any attachments are confidential. If you receive this

 message in error or are not the intended recipient, you should not

retain, 

 distribute, disclose or use any of this information and you should

destroy 

 the e-mail and any attachments or copies.

 "KULCZYCKI,

 CRISTINA R [STL]"

 <CRISTINA.R.KULCZ

To 

 YCKI@MECSGLOBAL.C <Cynthia_Winston@URSCorp.com>

 OM>

cc 

 <Randall_Taylor@URSCorp.com>,

 02/15/2007 11:22 <Amy_Marshall@URSCorp.com>,

 AM "PURICELLI, STEVEN M [STL]"

<STEVEN.M.PURICELLI@MECSGLOBAL.COM> 

Subject 

 RE: Quote for Recovery Boiler SO2

 Control System

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 352 

 December 17, 2007
Cynthia,

If I am doing the math correctly, the inlet flowrate is 365,562 acfm.

That is quite a large flowrate.

Without a detailed gas composition I can't calculate the quenched gas

flowrate (which is the flowrate used to design the scrubber); however, I

think you are in the 10 million dollar price range +/- 40% (i.e. 6 to 14

million). This number includes installation of the scrubber and stack

(assuming a reasonable height), major mechanical equipment, instruments,

piping, and structural steel.

We have been doing a lot of refinery work where 316 S/S is the

predominant material used (for the vessel and piping). If we could use

FRP we might be towards the lower end of the above price range. In

addition, we would need to know if the liquid effluent needs to be

oxidized and filtered for solids. If it isn't oxidized, the effluent

will contain a 10% solution of sodium sulfite and sodium bisulfite. If

you do oxidize, the effluent will contain 10% sodium sulfate. Anyway,

oxidation and filtration adds to the cost of the system. If you don't

oxidize or filter the effluent you may be towards the middle to lower

end of the above range.

Finally, if a system fan is required you will be on the higher end of

the above price range.

We can spend a bit more time and work up an actual budget estimate;

however, you need to allow at least two to four weeks for that process.

Also, if you do want us to do that we will need a complete gas

composition (i.e. % N2, % O2, etc., etc.) as well as the inlet pressure

to the Dynawave. In addition, we would need to know how you want the

effluent handled.

Hope this helps. If you have any other questions please give me a call

at 314-275-5787.

Cristina Kulczycki

-----Original Message-----

From: Cynthia_Winston@URSCorp.com [mailto:Cynthia_Winston@URSCorp.com]

Sent: Wednesday, February 14, 2007 1:08 PM

To: KULCZYCKI, CRISTINA R [STL]

Cc: Randall_Taylor@URSCorp.com; Amy_Marshall@URSCorp.com

Subject: Quote for Recovery Boiler SO2 Control System

Cristina -

Thank you for taking time to discuss the MECS SO2 control system with me

today. We are looking for a budgetary estimate for the installation of

an SO2 reduction device to be installed on a recovery boiler at a pulp

and paper mill in North Carolina. The device should be able to control

SO2 emissions by 90%. The SO2 loading to the device is 128.3 pounds per

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 353 

 December 17, 2007
hour. H2SO4 emissions from the unit are 0.18 pounds per hour. Please

cost the system using caustic. At the current time the mill is black

liquor solids limited and therefore, BL scrubbing is not an option. The

exhaust stream is approximately 400 degrees Kelvin with 172.5 cubic

meters per second of air flow.

Thank you again for your assistance! We are on a tight schedule so any

information you can provide is helpful.

Please do not hesitate to contact me for further clarification!! Cyndi

Cynthia Winston, P.E.

URS Corporation

1600 Perimeter Park Drive, Suite 100

Morrisville, North Carolina 27560

(919) 461-1230 - Phone

(919) 461-1415 - Fax

 This e-mail and any attachments are confidential. If you receive this

 message in error or are not the intended recipient, you should not

retain, distribute, disclose or use any of this information and you

should destroy the e-mail and any attachments or copies.

This e-mail contains information intended only for the use of the

individual or entity named as the addressee. This communication may

contain information that is the confidential and proprietary property of

MECS, Inc. If the reader of the e-mail is not an intended recipient or

the employee or agent responsible for delivering it to an intended

recipient, any review, dissemination, distribution or copying is

strictly prohibited. If you have received this e-mail in error, please

immediately notify us at

(314) 275-5700 and delete the copy you received.

All e-mails and attachments sent and received are subject to monitoring,

reading and archival by MECS, Inc. The recipient of this e-mail is

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This e-mail contains information intended only for the use of the individual 

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of the e-mail is not an intended recipient or the employee or agent 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 354 

 December 17, 2007
responsible for delivering it to an intended recipient, any review, 

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received this e-mail in error, please immediately notify us at (314) 275-5700 

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BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 355 

 December 17, 2007
URS Corporation 

DynaWave Tailgas Scrubber Design Conditions

Inlet Conditions 

Scrubber Inlet Flow Rate, acfm 365,500 

SO2, lb/hr 128 

Temperature, oF 260 

Scrubber Operations Summary 

SO2 Removal Efficiency* 90 

SO2 Outlet, lb/hr (ppmvd) 12 (5) 

System Gas DP, inches wc 12 

Scrubber Exit Flow Rate, acfm 314,500 

Liquid Circulation Rate to Each 

Reverse Jet, gpm 12,500 

Exit Temperature, oF 114 

Caustic Reagent Usage, lb/h 

145 

 (100% NaOH) 

Liquid Effluent Flow Rate, gpm 

5 

(10% Na2SO3) 

Reverse Jet Pump, HP 400 

* To a lower limit of 12 ppmv 

Scrubber Dimensions 

Nozzle Size, inches** 16 @ 10 psi 

Inlet Diameter (A), inches 106 

Outlet Diameter (C), ft 5 

Vessel Diameter (D), ft 24 

Sump Diameter (E), ft 24 

Vessel Height (F), ft 55 

Sump Height (G), ft 13 

Height of Inlet Barrel (H) ft 22 

Overall Height (I), ft 56 

** This is a three nozzle arrangement. 

NOTE: These are preliminary designs. Firm designs may vary based upon final specifications 

and requirements. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 356 

 December 17, 2007
All Dimensions are

approximate and subject to

change after detailed design.

Drawing not to scale.

This drawing is the confidential

property of MECS, Inc. Information

and know-how hereon are

confidential and may not be used

reproduced or revealed to others

except in accord with the contract or

other written permission of MECS. Any reproductions in whole or in

part including shop drawings shall

bear or refer to this stamp.

DynaWave

Engineered Scrubbing Systems

URS Corporation RFK

February 19, 2007

I

E

C

 F

GAS

OUTLET

GAS

INLET

A

D

G

H

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 357 

 December 17, 2007
Thomas Bell/Austin/URSCorp

07/19/2006 04:16 PM

To Cynthia Winston/Morrisville/URSCorp@URSCorp

cc Trey Pavy/Austin/URSCorp@URSCorp, Blake 

Stapper/Austin/URSCorp@URSCorp

bcc

Subject Scrubber support equipment costs

Cyndy,

Attached is a spreadsheet containing rough costs for the equipment about which we spoke over the 

phone. These numbers are based on actual purchased equipment and/or budget estimates that were 

obtained for similar sized components for some of the AdvaTech projects from first quarter 2006. The 

stack price is a lump sum number including construction since that is typically how that item is furnished. 

The balance of the numbers are equipment only with no contigency added. I tried to include some 

comments in the cells to explain the basis of the numbers in case you needed it.

I hope this helps.

Thanks.

Thomas Bell, P.E.

URS Corporation

512-419-5005 (ph)

512-454-8807 (fax)

This e-mail and any attachments are confidential. If you receive this message in error or are not the intended recipient, you should 

not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any attachments or copies. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 358 

 December 17, 2007
North Carolina Papermill

Scrubber Auxilliary equipment costs

Cost ($)

Summary QTY Unit

5

6 Major Capital Equipment $21,097,782

7 Freight 3.0% $632,933

8 Warranty 5.0% $1,054,889

12

13 FGD Upgrades Material Total $22,785,605

14

15 Process Studies and Modeling

16 Engineering

17 Construction Assistance, Startup and Training

18

19 Engineering Services Costs $0

20

Project Contigency

23 Total Project Cost incl. Fee and Contigency (URS Scope) $22,785,605

24

25 Detail

26 Scrubber Auxilliary Equipment

27 Major Capital Equipment

28 ID Fan (approximately 1000 HP, with 4160 motor) 1 ea 715,000 $715,000 $28.16 $715,000

29 Alloy Fabricated Materials - Ductwork

30 Inlet ductwork to scrubber , 13'x13' x 300' long, 2205 SS 300 ft 11,011 $3,303,300 0 $28.16 $0 $3,303,300

31 Outlet ductwork to scrubber , 13'x13' x 50' long, 2205 SS 50 ft 11,011 $550,550 0 $28.16 $0 $550,550

32 External stiffeners for inlet ductwork, 30lb/ft shapes 6,240 ft 59 $370,656 0 $28.16 $0 $370,656

33 External stiffeners for outlet ductwork, 30lb/ft shapes 1,040 ft 59 $61,776 0 $28.16 $0 $61,776

34 Structural framing for inlet ductwork support, 50' high 75 tons 3,960 $297,000 0 $28.16 $0 $297,000

35 Structural framing for ductwork support, 50' high 13 tons 3,960 $49,500 0 $28.16 $0 $49,500

36 Stack, 300 ft tall, 12' dia. (erected price, including foundations) $15,750,000 $15,750,000

37 Total major capital equipment $5,347,782 $15,750,000 $21,097,782

Revised Cost Estimates.xls Page 1 of 1 2/21/2007 3:46 PM

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 359 

 December 17, 2007
APPENDIX B 

NCASI Corporate Correspondents Memorandum on Retrofit Controls 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 360 

 December 17, 2007
ncasi 

NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. 

P.O. Box 13318, Research Triangle Park, NC 27709-3318 

Phone (919) 941-6400 Fax (919) 941-6401 

Ronald A. Yeske, Ph.D. 

President 

(919) 941-6404 

June 9, 2006 

TO: Corporate Correspondents -- CC 06-014 

Regional Managers 

FROM: Ronald A. Yeske 

SUBJECT: Information on Retrofit Control Measures for Kraft Pulp Mill Sources and Boilers 

for NOx, SO2 and PM Emissions 

The attached document “Retrofit Control Technology Assessment for NOx, SO2 and PM 

Emissions from Kraft Pulp and Paper Mill Unit Operations” was prepared to assist NCASI 

member company personnel involved in conducting Best Available Retrofit Technology 

(BART) site-specific engineering analyses. It deals with the three main pollutants of concern 

for BART analyses, namely NOx, SO2 and particulate matter (PM). Potentially available control 

technologies for these three pollutants for kraft recovery furnaces, lime kilns and boilers burning 

wood, coal, gas, or oil are discussed. Also, control technologies for PM emissions from lime 

slakers and smelt dissolving tanks are briefly reviewed. 

Sources subject to BART analyses were generally built in the 1962 to 1977 time frame. Thus, 

application of any control technologies to these sources will involve retrofits. Even though a 

given technology may have been installed on newer more modern units, or may be theoretically 

applicable, retrofitting the technology to an older existing unit requires consideration of unitspecific and location-specific factors. In many situations, these factors would eliminate one or 

more control technologies from consideration due to technical infeasibility or excessive costs. 

As noted throughout this document, site-specific factors will play a critical role in BART 

analyses. 

This document does not directly address the cost-effectiveness ($/ton of pollutant removed) 

of retrofit control measures. Site-specific information, including capital costs, operating and 

maintenance costs, and annual capacity factors, must be considered in assessing the costeffectiveness of a given control technology to a particular emission source. Not surprisingly, 

the ranges in costs and potential emission reductions are expected to be very large. 

For more information on this document, please contact Dr. Arun V. Someshwar, Principal 

Research Engineer, at the Southern Regional Center office, phone (352) 331-1745, ext 226; 

email asomeshwar@ncasi.org. 

Attachment 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 361 

 December 17, 2007
National Council for Air and Stream Improvement 

Retrofit Control Technology Assessment for NOx, SO2 and PM Emissions 

From Kraft Pulp and Paper Mill Unit Operations 

by Arun V. Someshwar, Ph. D., NCASI 

1.0 Introduction 

This document summarizes the general applicability of currently available emission control 

technologies for NOx, SO2 and particulate matter (PM) to various pulp and paper mill sources. 

The three main unit operations in a kraft pulp mill that emit NOx, SO2 and PM are kraft recovery 

furnaces, lime kilns and boilers. Boilers can be of the type which burn wood residues alone, 

wood in combination with coal, gas or oil, or only fossil fuels. Particulate emissions can also 

result from lime slakers and smelt dissolving tanks. Other pulp and paper mill sources for PM are 

generally quite insignificant. 

The origin and nature of the three pollutants in each relevant pulp mill unit operation is first 

discussed. Such discussion should be useful in understanding why some control technologies, 

while being suitable candidates for certain unit operations in other industries, may not be suitable 

in the pulp and paper industry. It is hoped this document will be useful in the context of a Best 

Available Retrofit Technology (BART) site-specific engineering analysis. However, it must be 

clearly noted that for any retrofit technology, site-specific considerations for a given emission 

source may disqualify a particular control technology from consideration, even though it might 

theoretically be feasible or may even have been installed elsewhere on a new, modern unit or a 

greenfield operation. 

Cost and emission reduction estimates are specifically not covered in this document. However, it 

is instructive to consider that a wide range in costs and potential emission reductions are expected 

due to the fact that site-specific factors play a critical role in determining how cost-effective 

various technologies will be in practice. Many facilities are space-limited, have controls already 

in place, or have older combustion equipment that cannot be retrofit to reach required conditions, 

making installation of certain technologies problematic or very expensive. 

2.0 Kraft Recovery Furnaces 

2.1 NOx Control 

Compared to coal- or residual oil-fired boilers of similar capacity, NOx emissions from kraft 

recovery furnaces are generally quite low, typically in the 60 to 130 ppm range. These low NOx

emissions are due to several factors inherent to kraft recovery furnace operations which include 

(a) low nitrogen concentrations in most “as-fired” black liquor solids (generally <0.2% ), (b) 

recovery furnace NOx formation resulting predominantly from “fuel NOx” mechanisms 

(insufficient temperatures for “thermal NOx” formation), (c) the highly staged combustion design 

of recovery furnaces, and (d) the existence of sodium fumes that might participate in “in-furnace” 

NOx reduction or removal. 

Researchers have concluded that nearly two-thirds to three-fourths of the liquor N is released 

during pyrolysis or devolatilization, partly as NH3 and partly as N2, the rest remaining with the 

smelt product most likely as a reduced N species. The ammonia released from the black liquor 

during pyrolysis partly oxidizes to NO and partly reduces to N2. A review of the theoretical 

kinetics governing the reactions between NH3, NO, and O2 suggests that, in the presence of 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 362 

 December 17, 2007
2 June 4, 2006 

National Council for Air and Stream Improvement 

excess O2, a decrease in temperature decreases the degree of oxidation of NH3 to NO, thus 

implying that fuel NOx generation during black liquor combustion is more temperature-dependent 

than previously thought. However, a reduction in furnace temperatures, particularly in the lower 

furnace, is generally expected to result in a sharp increase in SO2 emissions from the furnace. 

Most of the NO is formed by oxidation of the NH3 volatilized during pyrolysis of the liquor 

droplets. Very little NO is formed from the N in the char bed. In certain instances, where the 

liquor droplet dries completely before reaching the char bed, additional NO can be formed during 

“in-flight” char combustion of the liquor droplet. The use of liquor sprays resulting in larger 

droplet sizes avoids the problem of additional NO contribution from char burning. 

Some have observed that NOx emissions increased when firing liquors with increasing liquor 

solids contents. However, this may have had less to do with thermal NOx or an “in-furnace” 

capability of alkali fume to capture NOx as suggested by some, but more to do with a possible 

effect on increased conversion of ammonia to NO within the furnace due to an increase in lower 

furnace temperatures resulting from firing higher solids liquors. 

2.1.1 Low NOx Burners 

The use of low-NOx burners (LNB) for black liquor combustion has not been demonstrated. 

Unlike fossil fuels, black liquor has a large quantity of water and the drying, pyrolysis, and char 

burning of liquor droplets occurs over a long flight trajectory from the liquor guns to the char bed, 

thus making unavailable the benefits of staged combustion inherent in LNB designs. 

LNBs could however be applied to oil guns or gas burners in recovery furnaces that are used to 

supply supplemental heat or for start-up/shut down purposes. However, for most recovery units, 

the use of auxiliary fuel is very limited; in such cases the benefit from conversion to LNB would 

be marginal. 

2.1.2 Staged Combustion 

Recent research has concluded that to the extent “staged combustion” is allowed to take place in 

the upper furnace during oxidation of the volatilized NH3 to NO, such oxidation can be 

minimized. Limited short-term experience after installing “quaternary” air ports in two U.S. 

furnaces showed that a 20 to 40% reduction in baseline NOx levels is feasible using such air 

staging. However, to make it feasible to install a quaternary air system a recovery furnace 

typically needs to be fairly large in size. Thus this option would not be feasible for most BARTeligible recovery furnaces, since units built in the 1962 t o 1977 time period were considerably 

smaller than those installed in subsequent years. 

2.1.3 Flue Gas Recirculation (FGR) 

Flue gas recirculation (FGR) is also not a viable option for kraft recovery furnaces. In FGR, a 

portion of the uncontrolled flue gases is routed back to the combustion zone, primarily with the 

intention of reducing thermal NOx. Thermal NOx is, however, not a concern in recovery furnaces, 

as discussed earlier. FGR would add additional gas volume in the furnace, increasing velocities 

and potentially causing more liquor carryover, which would result in increased fouling of the 

recovery furnace tubes. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 363 

 December 17, 2007
June 4, 2006 3 

National Council for Air and Stream Improvement 

2.1.4 Oxygen Trim + Water Injection 

Oxygen-trim + water injection, a NOx control technology generally utilized in natural gas-fired 

boilers, would not be relevant to kraft recovery furnaces since (1) any injection of water into the 

furnace would lead to an unacceptable explosive condition and (2) the oxygen trim technique 

would have marginal effect due to the already existing highly staged combustion air configuration 

in recovery furnaces. 

2.1.5 Selective Non-Catalytic Reduction (SNCR) 

At the current time, there is no published information on the extended use of SNCR on an 

operating kraft recovery furnace. Short-term tests with the SNCR technology have been reported 

in the literature on two furnaces in Japan and one in Sweden. There are a number of critical, 

unresolved issues surrounding the use of urea or ammonia injection in a kraft recovery furnace 

for NOx control over a long-term basis. A kraft recovery furnace is the most expensive unit 

operation in a pulp mill since its primary purpose is to recover chemicals from spent pulping 

liquors in a safe and reliable manner. Although steam is generated from liquor combustion, 

certain chemical recovery steps have to be accomplished inside the furnace. It is not known 

whether the injection of NOx-reducing chemicals into the furnace would have deleterious effects 

on the kraft liquor recovery cycle on a long-term basis. Long-term tests would need to be carried 

out to address this important issue. In addition, there are several other factors that make the use 

of SNCR in a kraft recovery furnace problematic such as (1) the impact of large variations in flue 

gas temperatures at the superheater entrance due to fluctuating load and liquor quality, (2) limited 

residence times for the NOx-NH3 reactions available in smaller furnaces, (3) impact on fireside 

deposit buildup due to reduced chloride purging from long-term NH3/urea use and resulting 

impact on tube corrosion and fouling, and (4) potential for significant NH3 slip and plume opacity 

problems due to NH4Cl emissions. Unless these concerns are satisfactorily resolved, the use of 

SNCR in a kraft recovery furnace should not be considered as a feasible technology. 

2.1.6 Selective Catalytic Reduction (SCR) 

The use of SCR on a kraft recovery furnace has never been demonstrated, even on a short-term 

basis. The impact of high particulate matter concentrations in the economizer region and fine 

dust particles on catalyst effectiveness is a major impediment to the application of this technology 

ahead of PM control, as is catalyst poisoning by soluble alkali metals in the gas stream. For SCR 

installation after an ESP, the gas stream would be too cold for effective reaction with the NOx. A 

substantial energy penalty would have to be incurred to reheat the flue gas prior to the SCR 

section which would be a major drawback. 

2.1.7 Summary 

In summary, optimization of the staged combustion principle within large, existing kraft recovery 

furnaces to achieve lower NOx emissions might be the only technologically feasible option at the 

present time for NOx reduction. However, the effect of such air staging on emissions of other 

pollutants, chiefly SO2, CO, and TRS, and other furnace operational characteristics needs to be 

examined with longer-term data on U.S. furnaces. Ultimately, the liquor nitrogen content, which 

is dependent on the types of wood pulped, is the dominant factor affecting the level of NOx 

emissions from black liquor combustion in a recovery furnace. Unfortunately, this factor is 

beyond the control of pulp mill operators. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 364 

 December 17, 2007
4 June 4, 2006 

National Council for Air and Stream Improvement 

2.2 SO2 Control 

Black liquor contains a significant amount of sulfur, nominally 3 to 5% by weight of the 

dissolved solids. While the vast majority of this sulfur leaves the furnace in the smelt product, a 

small fraction (generally under 1%) can escape in gaseous or particulate form. Average SO2

concentrations in stack gases can range from nearly 0 to 500 ppm, although most furnaces 

currently operate with <100 ppm SO2 in stack emissions. Factors which influence SO2 levels are 

liquor sulfidity, liquor solids content, stack oxygen content, furnace load, auxiliary fuel use, and 

furnace design. However, none of these factors has exhibited a consistent relationship with SO2

emissions. At the present time, it is generally understood that conditions involving liquor quality 

(such as high Btu, high solids liquors) and liquor firing patterns and conditions related to furnace 

operations (air distribution, auxiliary fuel, etc.) that lead to maximizing temperatures in the lower 

furnace result in minimizing SO2 emissions from kraft recovery furnaces. 

There is no experience in the pulp and paper industry with the use of dedicated, add-on flue gas 

desulfurization technologies on kraft recovery furnaces. Although there are a few scrubbers on 

U.S. kraft recovery furnaces, none of these were installed for SO2 removal. Only one U.S. 

recovery furnace does not use an ESP for particulate control; this unit has venturi scrubbers 

instead. All of the other scrubbers follow an ESP. Two were installed for heat recovery reasons, 

although some SO2 scrubbing may also be occurring especially when caustic is added to the 

scrubbing solution. One scrubber following an ESP was installed with the main purpose of 

achieving incremental particulate matter removal. Another scrubber following an ESP was 

installed on a furnace with a direct contact evaporator to control black liquor droplets being 

entrained in the cascade and traveling all the way throughout the ESP and out the stack. Even if 

these scrubbers had been installed to reduce SO2 emissions, the removal costs in terms of dollars 

per ton of SO2 removed would be large due to high gas flows and site-specific retrofit 

considerations. Significant capital would be required for the large gas handling equipment and 

additional induced fan capacity needed to overcome the increased pressure drop across the 

scrubber. 

2.3 Particulate Matter Control 

Recovery furnaces are designed and operated in a manner so as to ensure the presence of high 

levels of sodium fumes in order to capture the sulfur dioxide produced as a result of oxidation of 

reduced sulfur compounds. Consequently, uncontrolled recovery furnace flue gases contain high 

levels of particulate matter. The uncontrolled particulate matter load from recovery furnaces is 

highly variable and has been reported to range from 100 to 250 lb/ODTP (oven dry ton pulp) for 

direct contact evaporator (DCE) furnaces and 200 to 450 lb/ODTP for non-direct contact 

evaporator (NDCE) furnaces. The lower particulate loading from DCE furnaces is due to the 

capture of some particulate matter in the direct contact evaporator. ESPs built for NDCE 

furnaces are designed to compensate for the higher particulate loading. 

Particulates generated in the recovery furnace are comprised mainly of sodium sulfate, with lesser 

amounts of sodium carbonate and sodium chloride. Similar potassium compounds are also 

generated, but in much lower amounts. Trace amounts of other metal compounds, e.g. 

magnesium, calcium, and zinc, can be present. A significant portion of the particulate material is 

sub-micron in size, which makes removal with additional add-on control devices more difficult. 

Increasing liquor firing density (ton/day/ft2

) increases recovery furnace particulate loading. Other 

factors such as bed and furnace temperature, liquor solids, liquor composition, and air distribution 

also affect uncontrolled particulate emissions from recovery furnaces. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 365 

 December 17, 2007
June 4, 2006 5 

National Council for Air and Stream Improvement 

ESPs are the device of choice for controlling PM emissions from kraft recovery furnaces. The 

use of larger ESPs is expected to result in better overall PM capture efficiencies. However, this 

option is expected to be quite cost ineffective based on the high, site-specific, retrofit costs 

incurred. Moreover, with the implementation of MACT II limitations in 2004, most recovery 

furnaces are operating at or below NSPS levels (NCASI Corporate Correspondents Memo 01-01). 

Any additional benefit would thus be marginal. 

3.0 Kraft Lime Kilns 

3.1 NOx Control 

NOx emissions from lime kilns result mainly from fossil fuel burning (natural gas and fuel oil). A 

recent NCASI study involving NOx testing at 15 lime kilns verified that “thermal” NOx was the 

sole mechanism operative in gas-fired kilns, while the “fuel” NOx mechanism was mostly 

operative in oil-fired kilns. Gas-fired kiln NOx emissions appeared to be strongly dependent on 

the dry-end lime temperature. Oxygen availability in the combustion zone was determined to be 

the key factor in oil-fired kilns. NOx emissions for gas-fired kilns also exhibited high short-term 

variability, unlike for oil-fired kilns. Analysis of long-term daily average data from two lime 

kilns showed no difference in NOx emissions between days with and without LVHC NCG 

burning. An earlier NCASI study had shown that when stripper off-gases (SOGs) containing 

ammonia were burned in lime kilns, a small fraction of the ammonia, up to 23%, converts to NOx. 

A BACT analysis conducted for a new lime kiln in 1997 concluded that the use of low NOx

burners in lime kilns was technically infeasible due to complexities resulting in poor efficiency, 

increased energy usage, and decreased calcining capacity of the lime kiln. The concept of 'low 

NOx burners' is considered a misnomer in the rotary kiln industry. In boiler burners where the 

combustion air can be staged, 'low NOx' could be a genuine option. However, in rotary kilns it is 

not possible to stage the mixing in the same way. There has to be sufficient primary (burner) air 

to provide control in flame shaping although this can be limited to minimize NOx to some extent. 

Effectively, the NOx can be reduced to some extent by 'de-tuning' the burner from optimized 

combustion. However, the result is an energy penalty by way of a higher heat input per ton 

product and higher feed-end temperatures. 

Post-combustion flue gas NOx control using SCNR or SCR is not feasible due to the 

configuration of the kraft lime kiln. The necessary temperature window of 1500°F to 2000°F for 

reagent injection in the SNCR process is unavailable in a kraft lime kiln. The very high PM load 

prior to control would make SCR infeasible in advance of the controls and the requisite 

temperature window of between 550°F and 750°F for applying SCR after a PM control device is 

unavailable for a lime kiln, even for one equipped with an ESP. 

Thus, NOx control in newer lime kilns may be achieved mainly by minimizing the hot end 

temperatures in gas-fired kilns and by reducing the available oxygen in the combustion zone in 

oil-fired kilns, both combustion related modifications. However, these modifications may be 

difficult to achieve in certain existing kilns due to their inherent design. For example, in order to 

complete the calcining reactions in kilns with short residence times, it is more difficult to control 

hot end temperatures in shorter kilns than in longer ones. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 366 

 December 17, 2007
6 June 4, 2006 

National Council for Air and Stream Improvement 

3.2 SO2 Control 

Sulfur dioxide is formed in lime kilns when fuel oil or petroleum coke is burned as primary fuel. 

SO2 will also be formed if non-condensible gases (NCGs) or stripper off-gases (SOGs) containing 

sulfur are burned in the kiln. Lime muds also contain a small amount of sulfur, which when 

oxidized, would form SO2. Median sulfur content of concentrated NCGs and SOGs have been 

reported as 1.1 and 4.2 lb/ADTP (air dried ton pulp), respectively. Median sulfur contents of 7 

lime muds have been reported at 0.2%, which translates to about 1.8 lb S/ADTP. Thus, fossil 

fuels such as fuel oil, kraft mill NCG/SOGs, and soluble sulfides in lime mud can contribute a 

significant amount of sulfur to the inputs of a lime kiln. Nevertheless, the regenerated quicklime 

in the kiln acts as an excellent in-situ scrubbing agent, and venturi scrubbers following the kiln 

can further augment this SO2 removal process since the scrubbing solution becomes alkaline from 

the captured lime dust. Consequently, even though the potential for SO2 formation in a kiln that 

burns sulfur-containing fuels with or without NCGs/SOGs is high, most lime kilns emit very low 

levels of SO2 (~50 ppm). Some kilns do, however, occasionally emit higher levels of SO2 (50 to 

200 ppm). Not much is known about why this happens. 

Emission test data show that SO2 concentrations do not appear to be related to either the fuel type 

(oil, gas) or the presence or absence of concentrated NCG or SOG burning in the kiln. A 

preliminary sulfur input-output balance carried out on 25 kilns with wet scrubbers and 7 kilns 

with electrostatic precipitators (ESPs), with sulfur inputs from fuel oil, NCGs and SOGs, or just 

lime mud, showed over 95% of the SO2 generated from the oil, NCG/SOGs, or lime mud was 

captured within the kiln. For kilns with wet scrubbers (majority) that have high SO2 emissions, 

alkali addition to the scrubbing fluid could further reduce the SO2 emissions. 

3.3 Particulate Matter Control

While passing through the kiln, the combustion gases pick up a good deal of particulate matter 

both from lime mud dust formation and from alkali vaporization. This PM must be removed 

before the gases exit to the atmosphere. Mechanical devices such as dust chambers or cyclones 

are generally used to remove larger particles, which are mainly calcium-containing. A wet 

scrubber or electrostatic precipitator follows for removal of smaller particulates, which are mainly 

sodium sulfate and sodium carbonate and have aerodynamic diameters less than 10 μm. 

Kraft lime kiln PM emissions are typically controlled by venturi-type wet scrubbers. Scrubbers 

with increasingly better PM removal efficiencies, such as the Ducon Dynamic Wet Scrubber, 

have been installed up until the late 1980s. However, most of the PM control installations on 

lime kilns since about 1990 have been ESPs. Replacing a wet scrubber with an ESP will most 

likely reduce PM emissions, but may increase emissions of SO2. The wet scrubber acts as an 

additional alkaline SO2 scrubber since it captures alkaline PM leaving the kiln. Just as for 

recovery furnaces, with the implementation of MACT II limitations in 2004, most lime kilns are 

operating at or below NSPS levels. Any additional benefit would thus be marginal. 

4.0 Boilers 

The majority of pulp and paper industry boilers are combination boilers, in that they are designed to 

burn more than one fuel. Thus, it should be noted that while a particular technology may be beneficial 

for a particular pollutant, the same technology may not address the control of another pollutant. For 

example, a wood-fired boiler with a wet scrubber for PM control may obtain better PM control with 

an ESP. However, if the boiler also fires some sulfur-containing fuel (as is often the case), the 

SO2 removal capability of the wet scrubber will be sacrificed by the installation of an ESP. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 367 

 December 17, 2007
June 4, 2006 7 

National Council for Air and Stream Improvement 

4.1 Natural Gas-Fired Boilers 

Gas-fired boilers are usually not equipped with particulate collectors. SO2 emissions depend on 

the sulfur content of the gas, which is typically negligible. NOx emissions are dependent on the 

combustion temperature and the rate of cooling of the combustion products. There are several 

combustion modification techniques available to reduce the amount of NOx formed in natural 

gas-fired boilers and turbines. The two most prevalent ones are flue gas recirculation (FGR) and 

low-NOx burners. FGR reduces formation of thermal NOx by reducing peak temperatures and 

limiting availability of oxygen. Low-NOx burners reduce formation of thermal NOx by delayed 

combustion (staging) resulting in a cooler flame. In conjunction with FGR, the burners can 

achieve NOx emission reductions of 60 to 90%. Other techniques include staged combustion and 

gas reburning. In general, these techniques have been incorporated in newer boilers and thus 

their NOx emissions are lower than those of older units. 

There are also add-on control technologies that can reduce NOx emissions from gas-fired boilers 

such as selective non-catalytic reduction (SNCR) and selective catalytic reduction (SCR). 

However, since most of the pulp and paper industry gas-fired boilers are of the package boiler 

type, cost considerations typically make the use of such technologies cost ineffective. Further, 

both the SNCR and SCR technologies have not been proven to apply to industrial boilers with 

frequent swing loads. 

4.2 Fuel Oil-Fired Boilers 

For fuel oil-fired boilers, criteria pollutants can be controlled by fuel substitution/alteration, 

combustion modification and post-combustion control. Fuel substitution reduces SO2 and NOx

and involves burning an oil with lower S or N content, respectively. Particulate emissions are 

lower when burning lower sulfur content oils, especially distillate oil. 

4.2.1 NOx Control 

For boilers burning residual oil, fuel NOx is the dominant mechanism for NOx formation and thus 

the most common combustion modification technique is to suppress combustion air levels below 

the theoretical amount required for complete combustion. There are several combustion 

modification techniques available to reduce the amount of NOx formed in fuel oil-fired boilers, 

including low excess air, burners out of service, biased-burner firing, flue gas recirculation, 

overfire air, and low-NOx burners. NOx reductions that could range between 5 and 60% from 

uncontrolled systems may be expected from using these techniques. 

Post-combustion controls include SNCR and SCR. NOx reductions from 25 to 0% and from 75 to 

85% may be expected from use of SNCR and SCR systems on oil-fired boilers, respectively. 

However, just as for gas-fired boilers, most of the pulp and paper industry oil-fired boilers are of 

the package boiler type, and cost considerations typically make the use of such technologies cost 

ineffective. Furthermore, both the SNCR and SCR technologies have not been proven to apply to 

industrial boilers with frequent swing loads. 

4.2.2 SO2 Control 

SO2 emissions are controlled by a number of commercialized post-combustion flue gas 

desulfurization (FGD) processes which use an alkaline reagent to absorb SO2 in the flue gas and 

produce a sodium or calcium sulfate compound. The FGD technologies may be wet, semi-dry or 

dry depending on the state of the reagent as it leaves the absorber vessel. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 368 

 December 17, 2007
8 June 4, 2006 

National Council for Air and Stream Improvement 

4.2.3 Particulate Matter Control 

Due to the extremely low level of PM emissions, most residual oil-fired boilers do not have 

particulate matter controls. A few boilers are, however, equipped with mechanical collectors or 

ESPs. 

4.3 Coal-Fired Boilers 

4.3.1 NOx Control 

NOx emissions from coal-fired boilers can be controlled by a) combustion controls and b) postcombustion controls. Combustion controls involve a) reducing peak temperatures in the 

combustion zone, b) reducing gas residence time in the high-temperature zone, and c) air or fuel 

staging by operating at an off-stoichiometric ratio by using a rich fuel-air ratio in the primary 

flame zone and lower overall excess air conditions. The use of combustion controls depends on 

the type of boiler and the method of coal firing. Low-NOx burners and overfire air (OFA) have 

been successfully applied to tangential- and wall-fired units, whereas reburning is the only current 

option for cyclone boilers. For large base-loaded coal-fired boilers, the most developed and 

widely applied post-combustion NOx control technology is SCR. Catalyst deactivation and 

residual NH3 slip are the two key operating considerations in an SCR system. There is only 

limited experience with the use of SNCR systems on industrial coal-fired boilers. NOx reductions 

from 30-70% and from 60-90% may be expected from use of SNCR and SCR systems on baseloaded coal-fired boilers, respectively. SNCR has a narrow temperature window in which it is 

effective, in the 1500 to 1900°F range, and SCR has a similar, but lower temperature window of 

550 to 750°F. When applied to industrial boilers, neither the SNCR nor the SCR technologies 

have been proven to yield the same high NOx removal efficiencies expected when the boilers 

operate at base loads as when they operate with frequent swing loads. The inability to maintain 

good control within the required temperature window during swing loads is most likely 

responsible for this reduction. Most coal-fired boilers in the pulp and paper industry operate in 

the swing load mode, a function of supplying steam as required to the various components of the 

process. 

4.3.2 SO2 Control 

Just as in fuel oil combustion, criteria pollutants can be controlled by fuel substitution/alteration, 

combustion modification and post-combustion control. SO2 reductions can be achieved by 

burning a coal with lower S content. SO2 emissions can be controlled by a number of 

commercialized post-combustion flue gas desulfurization (FGD) processes which use an alkaline 

reagent to absorb SO2 in the flue gas and produce a sodium or calcium sulfate compound. The 

FGD technologies may be wet, semi-dry or dry depending on the state of the reagent as it leaves 

the absorber vessel. The pulp and paper industry has limited experience with operating FGD 

systems on coal- or oil-fired boilers. Retrofit considerations include space restraints in many 

facilities. 

4.3.3 Particulate Matter Control 

Particulate emissions from coal-fired boilers are controlled by using a) ESPs, b) fabric filters (FF) 

or c) venturi scrubbers. Multi-cyclones are generally used as precleaners upstream of more 

efficient ESPs or FFs. The key operating parameters that influence ESP performance include fly 

ash mass loading, particle size distribution, fly ash resistivity (which is related to coal sulfur 

content), and precipitator voltage and current. Data for ESPs applied to coal-fired boilers show 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 369 

 December 17, 2007
June 4, 2006 9 

National Council for Air and Stream Improvement 

fractional collection efficiencies greater than 99% for fine (<0.1μm) and coarse particles (>10 

μm) and a reduction in collection efficiency for particles between 0.1 and 10 μm. Operational 

parameters that affect fabric filter collection efficiency include air-to-cloth ratio, operating 

pressure loss, cleaning sequence, interval between cleanings, cleaning method, and cleaning 

intensity. Collection efficiencies of fabric filters can be as high as 99.9%. Scrubber collection 

efficiency depends on particle size distribution, gas side pressure drop through the scrubber, and 

water (or scrubbing liquor) pressure, and can range from 90 to 95% for a 2 μm particle. 

4.4 Wood-Fired Boiler Emissions 

4.4.1 NOx Control 

Most large wood-fired boilers used in the pulp and paper industry are of the spreader stoker 

design. NOx control technologies effective for use on gas and oil burners are not applicable to 

spreader-stoker design boilers. Furthermore, these boilers are often operated handling swing 

loads, which makes add-on NOx controls difficult to implement. Spreader stoker boilers 

inherently practice staged combustion, which lowers NOx emissions, but within limits. 

Fuel NOx is the dominant NOx formation mechanism operative during wood combustion. Fuel 

NOx is most efficiently controlled by staged combustion. Overfire air ports inherent to most 

spreader-stoker boilers provide for staged combustion. The underfire and overfire air are 

balanced in most wood-fired spreader stokers to control NOx. 

As with other fuels, potential post-combustion controls include SNCR and SCR. SNCR has been 

applied to a few base-loaded wood-fired boilers, mainly in the electric generating industry. 

However, its long-term efficacy on wood-fired boilers with changing loads has not been 

demonstrated. Experience in the pulp and paper industry to date has shown it has been used on 

occasions for polishing, to get perhaps 10-20% NOx reduction during periods of air quality 

problems. The problem with control of the required temperature window is an inherent difficulty 

with use of SNCR for load-following boilers, whether wood or fossil fuel. Inadequate reagent 

dispersion in the region of reagent injection in wood-fired boilers is also a factor mitigating 

against the use of SNCR technology. At least one pulp mill wood-fired boiler met with 

significant problems and had to abandon their SNCR system. Significant ammonia slip, caused 

by inefficient dispersion of the reagent within the boiler, was to blame. 

The use of SCR on wood-fired boilers operating in the forest products industry has also never 

been successfully demonstrated for spreader stoker boilers, and would face the same inherent 

problem of requiring it to be post PM-control to protect the catalyst, and achieving and 

maintaining the required temperature window for effective NOx control. 

4.4.2 Particulate Matter Control 

Particulate matter is the air pollutant of primary concern in wood-fired boilers. As for coal-fired 

boilers, the most common devices used to control particulate emissions from wood-fired boilers 

are wet scrubbers and electrostatic precipitators (ESPs). Fabric filters (FF) and the electrified 

gravel bed filter (EGF) have been used on a few units. Wet scrubbers are widely used, operating 

at gas pressure drops ranging from 6 to 25” H2O. Liquid to gas ratios in the venturi system 

typically range from 8 to 10 gal H2O/1000 acfm saturated. Solids buildup in the recirculation 

loop rarely is allowed to exceed 5% by weight. High carbon ash resulting from wood combustion 

is more difficult to remove with an ESP due to its high conductivity/low resistivity. Thus, 

specific collection areas (ratio of ESP plate area to gas flow volume through the ESP) for ESPs 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 370 

 December 17, 2007
10 June 4, 2006 

National Council for Air and Stream Improvement 

on wood-fired boilers are greater than for those for coal-fired boilers, ranging from about 300 to 

500 ft2

/1000 acfm. Power requirements range from 150 to about 400 watts per acfm. To address 

fire concerns, ESPs on wood-fired boilers are sometimes operated in the wet mode, where the 

collection plates and internal parts are wetted continuously with water. A pre-quench is generally 

used to saturate the gas stream. Fabric filters are rarely used on wood-fired boilers due to 

concerns about bag flammability. Fabric filters have been successfully used where bark from 

logs stored in salt water is burned and the salt reduces the fire hazard. In this situation, the fabric 

filter is effective in removing the very small salt particulates exiting the boiler. Gravel-bed filters 

have a slowly moving bed of granular “rock” as the filtration medium through which the flue gas 

must travel. These systems are electrostatically augmented (10 to 20 watts/1000 acfm). A high 

voltage (about 50 kV) is applied to an electrical conductor positioned within the bed and this 

creates an electrical field between the conductor and the inlet and outlet louvers. Particulate 

collection efficiencies for wood-fired boilers range from 65 to 95% for two multiclones in series, 

over 90% for wet scrubbers, from 93 to 99.8% for ESPs and FFs and about 95% for EGFs. Once 

again, it should be noted that most wood-fired boilers are combination boilers that may burn other 

sulfur-containing fuels. Thus, a change in the control device might affect the ability to control 

other pollutants. For example, replacing a wet scrubber with an ESP for better PM control would 

result in higher SO2 emissions from a boiler burning wood in combination with oil or coal. 

5.0 Other Source Emissions 

5.1 Slakers - PM emissions 

Slakers are generally vented through a stack to discharge the large amounts of steam generated. 

The steam may contain particulate matter, which is largely calcium and sodium carbonates and 

sulfates. Scrubbers are generally employed to capture this particulate matter. Other PM control 

devices such as ESPs and fabric filters are both technologically infeasible (very high moisture 

source) and not cost effective. 

5.2 Smelt Dissolving Tanks - PM Emissions 

As with the recovery furnace, particulate emissions from smelt tanks are comprised of mainly 

sodium compounds with much lesser amounts of potassium compounds and some other trace 

metal compounds. The dominant compound is sodium carbonate, followed by sodium sulfate. 

Roughly 90% (by weight) of the particles have equivalent aerodynamic diameters under 10 μm, 

and 50% have diameters under 1 μm. Most smelt tank PM emissions are controlled by wet 

scrubbers, many of which are wetted fan scrubbers that are very effective in removing fine 

particulate. A dry ESP is once again infeasible as an option due to the high moisture content of 

the gases. The wet scrubber also serves to control total reduced sulfur compound emissions 

through pH control, thus replacing it with a wet ESP is not an option. As noted for other kraft 

mill sources, MACT II Implementation in 2004 has also resulted in significantly reduced 

allowable PM emissions from smelt dissolving tanks. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 371 

 December 17, 2007
APPENDIX C 

Public Notice for BART Title V Air Permit Modification 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 372 

 December 17, 2007
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES 

PUBLIC NOTICE AND NOTICE OF INTENT TO ISSUE AIR QUALITY PERMITS 

Notice is hereby given for a public hearing to be heard by the North Carolina Department of Environment 

and Natural Resources (DENR), Division of Air Quality (DAQ), concerning the proposed Regional Haze 

state implementation plan (SIP) and preliminary best available retrofit technology (BART) determinations. 

DAQ also hereby gives notice of intent to issue an Air Quality Permit to each of the facilities noted in the 

information section below. 

PURPOSE: The hearing is intended to inform interested parties on the Regional 

Haze SIP including BART determinations and intent to issue related 

Air Quality Permits. 

DATES AND LOCATIONS: November 13, 2007, 6:30 p.m., Asheville-Buncombe Technical 

Community College Main Campus, 1st Floor Lecture Room, 

Simpson Administrative Building, 340 Victoria Road, Asheville, 

NC 28801. 

November 15, 2007, 6:30 p.m., at the DENR Washington Regional 

Office, 943 Washington Square Mall, DENR Hearing Room, 

Washington, NC, 27889. 

COMMENT PROCEDURES: All persons interested in these matters are invited to attend the 

public hearing. Any person desiring to comment is requested to 

submit a written statement for inclusion in the record of proceedings 

at the public hearing. The hearing officer may limit oral 

presentation lengths if many people want to speak. The hearing 

record will remain open until November 26, 2007, to receive 

additional written statements. 

INFORMATION: Copies of the proposed Regional Haze SIP, the BART 

determinations, related permit reviews and draft permits, and a 

summary of initial Federal Land Managers comments on the 

Regional Haze SIP may be downloaded at 

http://daq.state.nc.us/planning/nc.sip.shtml. The documents may 

also be reviewed at the offices of the North Carolina Department of 

Environment and Natural Resources, Division of Air Quality, 

located in: 

 Raleigh, Planning Section (919) 715-7670 

Raleigh, Permits Section (919) 715-6237 

 Asheville Regional Office (828) 296-4500 

 Washington Regional Office (252) 946-6481 

Comments should be sent to and additional information concerning 

the hearings or the proposals may be obtained by contacting: 

 Ms. Laura Boothe 

Acting Chief, Planning Section 

 Division of Air Quality 

 1641 Mail Service Center 

 Raleigh, NC 27699-1641 

 Phone: (919) 733-1488 

 Fax: (919) 715-7476 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 373 

 December 17, 2007
daq.publiccomments@ncmail.net (Note: In the subject line 

type Regional Haze SIP) 

The following two facilities have submitted BART determinations 

under 15A NCAC 02D .0543 Best Available Retrofit Technology 

for DAQ to review and have applied for an Air Quality Permit 

which meets the requirements specified in 15A North Carolina 

Administrative Code 02Q .0300: 

PCS Phosphate Company 

1530 NC 306 South 

Aurora, NC 27806 

Beaufort County 

Permit # 04176 T34 App# 0700071.06D 

Blue Ridge Paper Company 

175 Main Street 

Canton, NC 28716 

Haywood County 

Permit # 08961 – T09 App# 440159.06E 

Comments should be sent to and additional information regarding 

the Air Quality Permits may be obtained by contacting: 

Mr. Donald van der Vaart, Ph. D., P.E. 

Chief, Air Permits Section 

Division of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

Attn: Permits Section 

Phone: (919) 715-6253 

Fax: (919) 733-5317 

All comments received by November 26, 2007 will be considered in 

the final determinations regarding these Air Quality Permits. 

Date: ______________________ 

B. Keith Overcash, P.E., Director 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 374 

 December 17, 2007
APPENDIX D 

Draft Air Permit 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 375 

 December 17, 2007
CERTIFIED MAIL DRAFT 

????, 200? 

Mr. Robert A. Shanahan 

VP, Manufacturing and Mill Manager 

Blue Ridge Paper Products, Inc 

P.O. Box 4000 

Canton, North Carolina 28716 

Dear Mr. Shanahan: 

SUBJECT: Air Quality Permit No. 08961T?? 

Facility ID: 4400159 

Blue Ridge Paper Products, Inc. 

Canton, Haywood County, North Carolina 

Fee Class: Title V 

Site No. 01/44/0159 

In accordance with your completed Air Quality Permit Application 4400159.06E. for a significant 

permit modification of a Title V permit received November 16, 2006, we are forwarding herewith Air 

Quality Permit we are forwarding herewith Air Quality Permit No. 08961T?? to Blue Ridge Paper 

Products, Inc., Canton, North Carolina authorizing the construction and operation, of the emission source(s) 

and associated air pollution control device(s) specified herein. Additionally, any emissions activities 

determined from your Air Quality Permit Application as being insignificant per 15A North Carolina 

Administrative Code 2Q .0503(8) have been listed for informational purposes as an "ATTACHMENT." 

Please note the requirements for the annual compliance certification are contained in General Condition P in 

Section 3 of Part I. The current owner is responsible for submitting a compliance certification for the 

entire year regardless of who owned the facility during the year.

As the designated responsible official it is your responsibility to review, understand, and abide by 

all of the terms and conditions of the attached permit. It is also your responsibility to ensure that any 

person who operates any emission source and associated air pollution control device subject to any term or 

condition of the attached permit reviews, understands, and abides by the condition(s) of the attached permit 

that are applicable to that particular emission source. 

If any parts, requirements, or limitations contained in this Air Quality Permit are unacceptable to 

you, you have the right to request a formal adjudicatory hearing within 30 days following receipt of this 

permit, identifying the specific issues to be contested. This hearing request must be in the form of a 

written petition 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 376 

 December 17, 2007
Mr. Robert A. Shanahan DRAFT 

???, 200? 

Page 2 

conforming to NCGS (North Carolina General Statutes) 150B-23, and filed with the Office of 

Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714.The form for 

requesting a formal adjudicatory hearing may be obtained upon request from the Office of Administrative 

Hearings. Unless a request for a hearing is made pursuant to NCGS 150B-23, this Air Quality Permit shall 

be final and binding. 

You may request modification of your Air Quality Permit through informal means pursuant to 

NCGS 150B-22. This request must be submitted in writing to the Director and must identify the specific 

provisions or issues for which the modification is sought. Please note that this Air Quality Permit will 

become final and binding regardless of a request for informal modification unless a request for a hearing is 

also made under NCGS 150B-23. 

The construction of new air pollution emission source(s) and associated air pollution control 

device(s), or modifications to the emission source(s) and air pollution control device(s) described in 

this permit must be covered under an Air Quality Permit issued by the Division of Air Quality prior 

to construction. Failure to do so is a violation of GS 143-215.108 and may subject the Permittee to 

civil or criminal penalties as described in GS 143-215.114A and 143-215.114B.

This Air Quality Permit shall be effective from ???, ???? until March 31, 2012, is nontransferable 

to future owners and operators, and shall be subject to the conditions and limitations as specified therein. 

Should you have any questions concerning this matter, please contact Mr. Wallace Pitts at (919) 

715-1060. 

Sincerely yours, 

Donald R. van der Vaart, Ph.D., P.E. 

Chief 

Enclosure 

c: Asheville Regional Office 

Central Files 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 377 

 December 17, 2007
DRAFT 

Changes to the Title V permit are as follows: 

PAGE CONDITION CHANGE 

All ~ Revised permit number and dates 

All 2.1 emission 

source tables 

Updated tables to identify emission sources subject to 15A NCAC 2D 

.0543 “Best Available Retrofit Technology (BART) 

82 2.4 Added 2.4 with BART determination for affected emission sources. 

ATTACHMENT A 

List of Insignificant Activities under 2Q .0503(8)

Emission Source I.D. 

IEmission Source Description 

G01001 Chip Unloading 

G03007 Reject knots 

G03008 Brownstock Washing B Other Units 

G05073 (MRP) Minerals removal process 

G06015 Methanol Storage 

G07017 Evaporator Other Units 

G08074 Chloride Removal Process (CRP) 

G09030 Lime Kiln Scrubber Sump Tanks 

G09033 Lime Kiln Area Other Sources 

G10036.Center Causticizer 

G10036.East Causticizer 

G10036.South Causticizer 

G10036.West Causticizer 

G10036.WLCCen White liquor clarifier 

G10036.WLCEas White liquor clarifier 

G10036.WLCSou White liquor clarifier 

G10036.WLCWes White liquor clarifier 

G10090 Green Liquor Stabilization Tank 

G10091 Lime Mud Washers and Storage 

G11041 No. 4 Boiler Coal Bunker 

G11043 Bark Storage and Handling 

G11046 Cooling Towers 

G11047 Power Boilers Other Units 

G10079 No. 4 Power boiler flyash storage silo (180,000 gallons; ID No. G1145) 

11-CU-006-01 Urea solution storage tanks for SNCR System 

G12052 No. 20 Paper Machine Trim System 

G12077 No. 19 Machine Calendar Nip Heaters 

G13053 Paper Machine Additives Area 

G16057 Backup Lime Dewatering System 

G16080 WTP Low Lift and Splitter Box 

G16083 WTP Secondary Clarifiers 

G16084 WTP Sludge Presses and Pile 

G16085 WTP Other Sources 

G20075 Main Turpentine Tank 

G21062 Tall Oil Finishing Plant 

G21063 Tall Oil Manufacturing Plant 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 378 

 December 17, 2007
Emission Source I.D. 

IEmission Source Description 

G21076 MQB Storage Tank 

G23064 Liquid Chemical Storage 

G23065 Bleached Stock Storage 

G23066.a Sewer Lines 

G23066.b Truck Traffic Fugitives 

G23066.c Coal Handling Fugitives 

G23066.d Water Treatment 

G23066.e Depoly System 

G23066.f-ire Two 200 horsepower, diesel generators used in the fire control system 

G23066.f-gen One 64 horsepower and one 227 horsepower diesel engine used to turn the 

lime kiln in the event of sudden power loss 

G23066.f-rec One 100-kW, diesel generator used for emergency breakdowns of the recovery 

furnaces in the event of sudden power loss 

G23066.g Propane Vaporizer 

G23066.h Paint Shop Activities 

G23066.i Maintenance Shop Activities 

G23066.j Carpentry Shop Activities 

G23067 Parts Washers 

G24093 Pre-Bleach B Other Sources 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 379 

 December 17, 2007
State of North Carolina, 

Department of Environment, 

and Natural Resources 

Division of Air Quality DRAFT

AIR QUALITY PERMIT

Permit No. Replaces Permit No.(s) Effective Date Expiration Date 

08961T?? 08961T?? ????, ???? March 31, 2012 

Until such time as this permit expires or is modified or revoked, the below named Permittee is authorized to operate, as 

outlined in Part I, and to construct, as outlined in Part II, the emission source(s) and associated air pollution control 

device(s) specified herein, in accordance with the terms, conditions, and limitations within this permit. This permit is 

issued under the provisions of Article 21B of Chapter 143, General Statutes of North Carolina as amended, and Title 15A 

North Carolina Administrative Codes (15A NCAC), Subchapters 2D and 2Q, and other applicable Laws. 

Pursuant to Title 15A NCAC, Subchapter 2Q, the Permittee shall not construct, operate, or modify any emission source(s) 

or air pollution control device(s) without having first submitted a complete Air Quality Permit Application to the permitting 

authority and received an Air Quality Permit, except as provided in this permit. 

Permittee: Blue Ridge Paper Products, Inc. 

Facility ID: 4400159 

Facility Site Location: 175 Main Street

City, County, State, Zip: Canton, Haywood County, North Carolina, 28716 

Mailing Address: P.O. Box 4000

City, State, Zip: Canton, North Carolina 28716 

Application Number: 4400159.06E 

Complete Application Date: November 16, 2006

Primary SIC Code: 2621

Division of Air Quality, Asheville Regional Office

Regional Office Address: 2090 US Highway 70 Swannanoa, North Carolina, 28778

Permit issued this the ??th day or ???, ???? 

_________________________________________________ 

Donald R. van der Vaart, Ph.D., P.E.., Chief, Air Permits Section 

By Authority of the Environmental Management Commission 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 380 

 December 17, 2007
Table Of Contents

PART I 

SECTION 1: PERMITTED EMISSION SOURCE(S) AND ASSOCIATED 

AIR POLLUTION CONTROL DEVICE(S) AND APPURTENANCES 

SECTION 2: SPECIFIC LIMITATIONS AND CONDITIONS 

2.1- Emission Source(s) Specific Limitations and Conditions 

(Including specific requirements, testing, monitoring, recordkeeping, and 

reporting requirements) 

2.2- Multiple Emission Source(s) Specific Limitations and Condition 

 (Including specific requirements, testing, monitoring, recordkeeping, and 

reporting requirements) 

2.3- State Only Applicable Requirements 

2.4 - Multiple Emission Source(s) Specific Limitations and Conditions – Best Available 

Control Technology (BART) 

SECTION 3: GENERAL PERMIT CONDITIONS 

ATTACHMENT 

List of Acronyms 

PART II This permit does not contain a Part II 

SECTION 3: GENERAL PERMIT CONDITIONS

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 381 

 December 17, 2007
Permit 08961T?? DRAFT

Page 3 

PART I 

The Division of Air Quality (DAQ), the United States Environmental Protection Agency (EPA), and citizens as defined under 

the Federal Clean Air Act have the authority to enforce the terms, conditions, and limitations contained in Part I of this permit 

unless otherwise specified. 

Under Title 15A NCAC 2Q, the operation of emission source(s) and associated air pollution control device(s) and 

appurtenances listed in Part I of this permit is based on plans, specifications, operating parameters, and other information as

submitted in the Air Quality Permit Application. 

SECTION 1- PERMITTED EMISSION SOURCE(S) AND ASSOCIATED 

AIR POLLUTION CONTROL DEVICE(S) AND 

APPURTENANCES 

The following table contains a summary of all permitted emission sources and associated air pollution control devices and appurtenances: 

Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G01002* Chip Handling Operations NA NA 

G01003* Chip Storage Area NA NA 

G02004 

MACT, Subpart S

Digester area, including: 

eighteen (18) batch digesters 

Hardwood - No.1 Blow Tank, 

No. 1 Fiberline Accumulator, 

No. 1 Secondary Condenser 

Pine - No.2 Blow Tank, No. 2 

Fiberline Accumulator, No. 2 

Secondary Condenser 

G09028 

(primary) 

or 

G09029 

(backup) 

G07018 

Lime Kiln No. 4 via NCG 

closed collection system 

Lime Kiln No. 5 via NCG 

closed collection system 

Foul condensate via closed 

collection system 

G03005 

MACT, Subpart S 

G03006 

MACT, Subpart S

No. 1 Hardwood Fiberline 

brownstock washing 

No. 2 Pine Fiberline 

brownstock washing 

NA 

G03007* Reject Knots NA NA 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 382 

 December 17, 2007
Permit 08961T?? DRAFT

Page 4 

Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G04009

MACT, Subpart S

G04010 

MACT, Subpart S

No. 1 Hardwood Fiberline 

oxygen delignification system 

including one O2 reactor, one 

oxygen blow tank, and postO2 washers 

No. 2 Pine Fiberline oxygen 

delignification system 

including one O2 reactor, one 

oxygen blow tank, and postO2 washers 

NA 

NA 

G04011 white liquor oxidation system 

(maximum production rate of 

40,500 pounds white liquor per 

hour) 

04-CD-021-01 One mist eliminator 

G04025 

MACT, Subpart S

No. 1 Hardwood Fiberline 

Pulp Screening System 

NA 

G04026 

MACT, Subpart S

No. 2 Pine Fiberline Pulp 

Screening System 

NA 

G05012 

MACT, Subpart S

No. 1 Hardwood Fiber 

Bleaching Line 

chlorine dioxide stage (D1), 

extraction stage (EO), final 

chlorine dioxide stage (D2), 

washer hoods, towers and 

filtrate tanks of the hardwood 

bleaching system 

05-CD-002-01 one counter-current packed 

tower wet scrubber (190 

gallons per minute design 

flow rate) 

G05013 

MACT, Subpart S

No. 2 Pine Fiber Bleaching 

Line 

chlorine dioxide stage (D1), 

extraction stage (EO), final 

chlorine dioxide stage (D2), 

towers and filtrate tanks of the 

pine bleaching system 

05-CD-017-01 one counter-current packed 

tower wet scrubber (70 

gallons per minute oxidized 

white liquor design flow 

rate) 

G05073* Minerals Removal Process 

(MRP) 

NA NA 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 383 

 December 17, 2007
Permit 08961T?? DRAFT

Page 5 

Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G06014 

06-PU-002 

06-TK-007 

06-TK-008 

06-TK-009 

112(r)

chlorine dioxide generation 

system including : 

one R-8 chlorine dioxide 

generator, and 

three chlorine dioxide solution 

storage tanks (125,000 gallons 

capacity, each) 

06-CD-002-01 

When the No.1 

Fiber Bleach 

Line is in 

operation, the 

No. 1 Fiber 

Bleach Line (ID 

No. 05-CD-002-

01) wet 

scrubber is 

operated in 

series with the 

above unit 

one two section packed 

tower wet scrubber (70 to 80 

gallons of chilled water per 

minute) 

one counter-current packed 

tower wet scrubber (190 

gallons per minute white 

liquor design flow rate) 

G07016-Swenson 

MACT, Subpart S 

G07016-West GB 

MACT, Subpart S 

One Swenson counter current 

evaporator (147,402 pounds 

per hour black liquor solids 

maximum capacity) consisting 

of six effects and one 

concentrator, with the fourth, 

fifth, and sixth effect venting 

to the foul condensate 

collection system via the 

hotwell; 

West GB counter-current 

evaporator (131,614 pounds 

per hour black liquor solids 

maximum capacity) consisting 

of six effects and steam liquor 

 heater, with the second 

through the sixth effect venting 

to the foul condensate 

collection system via the 

hotwell; 

G09028 

(primary) 

or 

G09029 

(backup) 

G07018 

(Control system 

serves both 

evaporators) 

Lime Kiln No. 4 via NCG 

closed collection system 

Lime Kiln No. 5 via NCG 

closed collection system 

Foul condensate via closed 

collection system 

G07018 

NSPS, Subpart BB 

MACT, Subpart S

foul condensate collection 

system consisting of a steam 

stripper (CD-006-01) and 

associated stripper feed tank 

and reflux tank 

G09029 

(primary) 

or 

G09028 

(backup) 

Lime Kiln No. 5 via NCG 

closed collection system 

Lime Kiln No. 4 via closed 

collection system 

G07019 Four (4) Heavy Black Liquor 

Storage Tanks 

NA NA 

G07086 Eight (8) Weak Black Liquor 

Storage Tanks 

NA NA 

BART Related Documentation 

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Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G08020 

MACT, Subpart MM 

BART

No. 10 new design recovery 

furnace (121,000 pounds per 

hour maximum black liquor 

solids firing rate and 382 

million Btu per hour maximum 

heat input rate from No. 6 fuel 

oil) 

08-CD-001-01 3-Chamber, 6-field 

electrostatic precipitator 

(115,236 square feet of plate 

area) 

G08021 

MACT, Subpart MM 

BART

No. 11 new design recovery 

furnace (121,000 pounds per 

hour maximum black liquor 

solids firing rate, 382 million 

Btu per hour maximum heat 

input rate from No. 6 fuel oil, 

and 0.25 million Btu per hour 

maximum heat input rate from 

propane ignition) 

08-CD-002-01 3-Chamber, 4-Field 

electrostatic precipitator 

(115,236 square feet of plate 

area) 

G08022 

BART 

black liquor oxidation system 

(228,000 pounds per hour 

maximum feed rate based on 

calendar day average 

CD-BLO 

cyclone 

CD-BLOXRTO 

CD-RTOSCR 

3 cyclones (60 inches in 

diameter each); 

one natural gas-fired 

regenerative thermal 

oxidizer (4.2 million Btu per 

hour heat input); 

one caustic scrubber (5 to 7 

gallon per minute NaOH 

injection design flow rate) 

G08023 

MACT, Subpart MM 

BART

No. 10 recovery furnace smelt 

dissolving tank (121,000 

pounds per hour black liquor 

solids feed rate) 

08-CD-011-01 chevron mist eliminator 

(33.5 square feet of 

collection surface area) 

G08024 

MACT, Subpart MM 

BART

No. 11 recovery furnace smelt 

dissolving tank (121,000 

pounds per hour black liquor 

solids feed rate) 

08-CD-012-01 chevron mist eliminator 

(33.2 square feet of 

collection surface area) 

G09027.4 

G09027.5 

G09027.6 

No. 4 Precoat Filter 

No. 5 Precoat Filter 

No. 6 Precoat Filter 

NA NA 

G09028 

MACT, Subpart MM

No. 6 fuel oil-fired No. 4 lime 

kiln (9.0 tons per hour 

maximum calcium oxide 

design capacity; 60 million 

Btu/hr maximum heat input 

rate with primary NCG and 

backup SOG combustion 

09-CD-009-01 cyclonic mist eliminator 

(120 inches in diameter) 

installed in series with a 

flooded disc-type wet 

scrubber (360 gallons per 

minute liquid design flow 

rate, with pH control) 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 385 

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Page 7 

Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G09029 

MACT, Subpart MM

No. 6 fuel oil-fired No. 5 lime 

kiln (12.0 tons per hour 

maximum calcium oxide 

design capacity; 100 million 

Btu/hr maximum heat input 

rate with backup NCG and 

primary SOG combustion 

09-CD-010-01 one 4-stage MicroMistTM

venturi scrubber [quench, 

venturi, impingement tray, 

and chevron mist eliminator 

(156 inches in diameter)] 

(250 gallons per minute 

venturi design rate, with pH 

control) 

G09031.1 

G09031.2 

G09031.3 

No. 6 lime storage silo 

No. 6 fresh lime storage silo 

(150 tons maximum capacity 

each) 

No. 6 lime conveyor 

09-CD-018-01 cartridge filter (1,728 square 

feet of filter area) 

G09032 No. 5 lime dust collection 

system installed on the hot 

lime conveyor, lime crusher, 

bucket elevator and lime 

storage silo (400 tons 

maximum capacity) 

09-CD-013-01 cartridge filter (1,728 square 

feet of filter area) 

G10035 No. 5 lime slaker serving No. 5 

lime kiln 

10-CD-027-01 one natural draft condensing 

scrubber (nominal 30 

gallons per minute mill 

water injection rate) 

G10034 No. 6 lime slaker serving No. 4 

lime kiln 

10-CD-036-01 one natural draft scrubber 

(nominal 30 gallons per 

minute mill water injection 

rate) 

G10036 Green Liquor Clarification NA NA 

G10090* Green Liquor Stabilization NA NA 

G11037 coal -fired Big Bill utility 

boiler (364 million Btu per 

hour maximum heat input rate) 

equipped with low NOx 

burners and natural gas igniters 

to be installed 

11-CD-003-01 2-Chamber, 3-Field 

electrostatic precipitator 

(51,840 square feet of plate 

area) 

G11038 coal-fired Peter G. utility 

boiler(364 million Btu per 

hour maximum heat input rate) 

equipped with low NOx 

burners and natural gas igniters 

11-CD-004-01 2-Chamber, 3-Field 

electrostatic precipitator 

(51,840 square feet of plate 

area) 

G11039 coal-fired Riley Coal utility 

boiler (399 million Btu per 

hour maximum heat input rate) 

equipped with low NOx 

burners and natural gas igniters 

11-CD-005-01 2-Chamber, 3-Field 

electrostatic precipitator 

(67,392 square feet of plate 

area) 

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Appendix L.10 - 386 

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Page 8 

Emission Source ID 

No. 

Emission Source Description Control Device 

ID No. 

Control Device Description 

G11040

NSPS, Subpart D PSD 

coal / No. 6 fuel oil-fired No. 4 

utility boiler (535 million Btu 

per hour maximum heat input 

rate) equipped with low NOx 

burner components and 

Separated Over fire Air 

(SOFA) system 

11-CD-006-01 

11-CD-006-02 

2-Chamber, 4-Field 

electrostatic precipitator 

(115,000 square feet of plate 

area) 

urea-based Selective NonCatalytic Reduction (SNCR) 

NOx emission reduction 

system 

G11042 woodwaste/ bark/ depoly 

waste/ fiber-based roll 

cores/coal-fired Riley bark 

boiler (380 million Btu per 

hour maximum heat input rate) 

with partial flyash reinjection, 

equipped with a multicyclone 

and a venturi-type wet 

scrubber in series 

11-CD-016-01 

11-CD-016-02 

multicyclone (approximately 

160 tubes, 9 inches in 

diameter each) 

venturi-type wet scrubber 

G11044 a bark fuel feed system and 

associated transfer cyclone 

and a depoly feed system and 

associated transfer cyclone 

NA NA 

G11045 

G11025 

Utility boiler flyash handling 

system consisting of the main 

flyash silo (25,300 cubic feet) 

and pneumatic flyash 

collection system and separate 

No. 4 Power Boiler flyash 

transfer silo (600 cubic feet) 

11-CD-021-01 

11-CD-021-02 

11-CD-021-03 

One bin vent bagfilter (95 

square feet of filter area); 

one cyclone separator with 

bagfilter (479 square feet of 

filter area); 

one bin vent bagfilter (26 

square feet of filter area) 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 387 

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G12048 

G12049 

G12050 

G12051 

No 20 Paper Machine 

No 19 Paper Machine 

No12 Paper Machine 

No 11 Paper Machine 

NA NA 

G13054 

G13055 

G13056 

East starch storage silo 

 

West starch storage silo 

Center starch storage silo 

(30 tons per hour maximum 

throughput, each) 

13-CD-014-01 

13-CD-016-01 

13-CD-020-01 

one bagfilter (255 square 

feet of filter area); 

one bin vent filter (183 

square feet of filter area); 

one bagfilter (255 square 

feet of filter area); 

G16081 WTP Primary Clarifiers NA NA 

G16082 WTP Aeration and Digestion 

Basins 

NA NA 

G19058 Rewinders on Trim System #1 NA NA 

G10959 Rewinders on Trim System #2 NA NA 

G20060 

MACT, Subpart S

No.1 Hardwood Turpentine 

Recovery System 

G09028 

(primary) 

or 

G09029 

(backup) 

G07018 

Lime Kiln No. 4 via closed 

NCG collection system 

Lime Kiln No. 5 via closed 

collection system 

Foul condensate via closed 

collection system 

G20062 

MACT, Subpart S

No.2 Pine Turpentine 

Recovery System 

G09028 

(primary) 

or 

G09029 

(backup) 

G07018 

Lime Kiln No. 4 via closed 

NCG collection system 

Lime Kiln No. 5 via closed 

NCG collection system 

Foul condensate via closed 

collection system 

G21072 Tall Oil Reactor 21-ST-008-01 packed tower-type wet 

scrubber (10 to 15 gallons 

per minute white liquor) 

G23078 NCG Collection System NA NA 

G24087 

MACT, Subpart S

No. 1 Hardwood Fiberline 

Deckers 

NA NA 

G24088 

MACT, Subpart S

No. 2 Pine Fiberline Deckers NA NA 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 388 

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Page 10 

G24092* Hardwood Brownstock High 

Density Storage 

NA NA 

G24094* Pine Brownstock High Density 

Storage 

NA NA 

16-CU-001 

MACT, Subpart 

ZZZZ 

one 1850 horsepower, dieselfired emergency generator 

NA NA 

*Sources with no applicable requirements that emit greater than deminimis for classification as Insignificant Activities per 15A NCAC 2Q .0503(8). 

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Appendix L.10 - 389 

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SECTION 2 - SPECIFIC LIMITATIONS AND CONDITIONS

2.1- Emission Source(s) and Control Devices(s) Specific Limitations and 

Conditions

The emission source(s) and associated air pollution control device(s) and appurtenances listed below are subject to the 

following specific terms, conditions, and limitations, including the testing, monitoring, recordkeeping, and reporting 

requirements as specified herein: 

DIGESTER AREA (AREA 02) 

A. The Digester Area (ID No. G02004) containing: 

eighteen (18) batch digesters (ID Nos. 02-PU-001thru 018); 

the No. 1 Hardwood Blow Heat System consisting of: 

the No. 1 Blow Tank (ID No. 02-PU-005), 

the No. 1 Fiberline Accumulator (ID No. 02-PU-006), and 

the No. 1 Secondary Condenser (ID No. 02-PU-008); 

the No. 2 Pine Blow Heat System consisting of: 

the No. 2 Blow Tank (ID No. 02-PU-003), 

the No. 2 Fiberline Accumulator (ID No. 02-PU-007), and 

the No. 2 Secondary Condenser (ID No. 02-PU-009). 

Foul gases are collected by the Low Volume, High Concentration (LVHC) Gas Collection 

System (ID No. G23078) for burning in Lime Kiln No. 4 (IDNo.G09028) or Lime Kiln No. 5 

(ID No. G09029). Foul condensates are collected via the closed Foul Condensate Collection 

System. 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

total reduced sulfur (TRS) 5 ppm by volume on a dry basis 15A NCAC 2D .0528

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart S (See Section 2.2.C.) 15A NCAC 2D .1111 

1. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS 

a. The emissions of total reduced sulfur shall not exceed five parts per million from any digester system, 

measured as hydrogen sulfide on a dry gas basis and averaged per discrete contiguous 12-hour time period. 

[15A NCAC 2D .0528] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 A. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Digester Area emission sources, shall comply with the limitation above by ensuring the following: 

i. The gases are combusted in the No. 4 Lime Kiln (ID No. G09028) or; 

ii. The gases are combusted in the No. 5 Lime Kiln (ID No. G09029). 

d. The Permittee shall follow the closed vent inspection procedures per Specific Condition 2.2 .C. to insure that 

the emissions are routed to either the No. 4 Lime Kiln (ID No. G09028) or No. 5 Lime Kiln (ID No. G09029) 

as specified above. The Permittee shall be deemed in noncompliance with 2D .0528 if these procedures are 

not followed or if the records are not maintained. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 390 

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Page 12 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

BROWNSTOCK WASHING (Area 03) 

B. The Brownstock Washing Area containing: 

the No. 1 Hardwood Fiberline Brownstock Washing System (ID No. G03005) and 

the No. 2 Pine Fiberline Brownstock Washing System (ID No. G03006). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart S (See Section 2.2.C.) 15A NCAC 2D .1111 

OXYGEN DELIGNIFICATION (Area 04) 

C. The Oxygen Delignification Area containing: 

the No. 1 Hardwood Fiberline Oxygen Delignification System (ID No. G04009) and 

the No. 2 Pine Fiberline Oxygen Delignification System (ID No. G04010). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart S (See Section 2.2.C.) 15A NCAC 2D .1111 

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Regional Haze SIP for NC Class I Areas 

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Page 13 

D. White Liquor Oxidizer (ID No. G04011) equipped with a chevron demister (ID No. 04-CD021-01) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 x P0.67

Where: 

E = allowable emission rate in pound per hour 

P = process weight rate in tons per hour 

15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES 

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated 

by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 D. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the White Liquor Oxidizer (ID No. G04011) shall be controlled by the 

demister. To assure compliance, the Permittee shall perform inspections and maintenance. As a minimum, the 

inspection and maintenance requirement shall include the following: 

i. a monthly visual inspection (for each calendar month, not to exceed 6 weeks from the previous inspection) of 

the system ductwork and material collection unit for leaks; and 

ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous inspection) 

of the demister’s structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and demister are not 

inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site 

and made available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action;

ii. the results of each inspection; 

iii. the results of any maintenance performed on the demister; and 

iv. any corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit the results of any maintenance performed on the demister within 30 days of a 

written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before 

January 30 of each calendar year for the preceding six-month period between July and December and July 30 of 

each calendar year for the preceding six-month period between January and June. All instances of deviations 

from the requirements of this permit must be clearly identified. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 392 

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Page 14 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

a. Visible emissions from the White Liquor Oxidizer (ID No. G04011) shall not be more than 20 percent 

opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 

percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) and 

General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 D.2.a. above, 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of this source for any 

visible emissions above normal. If the emission source(s) are not operating, a record of this fact along with 

the corresponding date and time shall substitute for the monthly observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 D. 2.a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 393 

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Page 15 

BLEACHING (Area 05) 

E. The No. 1 Hardwood Fiberline Bleaching System (ID No. G05012) consisting of: 

a chlorine dioxide stage (D1), extraction stage (Eo), final chlorine dioxide stage (D2), 

washer hoods, towers and filtrate tanks of the hardwood bleaching system exhausts to 

the No. 1 Fiberline Bleaching packed tower-type wet scrubber (190 gallons per minute 

oxidized white liquor design flow rate, ID No. 05-CD-002-01); and 

The No. 2 Pine Fiberline Bleaching System (ID No. G05013) consisting of: 

a chlorine dioxide stage (D1), extraction stage (Eo), final chlorine dioxide stage (D2), 

towers and filtrate tanks of the pine bleaching system exhausts to the No. 2 Fiberline 

Bleaching packed tower-type wet scrubber (70 gallons per minute oxidized white liquor 

design flow rate, ID No. 05-CD-017-01). 

The Eo stages are not required to be controlled for MACT compliance. Total production of 

1,420 air dried bleached tons of combined hardwood and pine per calendar day. 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart S (See Section 2.2.C.) 15A NCAC 2D .1111 

BART Related Documentation 

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Appendix L.10 - 394 

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Page 16 

Chlorine Dioxide Preparation (Area 06) 

F. Chlorine dioxide generation system (ID No. G06014) consisting of : 

one R-8 chlorine dioxide generator (ID No. 06-PU-002) and three chlorine dioxide 

solution storage tanks (125,000 gallons capacity, each, ID Nos. 06-TK-007, 06-TK-008, 

and 06-TK-009) controlled by a two section packed tower wet scrubber (70 to 80 gallons 

of chilled water per minute minimum flow rate, ID No. 06-CD-002-01) either normally in 

series with the No. 1 Hardwood Fiberline Bleaching System counter current type packed 

tower wet scrubber (ID No. 05-CD-002-01 (POS) or alone (AOS) if the No. 1 Hardwood 

Fiberline Bleaching System is not operating or for other reasons. 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulations

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

Hazardous Air Pollutants 112(r) - Prevention of accidental releases. 15A NCAC 2Q .0508(g) 

1. 15A NCAC 2Q .0508(g): PREVENTION OF ACCIDENTAL RELEASES - SECTION 112 (r) OF THE 

CLEAN AIR ACT 

a. The Permittee is subject to Section 112(r) of the Clean Air Act and shall comply with all applicable 

requirements in accordance with 40 CFR Part 68 [15A NCAC 2Q .0508(g)].

Monitoring [15A NCAC 2Q .0508(f)] 

b. Chlorine dioxide emissions from the Chlorine Dioxide System (ID No. G06014) shall be controlled by the 

wet scrubber (ID No. 06-CD-002-01) either in series with the No. 1 Hardwood Fiberline Bleaching System 

wet scrubber (ID No. 05-CD-002-01) or alone. To assure compliance, the Permittee shall perform 

inspections and maintenance. As a minimum, the inspection and maintenance requirement must include the 

following: 

 i. a monthly external visual inspection (for each calendar month, not to exceed 6 weeks from the previous 

inspection) of the system ductwork and material collection unit for leaks; and 

 ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous 

inspection) of the wet scrubber's structural integrity. 

 iii. inspection of the wet scrubber spray nozzles to detect clogging or corrosion damage of nozzles and 

perform maintenance and repair when necessary to assure proper operation of the scrubber; 

 iv. inspection of packing material to assure proper packing depth and to check for clogging; and 

 v. inspection, cleaning, and calibration of all instrumentation associated with the wet scrubber. 

c. The Permittee shall be deemed in noncompliance with 15A NCAC 2Q .0508 if the wet scrubber (ID No. 06-

CD-002-01) is not inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the following: 

 i. the date and time of each recorded action; 

 ii. the results of each inspection; 

 iii. the results of any maintenance performed on the wet scrubber; and 

 iv. any corrections made. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 395 

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EVAPORATORS (Area 07) 

G. Two (2) Black Liquor Evaporators (ID No. G07016) consisting of: 

the Swenson Evaporator (ID No. 07-PU-002) and associated Swenson Evaporator 

Hotwell (ID No. 07-TK-006) and; 

the West G.B. Evaporator (ID No. 07-PU-003) and associated West G.B. Evaporator 

Hotwell (ID No. 07-TK-007). 

Foul gases are collected by the LVHC Gas Collection System (ID No. G23078) for 

burning in Lime Kiln No. 5 (ID No. G09029) or Lime Kiln No. 4 (ID No. G09028). Foul 

condensates are controlled by the Condensate Stripper System (ID No. G07018). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

TRS 5 ppm by volume on a dry basis 15A NCAC 2D .0528

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart S (See Section 2.2.C.) 15A NCAC 2D .1111 

1. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS

a. The emissions of total reduced sulfur shall not exceed five parts per million from any multiple effect 

evaporator, measured as hydrogen sulfide on a dry gas basis and averaged per discrete contiguous 12-hour 

time period. [15A NCAC 2D .0528] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 G. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Evaporators Area emission sources, shall comply with the limitation above by ensuring the following: 

i. The gases are combusted in the No. 4 Lime Kiln (ID No. G09028) or; 

ii. The gases are combusted in the No. 5 Lime Kiln (ID No. G09029). 

d. The Permittee shall follow the closed vent inspection procedures per Specific Condition 2.2 .C. to insure that 

the emissions are routed to either the No. 4 Lime Kiln (ID No. G09028) or No. 5 Lime Kiln (ID No. G09029) 

as specified above. The Permittee shall be deemed in noncompliance with 2D .0528 if these procedures are 

not followed or if the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

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Appendix L.10 - 396 

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H. Eight (8) Weak Black Liquor Storage Tanks (ID No. G07086)

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulations

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

I. Condensate Stripper System (ID No. G07018) (40CFR60, Subpart BB) consisting of: 

the Condensate Stripper (ID No. 07-PU-015) and associated Stripper Feed Tank (ID No. 

07-TK-011) and Reflux Tank (ID No. 07-TK-014). 

Foul gases are collected by the LVHC Gas Collection System (ID No.G23078) for burning 

in Lime Kiln No. 5 (ID No. G09029) or Lime Kiln No. 4 (ID No. G09028). 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulations 

Total Reduced Sulfur (TRS) 5 ppm by volume on a dry basis, corrected to 10 

percent oxygen 

15A NCAC 2D .0524 

(40 CFR Part 60 Subpart BB) 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP Emissions See Permit Condition 2.2. C. 15A NCAC 2D .1111 

(40 CFR Part 63 Subpart S) 

1. 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS (40 CFR 60 SUBPART BB)

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 

15A NCAC 2D .0524 “New Source Performance Standards” (NSPS) as promulgated in 40 CFR Part 60 

Subpart BB, including Subpart A “General Provisions.”[15A NCAC 2D .0524] 

Emissions Limitations [15A NCAC 2D .0524] 

b. No owner or operator shall cause to be discharged into the atmosphere any gases which contain TRS in 

excess of 5 ppm by volume on a dry basis, corrected to 10 percent oxygen, unless the following conditions 

are met [40 CFR Part 60, Subpart 60.283(a)(1)]: 

i. The gases are burned with other waste gases in an incinerator or other device, and are subjected to a 

minimum temperature of 650 (C (1200 (F) for at least 0.5 second. 

Monitoring [15A NCAC 2Q .0508(f) and 2D .0524] 

c. The Permittee shall follow the closed vent inspection procedures per Specific Condition 2.2 .C. to insure that 

the emissions are routed to the No. 5 Lime Kiln (ID No. G09029) or the No. 4 Lime Kiln (ID No. G09028) as 

specified above. The Permittee shall be deemed in noncompliance with 2D .0524 if these procedures are not 

followed or if the records are not maintained. 

d. 40 CFR 60.284(b)(1) - The Permittee shall calibrate, maintain, and operate a monitoring device for 

measuring the combustion temperature at the point of incineration of effluent gases in the No. 5 Lime Kiln 

(ID No. G09029) and the No. 4 Lime Kiln (ID No. G09028) to assure the minimum temperature as specified 

above is maintained. 

Reporting/ Recordkeeping [15A NCAC 2Q .0508(f) and 2D .0524] 

e. The Permittee shall follow 40 CFR 60.284(d) for reporting of excess emissions. 

f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

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Appendix L.10 - 397 

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J. Four (4) Heavy Black Liquor Storage Tanks (ID No. G07019)

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulations

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

RECOVERY (AREA 08)

K. No. 10 new design recovery furnace (121,000 pounds per hour maximum black liquor 

solids firing rate and 382 million Btu per hour maximum heat input rate from No. 6 fuel 

oil; ID No. G08020) equipped with one 3-chamber, 6-field electrostatic precipitator 

(nominal 115,236 square feet of collection plate area; wet-bottom design; ID No. 08-CD001-01). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate 3.0 lbs. per ton of air dried pulp 15A NCAC 2D .0508

sulfur dioxide 2.3 lbs. per million Btu heat input 15A NCAC 2D .0516

visible emissions 40 percent opacity 15A NCAC 2D .0521 

total reduced sulfur 5 ppm by volume on a dry basis, corrected to 8 

percent oxygen 

15A NCAC 2D .0528 

sulfur dioxide Monitoring Requirements (See Condition 2.1 K. 2) 15A NCAC 2D .0608

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

HAP 40CFR63, Subpart MM (See Section 2.2.D.) 15A NCAC 2D .1111

sulfur dioxide, nitrogen 

oxides See Section 2.4 15A NCAC 2D .0543 BART 

1. 15A NCAC 2D .0508: PARTICULATES FROM PULP AND PAPER MILLS 

a. Emissions from the production of pulp and paper that are discharged from the No. 10 Recovery Furnace (ID 

No. G08020) into the atmosphere shall not exceed 3.0 pounds of particulate matter per equivalent tons of air 

dried pulp [15A NCAC 2D .0508.a.1.]

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.K. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0508. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by testing the No. 10 recovery furnace (ID No. G08020) for particulate matter in accordance 

with a testing protocol approved by the DAQ. Details of the emissions testing and reporting requirements 

can be found in Section 3 - General Condition JJ. Testing shall be completed and the results submitted within 

the calendar year of the effective date of Permit No. 08961T08 unless an alternate date is approved by the 

DAQ. The testing shall be performed annually thereafter. If the results of the testing demonstrate results at 

less than 80 percent of the limit above, the testing frequency may reduced to every two years. If the results of 

this or any test are above the limit given in Section 2.1 K. 1. a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0508.

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Appendix L.10 - 398 

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Monitoring/ Recordkeeping/ Reporting [15A NCAC 2Q .0508(f), 40 CFR 70.6(a)(3)(A)] 

d. Particulate matter emissions from the No. 10 recovery furnace (ID No. G08020) shall be controlled by an 

electrostatic precipitator (ESP) (ID No. 08-CD-001-01). To assure compliance with the emission limits in 

condition 2.1 K.1 a, the Permittee shall follow the 40 CFR 63, Subpart MM monitoring, recordkeeping, and 

reporting requirements as specified in Section 2.2 D. 

The Permittee shall determine compliance with the emission limit(s) in Section 2.1.K.1.a. above pursuant to 

the ongoing compliance determination provisions per 40 CFR 63.864(k)(2) and the applicable portions of 

MACT Subpart MM as specified in the monitoring, recordkeeping, and reporting requirements of Section 2.2 

D. However, excess emissions shall be in reported in accordance with 15A NCAC 2D .0535 as outlined in 

General Condition I. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if either 1) the applicable 

MACT Subpart MM requirements above are not monitored and recorded or 2) the MACT Subpart MM 

monitoring determines a violation of the applicable PM emission standard per 63.864(k)(2) as detailed above 

2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES 

a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur 

dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included 

when determining compliance with this standard. [15A NCAC 2D .0516] 

Testing [15A NCAC 2D .0501(c) and 2D .0608] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.K.2. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0516. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f), and 2D .0608] 

c. To assure compliance with 2.1.K.2.a, the Permittee shall monitor the sulfur content and heat content of the 

No. 6 fuel oil by using fuel oil supplier certification per month. The results of the fuel oil supplier 

certifications shall be recorded in a logbook (written or electronic format) and include the following 

information: 

i. the name of the fuel oil supplier; and 

ii. a statement verifying that the methods used to determine the maximum sulfur content of the fuel oil was 

in accordance with the following: 

(A) sample collection – ASTM D4177 or D4057; 

(B) heat of combustion (Btu) – ASTM D240 or D2015; and 

(C) sulfur content – ASTM D129, D-4294, or D1552; 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

iii. the maximum sulfur content of the fuel oil received during the month; 

iv. the average heat content of the fuel oil received during the month; and 

v. a certified statement signed by the responsible official that the records of fuel oil supplier certification 

submitted represent all of the fuel oil fired during the period. 

d. Additionally, the Permittee is required to calculate and record in a logbook (written or electronic format) the 

pounds of sulfur dioxide per million Btu heat content of the fuel oil per month using the above information. 

The Permittee shall be deemed in noncompliance if the results show an exceedance of the limit given in 

Section 2.1 K. 2. a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 and 2D .0608 if the 

requirements above are not monitored and recorded. 

Reporting [15A NCAC 2Q .0508(f) and 2D .0608] 

e. The Permittee shall submit a summary report of the fuel oil supplier certifications and calculated emission 

rates postmarked on or before January 30 of each calendar year for the preceding six-month period between 

July and December and July 30 of each calendar year for the preceding six-month period between January 

and June. All instances of deviations from the requirements of this permit must be clearly identified. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0608 if the reports are not submitted. 

3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

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Appendix L.10 - 399 

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a. Visible emissions from the No. 10 Recovery Furnace (ID No. G08020) shall not be more than 40 percent 

opacity (except during startups) when averaged over a six-minute period except that six-minute periods 

averaging not more than 90 percent opacity may occur not more than once in any hour nor more than four 

times in any 24-hour period. [15A NCAC 2D .0521(d)] 

b. For sources required to install, operate, and maintain continuous opacity monitoring systems (COMS), 

compliance with the 40 percent opacity limit shall be determined as follows:[15A NCAC 2D .0521(g)] 

i. No more than four six-minute periods shall exceed the opacity standard in any one day; and 

ii. The percent of excess emissions (defined as the percentage of monitored operating time in a calendar 

quarter above the opacity limit) shall not exceed 0.8 percent of the total operating hours. If a source 

operates less than 500 hours during a calendar quarter, the percent of excess emissions shall be 

calculated by including hours operated immediately previous to this quarter until 500 operational hours 

are obtained. 

Excess emissions during startup and shutdown shall be excluded from the determinations in paragraphs b.i. 

and b.ii. above, if the excess emissions are exempted according to the procedures set out in 2D .0535(g). 

Excess emissions during malfunctions shall be excluded from the determinations in paragraphs b.i. and b.ii. 

above, if the excess emissions are exempted according to the procedures set out in 2D .0535(c). 

All periods of excess emissions shall be included in the determinations in paragraphs b.i. and b.ii above until 

such time that the excess emissions are exempted according to the procedures in 2D .0535. 

Testing [15A NCAC 2D .0501(c)(8)] 

c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in Section 2.1 

K. 3.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The Permittee shall use a continuous opacity monitoring system (COMS) to monitor and record opacity. 

Continuous emissions monitoring and recordkeeping of opacity shall be performed as described in 

Paragraphs 2 and 3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet 

the minimum specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if the monitoring is not 

performed, if the monitored values exceed the limitations given above, or if the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring data postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified.

4. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS 

a. The emissions of total reduced sulfur from the No. 10 Recovery Furnace (ID No. G08020) shall not exceed 5 

parts per million corrected to 8 percent oxygen, measured as hydrogen sulfide on a dry gas basis and 

averaged per discrete contiguous 12-hour time period. [15A 2D .0528.c.1.] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.K. 4. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528.

Monitoring [15A NCAC 2Q .0508(f)] 

c. To ensure compliance, the Permittee shall calibrate, maintain, and operate a continuous monitoring system for 

determining the total reduced sulfur (as hydrogen sulfide, dry basis, corrected to 8 percent oxygen) emissions 

discharged to the atmosphere and record the output of the system. The continuous monitoring system shall be 

operated in accordance with the applicable performance specifications in 40 CFR 60 Appendix B and quality 

assurance procedures in Appendix F, Section 3, unless an alternative monitoring and quality assurance 

program is approved by the DAQ. The monitoring system downtime shall not exceed 5 percent. If any 

12-hour block average exceeds the limit above or the records are not maintained, the Permittee shall be 

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Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 400 

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Permit 08961T?? DRAFT

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deemed in noncompliance with 15A NCAC 2D .0528, except that one percent of all 12-hour total reduced 

sulfur averages per quarter year in excess of the limitation given above, in the absence of start-ups, 

shutdowns, and malfunctions, shall not be considered in violation. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

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Appendix L.10 - 401 

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L. No. 11 new design recovery furnace (121,000 pounds per hour maximum black liquor 

solids firing rate, 382 million Btu per hour maximum heat input rate from No. 6 fuel oil, 

and 0.25 million Btu per hour maximum heat input rate from propane igniters; ID No. 

G08021) equipped with one 3-chamber, 4-field electrostatic precipitator (nominal 

115,236 square feet of collection plate area; wet-bottom design; ID No. 08-CD-002-01) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate 3.0 lbs. per ton of air dried pulp 15A NCAC 2D .0508

visible emissions 35 percent opacity 15A NCAC 2D .0508 

sulfur dioxide 2.3 lbs. per million Btu heat input 15A NCAC 2D .0516

total reduced sulfur 5 ppm by volume on a dry basis, corrected to 8 

percent oxygen 

15A NCAC 2D .0528

sulfur dioxide Monitoring Requirements (See Condition 2.1 L. 2) 15A NCAC 2D .0608

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100

HAP 40CFR63, Subpart MM (See Section 2.2.D.) 15A NCAC 2D .1111

sulfur dioxide, nitrogen 

oxides See Section 2.4 15A NCAC 2D .0543 BART 

1. 15A NCAC 2D .0508: PARTICULATES FROM PULP AND PAPER MILLS 

a. Emissions from the production of pulp and paper that are discharged from the No. 11 recovery furnace (ID 

No. G08021) into the atmosphere shall not exceed: 

i. 3.0 pounds of particulate matter per equivalent tons of air dried pulp. [15A NCAC 2D .0508(a)], or 

ii. Visible emissions shall not be more than 35 percent opacity when averaged over a six-minute period. 

However, six-minute averaging periods may exceed 35 percent not more than once in any hour and not 

more than four times in any 24-hour period. In no event shall the six-minute average exceed 89 percent 

opacity. [15A NCAC 2D .0508 (b)] 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.L. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0508.

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by testing the No. 11 recovery furnace (ID No. G08021) for particulate matter in accordance 

with a testing protocol approved by the DAQ. Details of the emissions testing and reporting requirements 

can be found in Section 3 - General Condition JJ. Testing shall be completed and the results submitted within 

the calendar year of the effective date of Permit No. 08961T08 unless an alternate date is approved by the 

DAQ. The testing shall be performed annually thereafter. If the results of the testing demonstrate results at 

less than 80 percent of the limit above, the testing frequency may reduced to every two years. If the results of 

this or any test are above the limit given in Section 2.1 L. 1. a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0508.

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f) , 40 CFR 70.6(a)(3)(A)] 

d. Particulate matter emissions from the No. 11 recovery furnace (ID No. G08021) shall be controlled by an 

electrostatic precipitator (ESP) (ID No. 08-CD-001-01). 

The Permittee shall determine compliance with the particulate matter emission limit in Section 2.1.L.1.a. i. 

above pursuant to the ongoing compliance determination provisions per 40 CFR 63.864(k)(2) and the 

applicable portions of MACT Subpart MM as specified in the monitoring, recordkeeping, and reporting 

requirements of Section 2.2 D. However, excess emissions shall be in reported in accordance with 15A 

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Appendix L.10 - 402 

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NCAC 2D .0535 as outlined in General Condition I. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if either 1) the applicable 

MACT Subpart MM requirements above are not monitored and recorded or 2) the MACT Subpart MM 

monitoring determines a violation of the applicable PM emission standard per 63.864(k)(2) as detailed above. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f) , 40 CFR 70.6(a)(3)(A)] 

e. To determine compliance with the opacity limits in condition 2.1 L.1 a. ii., the Permittee shall follow the 40 

CFR 63, Subpart MM continuous opacity monitoring system (COMS) monitoring requirements as specified 

in Section 2.2 D. to monitor and record opacity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if the monitoring is not 

performed, if the monitored values exceed the limitations given above, or if the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

f. The Permittee shall submit a summary report of the monitoring data postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

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Appendix L.10 - 403 

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2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES 

a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur 

dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included 

when determining compliance with this standard. [15A NCAC 2D .0516] 

Testing [15A NCAC 2D .0501(c) and 2D .0608] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.L.2. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0516. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f), and 2D .0608] 

c. To assure compliance with 2.1.L.2.a, the Permittee shall monitor the sulfur content and heat content of the 

No. 6 fuel oil by using fuel oil supplier certification per month. The results of the fuel oil supplier 

certifications shall be recorded in a logbook (written or electronic format) and include the following 

information: 

i. the name of the fuel oil supplier; and 

ii. a statement verifying that the methods used to determine the maximum sulfur content of the fuel oil was 

in accordance with the following: 

(A) sample collection – ASTM D4177 or D4057; 

(B) heat of combustion (Btu) – ASTM D240 or D2015; and 

(C) sulfur content – ASTM D129, D-4294, or D1552; 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

iii. the maximum sulfur content of the fuel oil received during the month; 

iv. the average heat content of the fuel oil received during the month; and 

v. a certified statement signed by the responsible official that the records of fuel oil supplier certification 

submitted represent all of the fuel oil fired during the period. 

d. Additionally, the Permittee is required to calculate and record in a logbook (written or electronic format) the 

pounds of sulfur dioxide per million Btu heat content of the fuel oil per month using the above information. 

The Permittee shall be deemed in noncompliance if the results show an exceedance of the limit given in 

Section 2.1 K. 2. a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 and 2D .0608 if the 

requirements above are not monitored and recorded. 

Reporting [15A NCAC 2Q .0508(f) and 2D .0608] 

e. The Permittee shall submit a summary report of the fuel oil supplier certifications and calculated emission 

rates postmarked on or before January 30 of each calendar year for the preceding six-month period between 

July and December and July 30 of each calendar year for the preceding six-month period between January 

and June. All instances of deviations from the requirements of this permit must be clearly identified. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0608 if the reports are not submitted. 

3. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS 

a. The emissions of total reduced sulfur from the No. 11 Recovery Furnace (ID No. G08021) shall not exceed 5 

parts per million corrected to 8 percent oxygen, measured as hydrogen sulfide on a dry gas basis and 

averaged per discrete contiguous 12-hour time period. [15A 2D .0528(c)1] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.L. 3. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528.

Monitoring [15A NCAC 2Q .0508(f)] 

d. To ensure compliance, the Permittee shall calibrate, maintain, and operate a continuous monitoring system for 

determining the total reduced sulfur (as hydrogen sulfide, dry basis, corrected to 8 percent oxygen) emissions 

discharged to the atmosphere and record the output of the system. The continuous monitoring system shall be 

operated in accordance with the applicable performance specifications in 40 CFR 60 Appendix B and quality 

assurance procedures in Appendix F, Section 3, unless an alternative monitoring and quality assurance 

program is approved by the DAQ. The monitoring system downtime shall not exceed 5 percent. If any 

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Appendix L.10 - 404 

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12-hour block average exceeds the limit above or the records are not maintained, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0528, except that one percent of all 12-hour total reduced 

sulfur averages per quarter year in excess of the limitation given above, in the absence of start-ups, 

shutdowns, and malfunctions, shall not be considered in violation. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

M. Black liquor oxidation system (228,000 pounds per hour black liquor solids feed rate, ID 

No. G08022) equipped with three cyclones, one on each oxidizer tank (60 inches in 

diameter, ID No CD-BLOcylcone) followed by a natural gas-fired regenerative thermal 

oxidizer (ID No. CD-BLOXRTO) and a caustic scrubber (ID No. CD-RTOSCR) 

Only two of the three oxidizer tanks are required to operate if one of the recovery 

furnaces is down. 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100

Sulfur dioxide Less than 40 tons per consecutive twelve month 

period 

15A NCAC 2Q .0317 

(15A NCAC 2D .0530 Avoidance)

Sulfuric acid Less than 7 tons per consecutive twelve month 

period 

15A NCAC 2Q .0317 

(15A NCAC 2D .0530 Avoidance)

HAP 40CFR63, Subpart S via Equivalency by Permit 

(EBP) (See Section 2.2.C.)

15A NCAC 2D .1111 and 

40 CFR 63.94 

PM, sulfur dioxide, 

nitrogen oxides See Section 2.4 15A NCAC 2D .0543 BART 

1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS for 

 15A NCAC 2D. 0530: PREVENTION OF SIGNIFICANT DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530 (g) for major sources and major modifications, the 

BLOX System (G08022) shall discharge into the atmosphere: 

i. less than 40 tons per consecutive twelve month period of sulfur dioxide; and 

ii. less than 7 tons per consecutive twelve month period of sulfuric acid. 

b. To ensure that emissions are less than the above-specified limits, the Black Liquor Oxidation System thermal 

oxidizer (ID No. CD-BLOXRTO) is permitted to burn only BLOX gases and natural gas as an auxiliary fuel. 

Testing [15A NCAC 2D .0501(c)(8)] 

c. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ. If 

the results of this test are above the limits given in Section 2.1 M. 1. a. (G08022) above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0530. 

Monitoring/ Recordkeeping [15A NCAC 2Q .0508(f)] 

d. Sulfur dioxide and sulfuric acid emissions from the BLOX system shall be controlled by the RTO scrubber 

(ID Nos. CD-RTOSCR). To ensure compliance, the Permittee shall install, calibrate, operate, and maintain a 

pH indicator and a scrubbing liquid flow meter on the RTO scrubber. These parameters shall be recorded 

once per day. The Permittee shall be allowed three (3) days of absent observations per semi-annual period. If 

the emission source(s) is not operating, a record of this fact along with the corresponding date and time shall 

substitute for the daily observation. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if these records are not 

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maintained. 

e. The Permittee shall establish a “normal range” for flow meter and pH readings in the first 30 days following 

the commencement of operation of the scrubber and submit the proposed ranges to the DAQ for incorporation 

into this permit within 60 days of establishing these values.

f. The Permittee shall calculate the sulfur dioxide emissions from the BLOX System (G08022) on a monthly 

basis to ensure compliance with the limits given in Section 2.1 M. 1. a. above. The RTO scrubber is required 

to be operated only as necessary to achieve compliance with the limitations above. Sulfur dioxide emissions 

shall be determined by the following: 

i. When the RTO Scrubber is operating within the monitoring parameter values established above, the 

sulfur dioxide emissions shall be calculated by multiplying the total amount of operating time by the 

maximum controlled emission factor of 5 pounds per hour; 

ii. When the RTO Scrubber is not in operation or is not operating within the monitoring parameter values 

established above, the sulfur dioxide emissions shall be calculated by multiplying the total amount of 

operating time by the maximum uncontrolled emission factor of 50 pounds per hour; and 

iii. When the thermal oxidizer (ID No. CD-BLOXRTO) is not in operation, the RTO scrubber is not 

required and the sulfur dioxide emissions are zero. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530 if the amounts of sulfur dioxide 

emissions are not calculated and recorded. 

g. Calculations and the total amount of sulfur dioxide emissions from the BLOX System (G08022) shall be 

recorded monthly in a logbook (written or electronic format), maintained on-site and made available to 

officials of the Division of Air Quality, upon request. The Permittee must keep each entry in the log and all 

required records on file for a minimum of five years. The Permittee shall be deemed in noncompliance with 

15A NCAC 2D .0530 if the sulfur dioxide emissions exceed the limit in Section 2.1 M. 1. a. above or if the 

records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

h. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. The report shall contain the 

following: 

i. The monthly sulfur dioxide emissions shall be totaled for the previous seventeen months. The emissions 

shall be calculated for each of the twelve month periods over the previous seventeen months.

N. No. 10 recovery furnace smelt dissolving tank (121,000 lbs. per hour black liquor solids 

feed rate, ID No. G08023) equipped with a chevron mist eliminator (33.5 square feet of 

collection surface area, ID No. 08-CD-011-01) and 

No. 11 recovery furnace smelt dissolving tank (121,000 lbs. per hour black liquor solids 

feed rate, ID No. G08024) equipped with a chevron mist eliminator (33.2 square feet of 

collection surface area, ID No. 08-CD-012-01) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate 0.6 lbs. per ton of air dried pulp 15A NCAC 2D .0508

visible emissions 40 percent opacity (ID No. G08023) 

20 percent opacity (ID No. G08024) 

15A NCAC 2D .0521

total reduced sulfur 0.032 lbs. per ton black liquor solids (dry weight) 15A NCAC 2D .0528

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100

HAP 40CFR63, Subpart MM (See Section 2.2.D.) 15A NCAC 2D .1111

PM, sulfur dioxide See Section 2.4 15A NCAC 2D .0543 BART 

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1. 15A NCAC 2D .0508: PARTICULATES FROM PULP AND PAPER MILLS 

a. Emissions from the production of pulp and paper that are discharged from these sources into the atmosphere 

shall not exceed 0.6 pounds of particulate matter per equivalent tons of air dried pulp. [15A NCAC 2D 

.0508(a)] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 N. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0508. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f) , 40 CFR 70.6(a)(3)(A)] 

c. Particulate matter emissions from the No. 10 recovery furnace smelt dissolving tank (ID No. G08023) shall 

be controlled by a chevron mist eliminator (ID No. 08-CD-011-01). Particulate matter emissions from the 

No. 11 recovery furnace smelt dissolving tank (ID No. G08023) shall be controlled by a chevron mist 

eliminator (ID No. 08-CD-012-01). The Permittee shall determine compliance with the emission limit(s) in 

Section 2.1.N.1.a above pursuant to the ongoing compliance determination provisions per 40 CFR 

63.864(k)(2) and the applicable portions of MACT Subpart MM as specified in the monitoring, 

recordkeeping, and reporting requirements of Section 2.2 D. However, excess emissions shall be in reported 

in accordance with 15A NCAC 2D .0535 as outlined in General Condition I. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if either 1) the applicable 

MACT Subpart MM requirements above are not monitored and recorded or 2) the MACT Subpart MM 

monitoring determines a violation of the applicable PM emission standard per 63.864(k)(2) as detailed above.

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

a. Visible emissions from the No. 10 smelt dissolving tank (ID No. G08023) shall not be more than 40 percent 

opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 40 

percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 90 percent opacity. [15A NCAC 2D .0521 (c)] 

Visible emissions from the No. 11 smelt dissolving tank (ID No. G08024) shall not be more than 20 percent 

opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 

percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall 

the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) and 

General Condition JJ found in Section 3. If the results of this test are above the limits given in 2.1 N.2.a. above, 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a week the Permittee shall observe the emission points of these sources for any 

visible emissions above normal. If the emission source(s) are not operating, a record of this fact along with 

the corresponding date and time shall substitute for the monthly observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 N. 2.a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

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available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

3. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS 

a. The emissions of total reduced sulfur shall not exceed 0.032 pounds per ton of black liquor solids (dry 

weight) from No. 10 smelt dissolving tank (ID No. G08023) or the No. 11 smelt dissolving tank (ID No. 

G08024). [15A NCAC 2D .0528] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limits given in Section 2.1 N. 3. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528 

Monitoring/Recordkeeping [15A NCAC 2D .0501(c)] 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by testing the No. 10 smelt dissolving tank (ID No. G08023) and the No. 11 smelt dissolving 

tank (ID No. G08024) for TRS in accordance with a testing protocol approved by the DAQ. Details of the 

emissions testing and reporting requirements can be found in Section 3 - General Condition JJ. Testing shall 

be completed and the results submitted within the calendar year of the effective date of Permit No. 08961T08 

unless an alternate date is approved by the DAQ. The testing shall be performed annually thereafter. If the 

results of the testing demonstrate results at less than 80 percent of the limit above, the testing frequency may 

be reduced to once per five years. If the results of this or any test are above the limit given in Section 2.1 N. 

3. a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0528. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

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LIME PRODUCTION (Area 09)

O. No. 6 fuel oil-fired No. 4 Lime Kiln (60.0 million Btu per hour maximum permitted heat 

input rate , with gas igniters; ID No. G09028) equipped with a flooded-disc type wet 

scrubber (ID No. 09-CD-009-01); and 

No. 6 fuel oil-fired No. 5 Lime Kiln (100.0 million Btu per hour maximum permitted heat 

input rate, with gas igniters; ID No. G09029) equipped with a 4-stage MicroMistTM

venturi scrubber (ID No. 09-CD-010-01). 

No. 4 Lime Kiln is the primary burner and No. 5 Lime Kiln is backup burner for 

collected NCG foul gases; No. 5 Lime Kiln is the primary burner and No. 4 Lime Kiln is 

backup burner for Stripper Off Gases (SOG) from the Condensate Stripper System (ID 

No. G07018).

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutants Limits / Standards Applicable Regulation 

particulate 0.5 lbs. per ton of air dried pulp 15A NCAC 2D .0508 

sulfur dioxide 2.3 lbs. per million Btu heat input 15A NCAC 2D .0516 

visible emissions 40 percent opacity 15A NCAC 2D .0521 

total reduced sulfur 20 ppm by volume on a dry basis, corrected to 10 

percent oxygen 

15A NCAC 2D .0528 

HAP 40CFR63, Subpart MM (See Section 2.2.D.) 15A NCAC 2D .1111 

1. 15A NCAC 2D .0508: PARTICULATES FROM PULP AND PAPER MILLS 

a. Emissions from the production of pulp and paper that are discharged from these sources into the atmosphere 

shall not exceed 0.5 pounds of particulate matter per equivalent tons of air dried pulp. [15A NCAC 2D 

.0508(a)1]. 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section. If the results of this test are above the limit given in Section 2.1 O. 1. a. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0508. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by testing the No. 4 and No. 5 Lime Kilns (ID Nos. G09028 and G09029) for particulate 

matter in accordance with a testing protocol approved by the DAQ. Details of the emissions testing and 

reporting requirements can be found in Section 3 - General Condition JJ. Testing shall be completed and the 

results submitted within the calendar year of the effective date of Permit No. 08961T08 unless an alternate 

date is approved by the DAQ. The testing shall be performed annually thereafter. If the results of the testing 

demonstrate results at less than 80 percent of the limit above, the testing frequency may reduced to every two 

years. If the results of this or any test are above the limit given in Section 2.1 O. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0508. 

Monitoring/Recordkeeping/Reporting[15A NCAC 2Q .0508(f), 40 CFR 70.6(a)(3)(A)]] 

d. Particulate matter emissions from the No. 4 Lime Kiln (ID No. G09028) shall be controlled by the flooded 

disc-type wet scrubber (ID No.09-CD-009-01). Particulate matter emissions from the No. 5 Lime Kiln (ID 

No. G09029) shall be controlled by the 4-stage MicroMistTM venturi scrubber (ID No.09-CD-010-01). The 

Permittee shall determine compliance with the emission limit(s) in Section 2.1.O.1.a above pursuant to the 

ongoing compliance determination provisions per 40 CFR 63.864(k)(2) and the applicable portions of MACT 

Subpart MM as specified in the monitoring, recordkeeping, and reporting requirements of Section 2.2 D. 

However, excess emissions shall be in reported in accordance with 15A NCAC 2D .0535 as outlined in 

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General Condition I. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if either 1) the applicable 

MACT Subpart MM requirements above are not monitored and recorded or 2) the MACT Subpart MM 

monitoring determines a violation of the applicable PM emission standard per 63.864(k)(2) as detailed above. 

2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES 

a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur 

dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included 

when determining compliance with this standard. [15A NCAC 2D .0516] 

Testing [15A NCAC 2D .0501 (c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 O. 2. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0508. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. To assure compliance with 2.1.O.2.a , the Permittee shall monitor the sulfur content and heat content of the 

No. 6 fuel oil by using fuel oil supplier certification per month. The results of the fuel oil supplier 

certifications shall be recorded in a logbook (written or electronic format) on a quarterly basis and include the 

following information: 

i. the name of the fuel oil supplier; 

ii. the maximum sulfur content of the fuel oil received during the month; 

iii. the average heat content of the fuel received during the month; 

iv. the method used to determine the maximum sulfur and heat content of the fuel oil; 

v. the calculation of lb SO2 per million Btu; and 

vi a certified statement signed by the responsible official that the records of fuel oil supplier certification 

submitted represent all of the fuel oil fired during the period. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 if the sulfur and heat content of 

the oil are not monitored and recorded. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of the fuel oil supplier certifications postmarked on or before 

January 30 of each calendar year for the preceding six-month period between July and December and July 30 

of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

a. Visible emissions from the No. 4 Lime Kiln (ID No. G09028) and the No. 5 Lime Kiln (ID No. G09029) shall 

not be more than 40 percent opacity when averaged over a six-minute period. However, six-minute averaging 

periods may exceed 40 percent of more than once in any hour and not more than four times in any 24-hour period. 

 In no event shall the six- minute average exceed 90 percent opacity. [15A NCAC 2D .0521(c)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ. If the results of this test are above the limits given in Section 2.1 O. 3. a. above, 

the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a day the Permittee shall observe the emission points of this source for any 

visible emissions above normal. The daily observation must be made for each day of the calendar year period 

to ensure compliance with this requirement. The Permittee shall be allowed three (3) days of absent 

observations per semi-annual period. If the emission source(s) is not operating, a record of this fact along 

with the corresponding date and time shall substitute for the daily observation. If the weather conditions (i.e. 

fog) are such that the source emission points of this source cannot be observed, the Permittee shall make a 

minimum of two (2) attempts to make the required observation, a record of this fact along with the 

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corresponding date and time(s) shall substitute for the daily observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

 i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

 ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 O. 3. a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

4. 15A NCAC 2D .0528: TOTAL REDUCED SULFUR FROM KRAFT PULP MILLS 

a. The emissions of total reduced sulfur shall not exceed 20 ppm by volume on a dry basis, corrected to 10 

percent oxygen, measured as hydrogen sulfide and averaged per discrete contiguous 12-hour time period, 

from the No. 4 Lime Kiln (ID No. G09028) or the No. 5 Lime Kiln (ID No. G09029). [15A NCAC 2D 

.0528] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 O 4. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0528 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. To ensure compliance, the Permittee shall calibrate, maintain, and operate a continuous monitoring system for 

determining the total reduced sulfur (as hydrogen sulfide, dry basis, corrected to 10 percent oxygen) 

emissions discharged to the atmosphere and record the output of the system. The continuous monitoring 

system shall be operated in accordance with the applicable performance specifications in 40 CFR 60 

Appendix B and quality assurance procedures in Appendix F, Section 3, unless an alternative monitoring and 

quality assurance program is approved by the DAQ. The monitoring system downtime shall not exceed 5 

percent. If any 12-hour block average exceeds the limit above or the records are not maintained, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0528, except that two percent of all 12-

hour total reduced sulfur averages per quarter year in excess of the limitation given above, in the absence of 

start-ups, shutdowns, and malfunctions, shall not be considered in violation. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

P. No. 5 lime silo system (ID No. G09032), including: 

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the hot lime conveyor, lime crusher, bucket elevator, and 

No. 5 lime storage silo (400 tons maximum capacity), 

equipped with a cartridge-type bagfilter (1,728 square feet of filter area, 

ID No. 09-CD-013-01). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 P 0.67 15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated 

by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 P. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the No. 5 lime silo system (ID No. G09032) shall be controlled by the 

cartridge filter. To assure compliance, the Permittee shall perform inspections and maintenance. As a 

minimum, the inspection and maintenance requirement shall include the following: 

i. a monthly visual inspection (for each calendar month, not to exceed 6 weeks from the previous 

inspection) of the system ductwork and material collection unit for leaks; and 

ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous 

inspection) of the cartridge filter structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and cartridge 

filter are not inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action;

ii. the results of each inspection; 

iii. the results of any maintenance performed on the cartridge filter; and 

iv. any corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 

of each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the No. 5 lime silo system (ID No. G09032) shall not be more than 20 percent opacity 

when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not 

more than once in any hour and not more than four times in any 24-hour period. In no event shall the sixBART Related Documentation 

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minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 P.2.a. 

above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

visible emissions above normal. If the emission source(s) are not operating, a record of this fact along with 

the corresponding date and time shall substitute for the monthly observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 P. 2.a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 

of each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

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Q. No. 6 Lime Silos (ID No. G09031) including: 

No. 6 lime storage silo (150 tons maximum capacity, ID 09-TK-018), 

No. 6 fresh lime storage silo (150 tons maximum capacity, ID No. 09-TK-019), 

the hot lime conveyor, lime crusher, and bucket elevator, 

equipped with a cartridge-type bagfilter (1,728 square feet of filter area, 

ID No. 09-CD-018-01). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 x P0.67 15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from these sources shall not exceed an allowable emission rate as calculated 

by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 Q. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the No. 6 lime dust collection system (ID No. G09031) shall be controlled 

by the cartridge filter. To assure compliance, the Permittee shall perform inspections and maintenance. As a 

minimum, the inspection and maintenance requirement shall include the following: 

i. a monthly visual inspection (for each calendar month, not to exceed 6 weeks from the previous 

inspection) of the system ductwork and material collection unit for leaks; and 

ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous 

inspection) of the cartridge filter structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork and cartridge 

filter are not inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action;

ii. the results of each inspection; 

iii. the results of any maintenance performed on the cartridge filter; and 

iv. any corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 

of each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

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2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the No. 6 lime dust collection system (ID No. G09031) shall not be more than 20 

percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 

20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event 

shall the six-minute average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 Q.2.a. 

above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

visible emissions above normal. If the emission source(s) are not operating, a record of this fact along with 

the corresponding date and time shall substitute for the monthly observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 Q. 2.a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 

of each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

R. Lime Production - Other Units (ID No. G09027) consisting of: 

Lime Pre-Coat Filter Nos. 4, 5, and 6 (ID Nos. 09-PU-001, 09-PU-002, 

and 09-PU-003, respectively)

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100

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CAUSTICIZING (Area 10) 

S. No. 5 Lime Slaker (ID No. G10035) controlled by a natural draft wet scrubber (ID No. 10-

CD-027-01) and 

No. 6 Lime Slaker (ID No. G10034) controlled by a natural draft wet scrubber (ID No. 10-

CD-036-01), and 

Green Liquor Clarification (ID No. G10036) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 x P0.67 15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from each of these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 S. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the No. 5 Lime Slaker (ID No. G10035) shall be controlled by the natural 

draft scrubber (ID No.10-CD-027-01). Particulate matter emissions from the No. 6 Lime Slaker (ID No. 

G10036) shall be controlled by the natural draft wet scrubber (ID No.10-CD-036-01). The Permittee shall 

install, operate, and maintain a wet scrubbing liquid flowmeter on each scrubber. To ensure compliance and 

the effective operation of the scrubbers, the Permittee shall monitor and record, once per day, scrubbing 

liquid flow rate. The Permittee shall be allowed three (3) days of absent observations per semi-annual period. 

If the emission source(s) is not operating, a record of this fact along with the corresponding date and time 

shall substitute for the daily observation. The readings shall be recorded in a logbook (written or electronic 

format) on-site and made available to an authorized representative of DAQ upon request. To ensure quality, 

the flow rate gauges and pressure devices shall be calibrated annually. 

The scrubber shall be operated to ensure the following operational parameters are maintained: 

i. The scrubbing liquid flow rate shall be greater than 30 gallons per minute. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the scrubber liquid flow rate 

is not maintained above the above prescribed limit or if these records are not maintained. 

d. If the scrubber liquid flow rate readings recorded as required in 2.1.S.1.c. above are observed to be outside 

the prescribed range, the Permittee shall inspect the scrubber(s) for malfunctions and clean or repair, as 

necessary. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the inspections, 

cleaning, and repairs are not performed.

e. The results of inspection and maintenance activities, discussed above for the scrubbers, shall be maintained in 

a logbook (written or electronic format) on-site and made available to an authorized representative of DAQ 

upon request. The logbook shall record the following: 

i. the date and time of each recorded action 

ii. the results of each inspection; 

iii. the causes for any variance from the prescribed operating range for the scrubber(s); and 

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iv. corrective actions taken. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

f. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from these sources shall not be more than 20 percent opacity when averaged over a sixminute period. However, six-minute averaging periods may exceed 20 percent not more than once in any 

hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 

percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 S.2.a. 

above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

visible emissions above normal. If the emission source(s) are not operating, a record of this fact along with 

the corresponding date and time shall substitute for the monthly observation. The Permittee shall establish 

“normal” for the source in the first 30 days following the effective date of permit 08961T08. If visible 

emissions from this source are observed to be above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given in Section 2.1 S. 2.a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring activities postmarked on or before January 30 

of each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

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POWER (Area 11) 

T. Power Boilers: 

Coal -fired Big Bill utility boiler (364 million Btu per hour maximum heat input rate, ID 

No. G11037) equipped with low NOx burners, and a 2 chamber, 3 field electrostatic 

precipitator (51,840 square feet of plate area, ID No. 11-CD-003-01); 

Coal -fired Peter G. utility boiler (364 million Btu per hour maximum heat input rate, ID 

No. G11038) equipped with low NOx burners, and a 2 chamber, 3 field electrostatic 

precipitator (51,840 square feet of plate area, ID No. 11-CD-004-01); and 

Coal -fired Riley Coal utility boiler (399 million Btu per hour maximum heat input rate, 

ID No. G11039) equipped with low NOx burners, and a 2 chamber, 3 field electrostatic 

precipitator (67,392 square feet of plate area, ID No. 11-CD-005-01);

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate matter 0.16 lb/million Btu heat input 15A NCAC 2D .0503 

particulate matter 0.15 lb/million Btu heat input 

(See Section 2.2.A.) 

15A NCAC 2D .0530 

sulfur dioxide 2.3 lb/million Btu heat input 15A NCAC 2D .0516 

sulfur dioxide sulfur dioxide emissions from the Big Bill, Peter 

G., Riley Coal and No. 4 Power Boilers shall be 

limited to 8,277 tons per rolling consecutive 12 

months 

(See Section 2.2.A.) 

15A NCAC 2Q .0317 

Avoidance of 

15A NCAC 2D .0530 

nitrogen oxides 1.8 lb/million Btu heat input 15A NCAC 2D .0519 

nitrogen oxides nitrogen oxides emissions from the Big Bill, Peter 

G., Riley Coal and No. 4 Power Boilers shall be 

limited to 4,368 tons per rolling consecutive 12 

months 

(See Section 2.2.A.) 

15A NCAC 2D .0530 

nitrogen oxides NC SIP nitrogen oxides emissions allocations 

during ozone season (See Section 2.2.B.) 

15A NCAC 2D .1417 

visible emissions 40 percent opacity 15A NCAC 2D .0521 

carbon monoxide carbon monoxide emissions from the Big Bill, 

Peter G., Riley Coal and No. 4 Power Boilers shall 

be limited to 898.2 tons per consecutive 12 months 

(See Section 2.2.A.) 

15A 2D NCAC .0530 

visible emissions Excess Emissions Monitoring Requirements 

(40 CFR 51, Appendix P)

15A NCAC 2D .0606

sulfur dioxide Monitoring Requirements (See Condition 2.1 T. 2) 15A NCAC 2D .0608

 

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1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS

a. Emissions of particulate matter from the combustion of coal that are discharged from each of these sources 

(ID No(s) G11037, G11038, and G11039) into the atmosphere shall not exceed 0.16 pounds per million Btu 

heat input. [15A NCAC 2D .0503(a)]

Testing [15A NCAC 2D .0501(c)] 

b. If emission testing is required, the testing shall be performed in accordance General Condition JJ found in 

Section 3. If the results of the test are above the limit given in Section 2.1 T. 1. a. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0503. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. The Permittee shall demonstrate compliance with the emission limit(s) above by testing each of these sources 

(ID No(s) G11037, G11038, and G11039) for particulate matter in accordance with a testing protocol 

approved by the DAQ. Details of the emissions testing and reporting requirements can be found in Section 3 

- General Condition JJ. Testing shall be completed and the results submitted within the 180 days of the 

effective date of Permit No. 08961T08 unless an alternate date is approved by the DAQ. The testing shall be 

performed annually thereafter. If the results of the testing demonstrate results at less than 80 percent of the 

limit above, the testing frequency may reduced to every permit cycle. If the results of this or any test are 

above the limit given in Section 2.1 T. 1. a. above, the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0503. 

Monitoring [15A NCAC 2Q .0508(f)] 

d. Particulate matter emissions from these boilers (ID Nos. G11037, G11038, and G11039) shall be controlled 

by their respective electrostatic precipitators (ESP) (ID Nos. 11-CD-003-01, 11-CD-004-001, and 11-CD005-001). The Permittee shall monitor the following parameters daily for values outside the normal operating 

range in each field or section: 

i. primary voltage, 

ii. primary current, and 

iii. secondary current. 

The Permittee shall establish “normal” for these parameters within the first 30 days following the effective 

date of permit 08961T08 and submit the proposed ranges to the DAQ for incorporation into this permit within 

60 days of the effective date of said permit. The permit shall be administratively amended to incorporate the 

approved values.

The Permittee shall be allowed three (3) days of absent observations per semi-annual period. If the emission 

source(s) is not operating, a record of this fact along with the corresponding date and time shall substitute for 

the daily observation. 

e. If the ESP parameters above are observed to be outside the prescribed range, the Permittee shall inspect the 

ESP for malfunctions, take the necessary measures to correct any problems, and return the parameter to the 

proper range within the monitoring period. 

Notwithstanding any prior reduced testing frequency allowed per 2.1.T.1.c above, if the ESP parameter 

readings recorded as required above are observed to be outside the allowable range, in order to ensure that the 

abnormal value(s) is indicative of compliance, the Permittee shall be required to perform annual testing as 

outlined in 2.1.T.1.c above. If the ESP parameter is observed to be outside the allowable range within 60 

days prior to the end of the calendar year, the testing may be conducted the following calendar year. 

However, testing in this case shall be performed within the first quarter of the following year. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

f. The results of the electrostatic precipitator monitoring shall be maintained in a logbook (written or electronic 

form) on site and made available to an authorized representative upon request. The logbook shall record the 

following: 

i. the date and time of actions recorded, 

ii. the normal range of values for each parameter, 

iii. the values of each parameter, 

iv. the causes for any variance from the prescribed operating range(s); and 

v. corrective actions taken. 

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The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0508 if these parameters are not 

monitored or these records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

g. The Permittee shall submit a summary report of the monitoring and recordkeeping postmarked on or before 

January 30 of each calendar year for the preceding six-month period between July and December and July 30 

of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

2. 15A NCAC .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

a. Emissions of sulfur dioxide from these sources (ID No(s). G11037, G11038, and G11039) shall not exceed 

2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, 

ores, and other substances shall be included when determining compliance with this standard. [15A NCAC 

2D .0516] 

Testing [15A NCAC 2D .0501(c) and 2D .0608] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.T.2. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0516. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f), 2D .0608, and 2D .0613] 

c. To assure compliance with 2.1.T.2.a, the Permittee shall monitor the sulfur content and heat content of the 

coal by using coal supplier certification per total shipment received. The results of the coal supplier 

certifications shall be recorded in a logbook (written or electronic format) and include the following 

information: 

i. the name of the coal supplier; 

ii. a statement verifying that the methods used to determine the maximum sulfur content and heat content of 

the coal were in accordance with the following: 

(A) sampling - ASTM Method D 2234; 

(B) preparation - ASTM Method D 2013; 

(C) gross calorific value (Btu) - ASTM Method D-2015, D-3286, D-1989, or D-5865; 

(D) moisture content - ASTM Method D 3173 or D-3302; and 

(E) sulfur content - ASTM Method D 3177 or ASTM Method D 4239. 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

d. Additionally, the Permittee is required to calculate and record in a logbook (written or electronic format) the 

equivalent emission rate in pounds of sulfur dioxide per million Btu heat content of the coal per total 

shipment. The equivalent sulfur dioxide emission rate (pounds per million Btu heat input) shall be calculated 

in accordance with Method 19 of 40 CFR 60, Appendix A, Section 12.6 – Sulfur Retention Credit for 

Compliance Fuel. The Permittee shall be deemed in noncompliance if the results show an exceedance of the 

limit given in Section 2.1 T. 2. a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 and 2D .0608 if the 

requirements above are not monitored and recorded. 

Reporting [15A NCAC 2Q .0508(f) and 2D .0608] 

e The Permittee shall submit a summary report of the coal supplier certifications and calculated emission rates 

postmarked on or before January 30 of each calendar year for the preceding six-month period between July 

and December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0608 if the reports are not submitted. 

3. 15A NCAC 2D .0519: CONTROL OF NITROGEN DIOXIDE AND NITROGEN OXIDES 

a. Emissions of nitrogen oxides shall not exceed 1.8 pounds per million Btu of heat input from any coal-fired 

boiler with a capacity of 250 million Btu per hour or more. [15A NCAC 2D .0519(b)] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1 T. 3. a. above, the Permittee 

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shall be deemed in noncompliance with 15A NCAC 2D .0519. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. No monitoring/recordkeeping/reporting is required from the firing of coal in these sources for this regulation. 

4. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

a. Visible emissions from these sources (ID No(s). G11037, G11038, and G11039) shall not be more than 40 

percent opacity (except during startups) when averaged over a six-minute period except that six-minute 

periods averaging not more than 90 percent opacity may occur not more than once in any hour nor more than 

four times in any 24-hour period. [15A NCAC 2D .0521(c)] 

b. For sources required to install, operate, and maintain continuous opacity monitoring systems (COMS), 

compliance with the 40 percent opacity limit shall be determined as follows:[15A NCAC 2D .0521(g)] 

i. No more than four six-minute periods shall exceed the opacity standard in any one day; and 

ii. The percent of excess emissions (defined as the percentage of monitored operating time in a calendar 

quarter above the opacity limit) shall not exceed 0.8 percent of the total operating hours. If a source 

operates less than 500 hours during a calendar quarter, the percent of excess emissions shall be 

calculated by including hours operated immediately previous to this quarter until 500 operational hours 

are obtained. 

Excess emissions during startup and shutdown shall be excluded from the determinations in paragraphs b.i. 

and b.ii. above, if the excess emissions are exempted according to the procedures set out in 2D .0535(g). 

Excess emissions during malfunctions shall be excluded from the determinations in paragraphs b.i. and b.ii. 

above, if the excess emissions are exempted according to the procedures set out in 2D .0535(c). 

All periods of excess emissions shall be included in the determinations in paragraphs b.i. and b.ii above until 

such time that the excess emissions are exempted according to the procedures in 2D .0535. 

Testing [15A NCAC 2D .0501(c)(8)] 

c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ. If the results of this test are above the limit given in Section 2.1 T.4.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The Permittee shall use a continuous opacity monitoring system (COMS) to monitor and record opacity. 

Continuous emissions monitoring and recordkeeping of opacity shall be performed as described in 

Paragraphs 2 and 3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet 

the minimum specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if the monitoring is not 

performed, if the monitored values exceed the limitations given above, or if the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring data postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

5. 15A NCAC 2D .0606: SOURCES COVERED BY APPENDIX P OF 40 CFR PART 51 (CONTINUOUS 

OPACITY MONITORING AND EXCESS EMISSIONS)

For the “Big Bill” , “Peter G.” , and Riley Coal Boilers (ID Nos. G11037, G11038, and G11039, respectively) 

the provisions of 15A NCAC 2D .0606 apply as follows: 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f) and 2D .0606] 

a. The Permittee shall use a continuous opacity monitoring system (COMS) to monitor and record opacity. 

Continuous emissions monitoring and recordkeeping of opacity shall be performed as described in Paragraphs 2 

and 3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet the minimum 

specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51. 

b. The quarterly excess emissions (EE) reports required under Appendix P of 40 CFR Part 51 shall be used as an 

indication of good operation and maintenance of the electrostatic precipitators. These sources shall be deemed to 

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be properly operated and maintained if the percentage of time the opacity emissions, calculated on a 6-minute 

average, in excess of 40 percent (including startups, shutdowns, and malfunctions) does not exceed 3.0 percent of 

the total operating time for any given calendar quarter, adjusted for monitor downtime (MD) as calculated below. 

 In addition, these sources shall be deemed to be properly operated and maintained if the %MD does not exceed 

2.0 percent. 

Calculations for %EE and %MD

Percent Excess Opacity Emission (%EE) Calculation: 

%EE = Total Excess Emission Time* x 100 

 (Total Source Operating Time***) - (Monitor Downtime) 

Percent Monitor Downtime (%MD) Calculation for COMS: 

%MD = Total Monitor Downtime** x 100 

(Total Source Operating Time***) 

* Total Excess Emission Time contains any 6-minute period greater than 40% opacity including 

startup, shutdown, and malfunction. 

** Total Monitor Downtime includes Quality Assurance (QA) activities unless exempted by 

regulation or defined in an agency approved QA Manual. The amount of exempt QA Time will be 

reported in the quarterly report as such. 

*** If a source operates less than 2200 hours during any quarter, the source may calculate the %EE 

and/or %MD using all operating data for the current quarter and the preceding quarters until 2200 

hours of data are obtained. [N.C.G.S. 143-215.110] 

Reporting [15A NCAC 2Q .0508(f) and 2D .0606] 

c. The Permittee shall submit the excess emissions and monitor downtime reports as required under Appendix P of 

40 CFR Part 51 no later than January 30 of each calendar year for the preceding three-month period between 

October and December, April 30 of each calendar year for the preceding three-month period between January and 

March, July 30 of each calendar year for the preceding three-month period between April and June, and October 

30 of each calendar year for the preceding three-month period between July and September. For periods of 

excess emissions, defined as each six-minute period average greater than 40 percent opacity, the opacity 

measurements recorded by the COMS shall be reported as described in Paragraphs 4 and 5.1 of Appendix P of 40 

CFR Part 51 except that a six-minute time period shall be deemed as an appropriate alternative opacity averaging 

period as described in Paragraph 4.2 of Appendix P of 40 CFR Part 51. A minimum of 36 data points, equally 

spaced, is required to determine a valid six-minute value. All instances of deviations from the requirements of 

this permit must be clearly identified. 

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U. Coal/No. 6 fuel oil-fired No. 4 Power Boiler (535 million Btu per hour maximum heat 

input; pulverized dry bottom type design; ID No. G11040; NSPS Subpart D; PSD) 

equipped with low NOX burner components, a Separated Over Fire Air (SOFA) 

system, a urea-based Selective Non-Catalytic Reduction (SNCR) NOX emission 

reduction system (ID No. 11-CD-006-02), and an electrostatic precipitator (115,236 

square feet of plate area, ID No. 11-CD-006-01); 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

nitrogen oxides 0.8 pounds per million Btu heat input while 

burning oil; 

1.8 pounds per million Btu heat input while 

burning coal; or 

E = [(Ec)(Qc) + (Eo)(Qo)]/Qt 

Where; 

E = the emission limit in pounds per million Btu 

heat input for the fuel combination; 

Ec = 1.8 pounds per million Btu heat input while 

burning coal; 

Eo = 0.8 pounds per million Btu heat input while 

burning oil; 

Qc = coal heat input in Btu per hour; 

Qo = oil heat input in Btu per hour; and 

Qt = Qc + Qo 

15A NCAC 2D .0519 

particulate 0.10 lb/million Btu heat input (all fuels) 15A NCAC 2D .0524 

40 CFR 60, Subpart D 

particulate 0.085 lb/million Btu heat input 

(See Section 2.2.A.) 

15A NCAC 2D .0530 

sulfur dioxide 0.8 lb/million Btu heat input (oil) 

1.2 lb/million Btu heat input (coal) 

15A NCAC 2D .0524 

40 CFR 60, Subpart D 

sulfur dioxide sulfur dioxide emissions from the Big Bill, Peter 

G., Riley Coal and No. 4 Power Boilers shall be 

limited to 8,277 tons per rolling consecutive12 

months(See Section 2.2.A.) 

15A NCAC 2Q .0317 

Avoidance of 

15A NCAC 2D .0530 

nitrogen oxides 0.3 lb/million Btu heat input (oil) 

0.7 lb/million Btu heat input (coal) 

15A NCAC 2D .0524 

40 CFR 60, Subpart D 

nitrogen oxides nitrogen oxides emissions from the Big Bill, Peter 

G., Riley Coal and No. 4 Power Boilers shall be 

limited to 4,368 tons per rolling consecutive 12 

months (See Section 2.2.A.) 

15A NCAC 2D .0530 

nitrogen oxides NC SIP nitrogen oxides emissions allocations 

during ozone season (see Section 2.2.B.) 

15A NCAC 2D .1417 

visible emissions 20% opacity 15A NCAC 2D .0524 

40 CFR 60, Subpart D 

carbon monoxide carbon monoxide emissions from the Big Bill, 

Peter G., Riley Coal and No. 4 Power Boilers 

shall be limited to 898.2 tons per rolling 

consecutive 12 months (See Section 2.2.A.) 

15A NCAC 2D .0530 

 

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1. 15A NCAC 2D .0519: CONTROL OF NITROGEN OXIDES EMISSIONS 

a. Emissions of nitrogen oxides from these sources when burning coal and oil shall be calculated by the 

following equation [15A NCAC 2D .0519]: 

E = [(Ec)(Qc) + (Eo)(Qo)]/Qt

where: E = emission limit for combined burning of coal and oil in pounds per million Btu heat 

input 

Ec = 1.8 pounds per million Btu heat input for coal only 

Eo = 0.8 pounds per million Btu heat input for oil only 

Qc = coal heat input in Btu per hour 

Qo = oil heat input in Btu per hour 

Qt = Qc + Qo 

Testing [15A NCAC 2D .0501(c)] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c) 

and General Condition JJ. If the results of this test are above the limit given in Section 2.1 U.1.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0519. 

c. Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 No monitoring recordkeeping or reporting are required for the burning of coal or oil in this source. 

2. 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS (40 CFR PART 60 SUBPART D) 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements in accordance with 15A NCAC 2D .0524, “New Source 

Performance Standards” (NSPS) as promulgated in 40 CFR Part 60, Subpart D, including Subpart A “General 

Provisions.”[15A NCAC 2D .0524] 

b. For the No. 4 Power Boiler (ID No. G1140) the following emission limits shall not be exceeded 

[15A NCAC 2D .0524; 40 CFR 60.42, 60.43, and 60.44]: 

Regulated Pollutant Limits/Standards 

particulates 0.10 lb/million Btu heat input (all fuels) 

visible emissions 20 percent opacity (except during periods of startup, shutdown and malfunction) 

except for one six-minute period per hour of not more than 27 percent opacity 

sulfur dioxide 0.8 lb (oil only) / million Btu heat input 

1.2 lb (coal only) / million Btu heat input 

or 

S = [y (0.8) + z (1.2)] / y + z 

Where y = % total heat input from oil 

 z = % total heat input from coal 

nitrogen oxides 0.3 lb (oil only) / million Btu heat input 

0.7 lb (coal only) / million Btu heat input 

or 

S = [y (0.3) + z (1.2)] / y + z 

Where y = % total heat input from oil 

 z = % total heat input from coal 

Testing [15A NCAC 2D .0501(c)] 

c. If emission testing is required, the testing shall be performed in accordance General Condition JJ found in 

Section 3. If the results of the test are above the limits given in Section 2.1 U. 2. b. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0524. 

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Monitoring [15A NCAC 2Q .0508(f)] 

d. The Permittee shall demonstrate compliance with the emission limit(s) above by testing the No. 4 Power 

Boiler (ID No. G1140) for particulate matter in accordance with a testing protocol approved by the DAQ. 

Details of the emissions testing and reporting requirements can be found in Section 3 - General Condition JJ. 

 Testing shall be completed and the results submitted within the 180 days of the effective date of Permit No. 

08961T08 unless an alternate date is approved by the DAQ. The testing shall be performed annually 

thereafter. If the results of the testing demonstrate results at less than 80 percent of the limit above, the 

testing frequency may reduced to every permit cycle. If the results of this or any test are above the limit 

given in Section 2.1 U. 2. b. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.0524. 

Monitoring [15A NCAC 2Q .0508(f)] 

e. Particulate matter emissions from this boiler (ID No. G11040) shall be controlled by the ESP (ID Nos. 11-

CD-006-01). The Permittee shall monitor the following parameters daily for values outside the normal 

operating range in each field or section: 

i. primary voltage, 

ii. primary current, and 

iii. secondary current. 

The Permittee shall establish “normal” for these parameters within the first 30 days following the effective 

date of permit 08961T08 and submit the proposed ranges to the DAQ for incorporation into this permit within 

60 days of the effective date of said permit. The permit shall be administratively amended to incorporate the 

approved values.

The Permittee shall be allowed three (3) days of absent observations per semi-annual period. If the emission 

source(s) is not operating, a record of this fact along with the corresponding date and time shall substitute for 

the daily observation. 

f. If the ESP parameters above are observed to be outside the prescribed range, the Permittee shall inspect the 

ESP for malfunctions, take the necessary measures to correct any problems, and return the parameter to the 

proper range. 

Notwithstanding any prior reduced testing frequency allowed per 2.1.U.2.d above, if the ESP parameter 

readings recorded as required above are observed to be outside the allowable range, in order to ensure that the 

abnormal value(s) is indicative of compliance, the Permittee shall be required to perform annual testing as 

outlined in 2.1.U.2.d above. If the ESP parameter is observed to be outside the allowable range within 60 

days prior to the end of the calendar year, the testing may be conducted the following calendar year. 

However, testing in this case shall be performed within the first quarter of the following year. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

h. The results of the electrostatic precipitator monitoring shall be maintained in a logbook (written or electronic 

form) on site and made available to an authorized representative upon request. The logbook shall record the 

following: 

i. the date and time of actions recorded, 

ii. the normal range of values for each parameter, 

iii. the values of each parameter, 

iv. the causes for any variance from the prescribed operating range(s), and 

v. corrective actions taken. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if these parameters are not 

monitored or these records are not maintained. 

Monitoring/Recordkeeping [15A NCAC 2D .0524] 

i. The Permittee shall install, maintain, and operate a continuous opacity monitoring system (COMS) for 

measuring the opacity of emissions meeting the requirements of 40 CFR Part 60. [40 CFR 60.45] 

j. Compliance with opacity limit of Section 2.1.U.2.b above, shall be determined using six-minute averages of 

the COMS values. If any six-minute period average exceeds 20 percent opacity (except during periods of 

startup, shutdown and malfunction) except for one six-minute period per hour of not more than 27 percent 

opacity, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524. [40 CFR 60.45] 

k. The COMS and the facility shall be assessed for good operation and maintenance (O&M) practices in 

accordance with 40 CFR Part 60, Subpart A, Section 60.11(d); Subpart D, Section 60.45; and the EPA 

Region IV Continuous Emission Monitor Enforcement Plan (CEP). 

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Monitoring / Recordkeeping [15A NCAC 2D .0524, 2Q .0508(f)] 

l. As allowed per 40 CFR 60.45(b)(2) for a fossil fuel-fired steam generator that does not use a flue gas 

desulfurization device, a continuous monitoring system for measuring sulfur dioxide emissions is not required 

if the owner or operator monitors sulfur dioxide emissions by fuel sampling and analysis. 

m. As required by 15A NCAC 2D .0524 under 40 CFR Subpart D, 60.45, to assure compliance, the Permittee 

shall monitor the sulfur and heat content of all the coal burned during the period by using coal supplier 

certification per total shipment received. The coal supplier certification shall be recorded in a logbook 

(written or electronic format) per total shipment and include the following information:

i. the name of the coal supplier; 

ii. a statement verifying that the methods used to determine the maximum sulfur content of the coal was in 

accordance with the following: 

(A) sampling - ASTM Method D 2234; 

(B) preparation - ASTM Method D 2013; 

(C) gross calorific value (Btu) - ASTM Method D-2015, D-3286, D-1989, or D-5865; 

(D) moisture content - ASTM Method D 3173 or D-3302; and 

(E) sulfur content - ASTM Method D 3177 or ASTM Method D 4239. 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur and heat content of 

the coal is not monitored and recorded. 

n. The maximum equivalent sulfur dioxide emission rate (as SO2) of any coal received and burned in 

the boiler shall not exceed 1.2 pounds per million Btu. The Permittee is required to calculate and record in a 

logbook (written or electronic format) the pounds of sulfur dioxide per million Btu heat content of the coal 

per total shipment. The equivalent sulfur dioxide emission rate (pounds per million Btu heat input) shall be 

calculated in accordance with with Method 19 of 40 CFR 60, Appendix A, Section 12.6 – Sulfur Retention 

Credit for Compliance Fuel. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if 

the results show an exceedance of the limit given above if the requirements above are not monitored and 

recorded. 

o. As required by 15A NCAC 2D .0524 under 40 CFR Subpart D, 60.45, to assure compliance, the Permittee 

shall monitor the sulfur content and heat content of the No. 6 fuel oil by using fuel oil supplier certifications 

per shipment and/or site specific fuel oil storage tank sampling and analysis. The fuel oil supplier 

certifications and/or sampling results shall be recorded in a logbook (written or electronic format) and include 

the following information: 

 i. the name of the fuel oil supplier; and 

ii. a statement verifying that the methods used to determine the maximum sulfur content of the fuel oil was 

in accordance with the following: 

(A) sample collection – ASTM D4177 or D4057; 

(B) heat of combustion (Btu) – ASTM D240 or D2015; and 

(C) sulfur content – ASTM D129, D-4294, or D1552. 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the sulfur and heat content of 

the fuel oil are not monitored and recorded. 

p. The maximum sulfur content (as SO2) of any No. 6 fuel oil received and burned in the boiler shall not exceed 

0.8 pounds per million Btu. The Permittee is required to calculate and record in a logbook (written or 

electronic format) the pounds of sulfur dioxide per million Btu heat content of the fuel oil per month. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the results show an 

exceedance of the limit given above or if the requirements above are not monitored and recorded 

Monitoring / Recordkeeping [15A NCAC 2D .0524, 2Q .0508(f)] 

q. As allowed per 40 CFR 60.45(b)(3) the Permittee has demonstrated that emissions of nitrogen oxides are less 

than 70 percent of the applicable standards in 40 CFR 60.44, and a continuous monitoring system for 

measuring nitrogen oxides emissions is not required pursuant to NSPS Subpart D. 

r. However, the Permittee is required to install and operate a continuous emission monitoring system (CEM) for 

nitrogen oxides pursuant to the requirements of Section 2.2.B. Therefore, whenever the Permittee operates 

the nitrogen oxide CEM system (regardless of the time of year), the Permittee shall use the CEM data to 

determine compliance with the applicable NSPS Subpart D nitrogen oxides standard in Section 2.1.U.2.b 

above as follows: 

i. The Permittee may evaluate the hourly emissions data produced by the nitrogen oxide CEM system for 

comparison against the nitrogen oxides standard in Section 2.1.U.2.b above. If any hourly value(s) 

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exceeds the limit, the Permittee shall calculate the nitrogen oxide emissions for the relevant time period 

pursuant to 2.1.U.2.r.ii, below; or 

ii. Compliance with the NSPS Subpart D nitrogen oxides standard in Section 2.1.U.2.b above shall be 

determined based on any three-hour period during which the average emissions (arithmetic average of 

three contiguous one-hour periods) exceed the applicable standard. 

When operated outside of the timeframe required under Section 2.2.B, the continuous monitoring system 

shall be operated in accordance with the applicable performance specifications in 40 CFR 60 Appendix B and 

quality assurance procedures in Appendix F, unless an alternative monitoring and quality assurance program 

is approved by the DAQ. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0524 if the results show an 

exceedance of the limit given above. 

Reporting [15A NCAC 2D .0524, 2Q .0508(f)] 

s. The Permittee shall submit a summary report of the ESP monitoring and recordkeeping postmarked on or 

before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

t. The Permittee shall submit excess emissions and monitoring system performance reports for the continuous 

opacity monitoring system, postmarked by the 30th day following the end of each calendar year quarter. The 

report shall include, as a minimum, the information required in 40 CFR 60.7(c), as follows: 

i. all six-minute periods of excess emissions including all six-minute periods exempted during startup, 

shutdown, and malfunction. 

u. The Permittee shall submit a summary report of the fuel suppliers certifications and calculations of the 

pounds of sulfur dioxide per million Btu heat content of each fuel per month post marked on or before 

January 30 of each calendar year for the preceding six-month period between July and December and July 30 

of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

v. The Permittee shall submit a summary report of the nitrogen oxides monitoring results. All instances of 

deviations from the requirements of this permit must be clearly identified. 

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V. Woodwaste, bark, “depoly” waste, fiber-based roll cores, on-site generated waste oil, 

and coal-fired Riley Bark Boiler (380 million Btu per hour maximum heat input rate, 

IDNo.G11042) with partial flyash reinjection, equipped with a multicyclone 

(approximately 160 nine inches in diameter tubes, ID No. 11-CD- 016-01)in series 

with a venturi-type wet scrubber (water with pH adjustment, ID No. 11-CD-016-02); 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate matter 0.16 pounds per million Btu heat input (when 

firing coal/ fuel oil only); 

0.31 pounds per million Btu heat input (when 

firing woodwaste only); or 

Ec = [(0.31)(Qw) + (0.16)(Qo)]/Qt 

Where; 

Ec = emission limit for combined firing (pound per 

mmBtu); 

Qw=actual wood heat input including woodwaste; 

Qo=actual heat input other than wood heat input; 

and 

Qt = Qw + Qo

15A NCAC 2D .0503 

15A NCAC 2D .0504

sulfur dioxide 2.3 lb/million Btu heat input 15A NCAC 2D .0516

Nitrogen oxides 1.8 lb/million Btu heat input (when firing coal) 15A NCAC 2D .0519 

Nitrogen oxides NC SIP nitrogen oxides emissions allocations 

during ozone season (See Section 2.2.B.) 

15A NCAC 2D .1417 

visible emissions 40 percent opacity 15A NCAC 2D .0521 

visible emissions Excess Emissions Monitoring Requirements 

(40 CFR 51, Appendix P)

15A NCAC 2D .0606

sulfur dioxide Monitoring Requirements (See Condition 2.1 V. 3) 15A NCAC 2D .0608

 

1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS 

a. Emissions of particulate matter from the combustion of coal and fuel oil that are discharged from this source 

into the atmosphere shall not exceed 0.16 pound per million Btu heat input. [15A NCAC 2D .0503(c)] 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the 

results of this test are above the limit given in Section 2.1 V. 1. a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0503. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. To assure compliance, the Permittee shall follow the monitoring, recordkeeping, and reporting requirements 

per Specific Conditions 2.1 V. 2. d-h. The Permittee shall be deemed in noncompliance with 2D .0503 if the 

monitoring and recordkeeping is not maintained. 

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2. 15A NCAC 2D .0504: PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS 

a. Emissions of particulate matter from this source shall not exceed an allowable emission rate as calculated by 

the following equation: [15A NCAC 2D .0504] 

Ec = [(0.31)(Qw) + (0.16)(Qo)]/Qt 

Where; 

Ec = emission limit for combined firing (pound per mmBtu); 

Qw = actual wood heat input including woodwaste; 

Qo = actual heat input other than wood heat input; and 

Qt = Qw + Qo 

Testing [15A NCAC 2D .0501(c)] 

b. If emissions testing is required, the testing shall be performed in accordance General Condition JJ. If the 

results of this test are above the limit given in Section 2.1 V. 2. a. above, the Permittee shall be deemed in 

noncompliance with 15A NCAC 2D .0504. 

c. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by testing the boiler for particulate matter in accordance with a testing protocol approved by 

the DAQ. Details of the emissions testing and reporting requirements can be found in Section 3 - General 

Condition JJ. Testing shall be completed and the results submitted within the calendar year of the effective 

date of Permit No. 08961T08 unless an alternate date is approved by the DAQ. The testing shall be 

performed annually thereafter. If the results of the testing demonstrate results at less than 80 percent of the 

limit above, the testing frequency may reduced to every five years. If the results of this or any test are above 

the limit given in Section 2.1 V. 2. a. above, the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .0504. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

d. Particulate matter emissions from the boiler shall be controlled by the multicyclone and venturi-type wet 

scrubber. The Permittee shall install, operate, and maintain a wet scrubbing liquid flowmeter and pressure 

drop indicator on the scrubber. To assure compliance and the effective operation of the scrubber, the 

Permittee shall continuously monitor and record scrubbing liquid flow rate and pressure drop on a 3-hour 

block average. 

The scrubber parameter monitoring system downtime shall not exceed two (2) percent of the monitoring time 

in any semi-annual reporting period. If the emission source(s) is not operating, a record of this fact along 

with the corresponding date and time shall substitute for the observation. The readings shall be recorded in a 

logbook (written or electronic format) on-site and made available to an authorized representative upon 

request. To ensure quality, the flow rate gauges or devices shall be calibrated annually. 

The scrubber shall be operated to ensure the following operational parameters are maintained: 

i. The pressure drop across the scrubber shall be greater than 4 inches water column, and 

ii. The scrubbing liquid flow rate shall be greater than 450 gallons per minute 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0504 if the scrubbing liquid flow rate 

or pressure drop is not maintained above the above prescribed value(s) or if these records are not maintained. 

e. If the scrubber liquid flow rate or pressure drop readings recorded as required in Section 2.1. V.2.d., above, 

are observed to be outside the prescribed range, the Permittee shall inspect the scrubber(s) for malfunctions 

and clean or repair, as necessary. The Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.0504 if the inspections, cleaning, and repairs are not performed. 

f. The results of inspection and maintenance activities, discussed above for the scrubbers, shall be maintained in 

a logbook (written or electronic format) on-site and made available to an authorized representative of DAQ 

upon request. The logbook shall record the following: 

i. the date and time of each recorded action 

ii. the results of each inspection; 

iii. the causes for any variance from the prescribed operating range for the scrubbers(s); and 

iii. corrective actions taken. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0504 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

g. The Permittee shall submit a summary report of the monitoring and recordkeeping activities postmarked on or 

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before January 30 of each calendar year for the preceding six-month period between July and December and 

July 30 of each calendar year for the preceding six-month period between January and June. All instances of 

deviations from the requirements of this permit must be clearly identified. 

3. 15A NCAC .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES

a. Emissions of sulfur dioxide from this source shall not exceed 2.3 pounds per million Btu heat input. Sulfur 

dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included 

when determining compliance with this standard. [15A NCAC 2D .0516]

Testing [15A NCAC 2D .0501(c) and 2D .0608] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.V.3. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0516. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f), and 2D .0608] 

c. To assure compliance with 2.1.V.3.a, the Permittee shall monitor the sulfur content and heat content of the 

coal by using coal supplier certification per total shipment received. The results of the coal supplier 

certifications shall be recorded in a logbook (written or electronic format) and include the following 

information: 

i. the name of the coal supplier; 

ii. a statement verifying that the methods used to determine the maximum sulfur content of the coal was in 

accordance with the following: 

(A) sampling - ASTM Method D 2234; 

(B) preparation - ASTM Method D 2013; 

(C) gross calorific value (Btu) - ASTM Method D-2015, D-3286, D-1989, or D-5865; 

(D) moisture content - ASTM Method D 3173 or D-3302; and 

(E) sulfur content - ASTM Method D 3177 or ASTM Method D 4239. 

Alternate test methods may be used upon prior DAQ approval per 15A NCAC 2D .0501(c)(18). 

d. Additionally, the Permittee is required to calculate and record in a logbook (written or electronic format) the 

equivalent emission rate in pounds of sulfur dioxide per million Btu heat content of the coal per total 

shipment. This equivalent sulfur dioxide emission rate (pounds per million Btu heat input) shall be calculated 

in accordance with Method 19 of 40 CFR 60, Appendix A, Section 12.6 – Sulfur Retention Credit for 

Compliance Fuel. The Permittee shall be deemed in noncompliance if the results show an exceedance of the 

limit given in Section 2.1 V. 3. a. above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0516 and 2D .0608 if the 

requirements above are not monitored and recorded. 

Reporting [15A NCAC 2Q .0508(f) and 2D .0608] 

e The Permittee shall submit a summary report of the coal supplier certifications and calculated emission rates 

postmarked on or before January 30 of each calendar year for the preceding six-month period between July 

and December and July 30 of each calendar year for the preceding six-month period between January and 

June. All instances of deviations from the requirements of this permit must be clearly identified. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0608 if the reports are not submitted. 

4. 15A NCAC 2D .0519: CONTROL OF NITROGEN OXIDES EMISSIONS 

a. Emissions of nitrogen oxides from these sources when burning coal and oil shall be calculated by the 

following equation [15A NCAC 2D .0519]: 

E = [(Ec)(Qc) + (Eo)(Qo)]/Qt

where: E = emission limit for combined burning of coal and oil in pounds per million Btu heat 

input 

Ec = 1.8 pounds per million Btu heat input for coal only 

Eo = 0.8 pounds per million Btu heat input for oil only 

Qc = coal heat input in Btu per hour 

Qo = oil heat input in Btu per hour 

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Qt = Qc + Qo 

Testing [15A NCAC 2D .0501(c)] 

 b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c) 

and General Condition JJ. If the results of this test are above the limit given in Section 2.1 V.4.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0519. 

c. Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

 No monitoring recordkeeping or reporting is required for the burning of coal or oil in this source. 

5. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS 

a. Visible emissions from this sources shall not be more than 40 percent opacity (except during startups) when 

averaged over a six-minute period except that six-minute periods averaging not more than 90 percent opacity 

may occur not more than once in any hour nor more than four times in any 24-hour period. [15A NCAC 2D 

.0521(c)] 

b. For sources required to install, operate, and maintain continuous opacity monitoring systems (COMS), 

compliance with the 40 percent opacity limit shall be determined as follows:[15A NCAC 2D .0521(g)] 

i. No more than four six-minute periods shall exceed the opacity standard in any one day; and 

ii. The percent of excess emissions (defined as the percentage of monitored operating time in a calendar 

quarter above the opacity limit) shall not exceed 0.8 percent of the total operating hours. If a source 

operates less than 500 hours during a calendar quarter, the percent of excess emissions shall be 

calculated by including hours operated immediately previous to this quarter until 500 operational hours 

are obtained. 

Excess emissions during startup and shutdown shall be excluded from the determinations in paragraphs b.i. 

and b.ii. above, if the excess emissions are exempted according to the procedures set out in 2D .0535(g). 

Excess emissions during malfunctions shall be excluded from the determinations in paragraphs b.i. and b.ii. 

above, if the excess emissions are exempted according to the procedures set out in 2D .0535(c). 

All periods of excess emissions shall be included in the determinations in paragraphs b.i. and b.ii above until 

such time that the excess emissions are exempted according to the procedures in 2D .0535. 

Testing [15A NCAC 2D .0501(c)(8)] 

c. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ. If the results of this test are above the limit given in Section 2.1 V.5.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The Permittee shall use a continuous opacity monitoring system (COMS) to monitor and record opacity. 

Continuous emissions monitoring and recordkeeping of opacity shall be performed as described in 

Paragraphs 2 and 3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet 

the minimum specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51. 

During periods of unreliability of the COMS on Riley Bark Boiler due to uncombined water in the stack, the 

Permittee shall demonstrate compliance with the opacity limit in Section 2.1.V.5.a using the scrubber 

monitoring in Section 2.1.V.2.d above. The Permittee shall document periods of unreliability due to 

uncombined water or in the stack. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if the monitoring is not 

performed, if the monitored values exceed the limitations given above, or if the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the monitoring data postmarked on or before January 30 of 

each calendar year for the preceding six-month period between July and December and July 30 of each 

calendar year for the preceding six-month period between January and June. All instances of deviations from 

the requirements of this permit must be clearly identified. 

6. 15A NCAC 2D .0606: SOURCES COVERED BY APPENDIX P OF 40 CFR PART 51 (CONTINUOUS 

OPACITY MONITORING AND EXCESS EMISSIONS)

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For the Riley Bark Boilers (ID No. G11042) the provisions of 15A NCAC 2D .0606 apply as follows: 

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f) and 2D .0606] 

a. The Permittee shall use a continuous opacity monitoring system (COMS) to monitor and record opacity. 

Continuous emissions monitoring and recordkeeping of opacity shall be performed as described in Paragraphs 2 

and 3.1.1 through 3.1.5 of Appendix P of 40 CFR Part 51. The monitoring systems shall meet the minimum 

specifications described in Paragraphs 3.3 through 3.8 of Appendix P of 40 CFR Part 51. 

During periods of unreliability of the COMS on Riley Bark Boiler due to uncombined water in the stack, the 

Permittee shall demonstrate compliance with the opacity limit in Section 2.1.V.5.a using the scrubber monitoring 

in Section 2.1.V2.d above. The Permittee shall document periods of unreliability due to uncombined water or in 

the stack. These periods shall be excluded from the excess emissions calculations below and shall not be to be 

considered monitor downtime, provided the monitors are otherwise operating during these periods. 

b. The quarterly excess emissions (EE) reports required under Appendix P of 40 CFR Part 51 shall be used as an 

indication of good operation and maintenance of the multicyclone and scrubber. These sources shall be deemed 

to be properly operated and maintained if the percentage of time the opacity emissions, calculated on a 6-minute 

average, in excess of 40 percent (including startups, shutdowns, and malfunctions) does not exceed 3.0 percent of 

the total operating time for any given calendar quarter, adjusted for monitor downtime (MD) as calculated below. 

 In addition, these sources shall be deemed to be properly operated and maintained if the %MD does not exceed 

2.0 percent. 

Calculations for %EE and %MD

Percent Excess Opacity Emission (%EE) Calculation: 

%EE = Total Excess Emission Time* x 100 

 (Total Source Operating Time***) - (Monitor Downtime) 

Percent Monitor Downtime (%MD) Calculation for COMS: 

%MD = Total Monitor Downtime** x 100 

(Total Source Operating Time***) 

* Total Excess Emission Time contains any 6-minute period greater than 40% opacity including 

startup, shutdown, and malfunction. 

** Total Monitor Downtime includes Quality Assurance (QA) activities unless exempted by 

regulation or defined in an agency approved QA Manual. The amount of exempt QA Time will be 

reported in the quarterly report as such. 

*** If a source operates less than 2200 hours during any quarter, the source may calculate the %EE 

and/or %MD using all operating data for the current quarter and the preceding quarters until 2200 

hours of data are obtained. [N.C.G.S. 143-215.110] 

Reporting [15A NCAC 2Q .0508(f) and 2D .0606] 

c. The Permittee shall submit the excess emissions and monitor downtime reports as required under Appendix P of 

40 CFR Part 51 no later than January 30 of each calendar year for the preceding three-month period between 

October and December, April 30 of each calendar year for the preceding three-month period between January and 

March, July 30 of each calendar year for the preceding three-month period between April and June, and October 

30 of each calendar year for the preceding three-month period between July and September. For periods of 

excess emissions, defined as each six-minute period average greater than 40 percent opacity, the opacity 

measurements recorded by the COMS shall be reported as described in Paragraphs 4 and 5.1 of Appendix P of 40 

CFR Part 51 except that a six-minute time period shall be deemed as an appropriate alternative opacity averaging 

period as described in Paragraph 4.2 of Appendix P of 40 CFR Part 51. A minimum of 36 data points, equally 

spaced, is required to determine a valid six-minute value. All instances of deviations from the requirements of 

this permit must be clearly identified. All excluded periods due to unreliability of the COMS on the Riley Bark 

Boiler due to uncombined water in the stack shall be clearly identified. 

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W. Bark Fuel Feed System and associated transfer cyclone and 

“Depoly” Fuel Feed System and associated transfer cyclone (ID No. 11044) 

for Riley Bark Boiler. 

Utility boiler flyash handling system consisting of the main flyash silo and pneumatic 

flyash collection system (ID No. 11045) and separate No. 4 Power Boiler flyash transfer 

silo (ID No. 11025). 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 P 0.67 15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from each of these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour

Testing [15A NCAC 2D .0501 (c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.W.1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the Bark Feed System and “Depoly” Feed System (ID No. G11044) shall 

be controlled by the respective, associated cyclone. Particulate matter emissions from the Utility Boiler 

Flyash Handling System (ID Nos. G11045 and G11025) shall be controlled by their respective bin vent 

bagfilters and the pneumatic system dust separator cyclone with bagfilters. To assure compliance, the 

Permittee shall perform inspections and maintenance. As a minimum, the inspection and maintenance 

requirement shall include the following: 

i. a monthly visual inspection (for each calendar month, not to exceed 6 weeks from the previous 

inspection) of the system ductwork and material collection unit for leaks; and 

ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous 

inspection) of the bagfilters’ and cyclones’ structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, bagfilters, 

and cyclones are not inspected and maintained.

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) 

on-site and made available to an authorized representative upon request. The logbook shall record the 

following: 

i. the date and time of each recorded action; 

ii. the results of each inspection; 

iii. the results of any maintenance performed on the bagfilters or cyclones; and 

iv. any corrections made. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not 

maintained.

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit the results of any maintenance performed on the bagfilters or cyclones within 30 

days of a written request by the DAQ. 

f. The Permittee shall submit a summary report of monitoring and recordkeeping activities postmarked on or before 

January 30 of each calendar year for the preceding six-month period between July and December and July 30 of 

each calendar year for the preceding six-month period between January and June. All instances of deviations 

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Appendix L.10 - 433 

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from the requirements of this permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the Bark Feed System and “Depoly” Feed System (ID No. G11044) and Utility Boiler 

Flyash Handling System (ID Nos. G11045 and G11025) shall not be more than 20 percent opacity when 

averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more 

than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute 

average exceed 87 percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1.W.2.a. 

above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

visible emissions above normal. The Permittee shall establish “normal” for the source in the first 30 days 

following the effective date of permit 08961T08. If visible emissions from any source are observed to be 

above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each 

calendar year for the preceding six-month period between July and December and July 30 of each calendar year 

for the preceding six-month period between January and June. All instances of deviations from the requirements 

of this permit must be clearly identified. 

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PAPER MACHINES (Area 12) 

X. No. 20 Paper Machine (ID No. G12048); No. 19 Paper Machine (ID No. G12049); 

No. 12 Paper Machine (ID No. G12050); and No. 11 Paper Machine (ID No. G12051) 

The following table provides a summary of limits and standards for the emission source(s) described above: 

Regulated Pollutant Limits/Standards Applicable Regulations

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

CHEMICAL PREPARATION (Area 13) 

Y. Three starch storage silos (30 tons per hour maximum throughput each, ID Nos. 

G13054, G13055, and G13056) controlled by a 255 square feet of filter area bagfilter, a 

183 square feet of filter area bin vent filter, and a 255 square feet of filter area bagfilter 

(ID Nos. 13-CD-014-01, 13-CD-016-01, and 13-CD-020-01), respectively. 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 x P 0.67 15A NCAC 2D .0515

visible emissions 20 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from each of these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found in 

Section 3. If the results of this test are above the limit given in Section 2.1.Y. 1. a. above, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. Particulate matter emissions from the starch silos (ID Nos. G13054, G13055, and G13056) shall be 

controlled by the bagfilters and bin vent filter. To assure compliance, the Permittee shall perform inspections 

and maintenance. As a minimum, the inspection and maintenance requirement shall include the following: 

i. a monthly visual inspection (for each calendar month, not to exceed 6 weeks from the previous 

inspection) of the system ductwork and material collection unit for leaks; and 

ii. an annual internal inspection (for each calendar year, not to exceed 14 months from the previous 

inspection) of the bagfilters' and bin vent filter's structural integrity. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if the ductwork, bagfilters, and 

bin vent filter are not inspected and maintained. 

d. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action;

ii. the results of each inspection; 

iii. the results of any maintenance performed on the bagfilters and bin vent filter; and 

iv. any corrections made. 

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Appendix L.10 - 435 

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The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0515 if these records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each 

calendar year for the preceding six-month period between July and December and July 30 of each calendar year 

for the preceding six-month period between January and June. All instances of deviations from the requirements 

of this permit must be clearly identified. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the starch silos shall not be more than 20 percent opacity when averaged over a six-minute 

period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not 

more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. 

[15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) and 

General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1Y.2.a. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

visible emissions above normal. The Permittee shall establish a “normal” for the source in the first 30 days 

following the effective date of permit 08961T08. If visible emissions from any source are observed to be 

above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each 

calendar year for the preceding six-month period between July and December and July 30 of each calendar year 

for the preceding six-month period between January and June. All instances of deviations from the requirements 

of this permit must be clearly identified. 

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WASTEWATER TREATMENT PLANT (Area 16)

Z. WTP Primary Clarifiers (ID No. G16081) and WTP Aeration and Digestion Basins (ID 

No. G16082)

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutants Limits / Standards Applicable Regulations 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

PAPER CONVERTING (Area 19) 

AA. Rewinders on Trim System #1 (ID No. G19058) and Rewinders on Trim System #2 (ID 

No. G19059)

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

particulate E = 4.10 x P 0.67 15A NCAC 2D .0515

visible emissions 40 percent opacity 15A NCAC 2D .0521

1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from each of these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.AA. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping [15A NCAC 2Q .0508(f)] 

c. The Permittee shall maintain production records which specify the types of materials processed and shall 

make these records available to a DAQ authorized representative upon request. The Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .0515 if the production records are not maintained or the 

types of materials are not monitored. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the rewinders shall not be more than 40 percent opacity when averaged over a sixminute period. However, six-minute averaging periods may exceed 40 percent not more than once in any 

hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 90 

percent opacity. [15A NCAC 2D .0521 (c)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 AA. 

2.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring [15A NCAC 2Q .0508(f)] 

c. To assure compliance, once a month the Permittee shall observe the emission points of the sources for any 

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Appendix L.10 - 437 

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visible emissions above normal. The Permittee shall establish a “normal” for the source in the first 30 days 

following the effective date of permit 08961T08. If visible emissions from any source are observed to be 

above normal, the Permittee shall either: 

i. take appropriate action to correct the above-normal emissions within the monitoring period and record 

the action taken as provided in the recordkeeping requirements below, or 

ii. demonstrate that the percent opacity from the emission points of the emission source in accordance with 

15A NCAC 2D .0501(c)(8) is below the limit given above. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D.0521 unless (within the monitoring 

period) either: 1) the above-normal emissions are corrected per (i) above or, 2) the demonstration per (ii) 

above is made. 

Recordkeeping [15A NCAC 2Q .0508(f)] 

d. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made 

available to an authorized representative upon request. The logbook shall record the following: 

i. the date and time of each recorded action; 

ii. the results of each observation and/or test noting those sources with emissions that were observed to be 

above normal along with any corrective actions taken to reduce visible emissions; and 

iii. the results of any corrective actions performed. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521 if these records are not 

maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

e. The Permittee shall submit a summary report of the observations postmarked on or before January 30 of each 

calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. 

BART Related Documentation 

Regional Haze SIP for NC Class I Areas 

Appendix L.10 - 438 

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TURPENTINE RECOVERY (Area 20) 

BB. No. 1 Hardwood Turpentine Recovery System (ID No. G20060) and No. 2 Pine 

Turpentine Recovery System (ID No. G20062) exhausting to the NCG collection system 

(ID No. G23078) for incineration in the No. 4 Lime Kiln or No. 5 Lime Kiln. 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

HAP (See Section 2.2.C.) 15A NCAC 2D .1111 

(40 CFR Part 63 Subpart S) 

TALL OIL PRODUCTION (Area 21) 

CC. Tall Oil Reactor (ID No. G21072) controlled by a packed tower-type wet scrubber 

(10-15 gallons per minute minimum injection rate, ID No. 21-ST-008-01) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100 

DD. No. 1 Hardwood Fiberline Deckers (ID No. G24087) and No. 2 Pine Fiberline Deckers 

(ID No. G24088) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

HAP (See Section 2.2.C.) 15A NCAC 2D .1111 

(40 CFR Part 63 Subpart S) 

EE. One 1850 horsepower, diesel-fired emergency generator (ID No. 16-CU-001) 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation 

sulfur dioxide 2.3 lb/million Btu heat input 15A NCAC 2D .0516 

visible emissions 20 percent opacity 15A NCAC 2D .0521 

HAPs Notification Requirements 15A NCAC 2D .1111 

(40 CFR Part 63 Subpart ZZZZ) 

1. 15A NCAC 2D .0516: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL PROCESSES

a. Emissions of particulate matter from each of these sources shall not exceed an allowable emission rate as 

calculated by the following equation: [15A NCAC 2D .0515(a)] 

E = 4.10 x P 0.67 Where E = allowable emission rate in pounds per hour 

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P = process weight in tons per hour 

Liquid and gaseous fuels and combustion air are not considered as part of the process weight. 

Testing [15A NCAC 2D .0501 (c)(3)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of this test are above the limit given in Section 2.1.EE. 1. a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0515.

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. No monitoring/recordkeeping/reporting is required from the firing of diesel fuel oil in this source for this 

regulation. 

2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS

a. Visible emissions from the generator shall not be more than 20 percent opacity when averaged over a sixminute period. However, six-minute averaging periods may exceed 20 percent not more than once in any 

hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 

percent opacity. [15A NCAC 2D .0521 (d)] 

Testing [15A NCAC 2D .0501(c)(8)] 

b. If emissions testing is required, the testing shall be performed in accordance with 15A NCAC 2D .0501(c)(8) 

and General Condition JJ found in Section 3. If the results of this test are above the limit given in 2.1 EE. 

2.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0521. 

Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] 

c. No monitoring/recordkeeping/reporting is required from the firing of diesel fuel oil in this source for this 

regulation.

3. 15A NCAC 2D .1111: MACT 40 CFR 63 SUBPART ZZZZ 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 

15A NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as promulgated in 40 CFR Part 

63 Subpart ZZZZ, including Subpart A “General Provisions.” 

 i. For the reciprocating internal combustion engine (ID No. 16-CU-001), the Permittee shall comply with the 

Initial Notification Requirements per 40 CFR 63.6645(d) contained in Environmental Management 

Commission Standard 15A NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as 

promulgated in 40 CFR 63 Subpart ZZZZ. 

 ii. The Permittee shall submit an Initial Notification no later than 120 calendar days after initial start-up.

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2.2- Multiple Emission Sources Specific Limitations and Conditions

A. Prevention of Significant Deterioration (PSD) BACT-affected Sources: 

1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements in accordance with 15A NCAC 2D .0530, “Prevention of 

Significant Deterioration of Air Quality” as promulgated in 40 CFR 51.166. [15A NCAC 2D .0530] 

Operations Restrictions [15A NCAC 2D .0530] 

b. As required by 40 CFR 51.166 and as approved by the Western North Carolina Air Pollution Control Agency 

in the Final BACT Determination dated July 27, 1984, the following requirements on the No. 4 Power Boiler 

(ID No. G11040) shall be met: 

i. a dust suppression system and enclosed conveyor system for feeding coal to the boilers shall be installed 

and maintained; 

ii. the boiler design shall incorporate low excess air in the primary combustion zone and staged combustion, 

and tangential firing to control NOx emissions; 

iii. the coal fuel shall be low sulfur coal, and the NSPS limits for sulfur dioxide, and nitrogen oxides shall 

apply; 

iv. the particulate matter emissions shall be limited to 0.085 pounds per million Btu; 

v. boilers Big Bill (ID No. G11037), Peter G (ID No. G11038), and Riley Coal (ID No. G11039) shall be 

limited to a steam production of no more than 274,000 lb steam/hr (364 million Btu per hour heat input), 

274,000 lb steam/hr (364 million Btu per hour heat input), and 300,000 lb steam/hr (399 million Btu per 

hour heat input), respectively; 

vi. boilers Big Bill (ID No. G11037), Peter G (ID No. G11038), and Riley Coal (ID No. G11039) shall be 

limited to particulate matter emissions of no more than 0.15 pounds per million Btu, each; 

vii. nitrogen oxide emissions from boilers Big Bill, Peter G, Riley Coal, and No. 4 Power Boiler shall be 

limited to 4,368 tons per 12-month rolling total; and 

viii. carbon monoxide emissions from boiler Big Bill, Peter G, Riley Coal, and No. 4 Power Boiler shall be 

limited to 898.2 tons per 12-month rolling total.

The Permittee shall be deemed in noncompliance with 2D .0530 if these operational restrictions are exceeded. 

Testing [15A NCAC 2D .0501 (c)] 

c. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the results of the testing are above the limits given in Section 2.2. A. 1.b. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0530. 

d. Under the provisions of NCGS 143-215.108, the Permittee shall demonstrate compliance with the emission 

limit(s) above by utilizing the test results of the particulate matter testing required per Section 2.1.T and 

2.1.U. If the results of the testing are above the limits given in Section 2.2. A. 1.b. above, the Permittee shall 

be deemed in noncompliance with 15A NCAC 2D .0530. 

Monitoring, Recordkeeping, and Reporting [15A NCAC 2Q .0508(f)] 

e. For compliance purposes, the following shall be monitored and recorded (in written or electronic format): 

i. the monthly usage of all fuels burned at the facility, categorized by source, for the previous fourteen 

months. The usage must be calculated for each of the three twelve month periods over the previous 

fourteen months; 

ii. the total monthly nitrogen oxide, and carbon monoxide emissions from Big Bill, Peter G, Riley Coal, and 

No. 4 Power Boiler for the previous fourteen months. The emissions shall be provided for each of the 

three twelve month periods over the previous fourteen months; and 

iii. The Permittee shall keep each monthly record on file for a minimum of three years. 

iv. The Permittee shall follow the ESP monitoring, and recordkeeping per Specific Conditions 2.1 T. 1. d-e, 

and 2.1 U.2 d-h. 

The Permittee shall be deemed in noncompliance with 2D .0530 if these requirements are not monitored or if 

the records are not maintained. 

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Reporting [15A NCAC 2Q .0508(f)] 

f. The Permittee shall submit a summary report, acceptable to the Regional Air Quality Supervisor, of 

monitoring and recordkeeping activities within 30 days after each calendar year quarter, due and postmarked 

on or before January 30 of each calendar year for the preceding three-month period between October and 

December, April 30 of each calendar year for the preceding three-month period between January and March, 

July 30 of each calendar year for the preceding three-month period between April and June, and October 30 

of each calendar year for the preceding three-month period between July and September. 

2. 15A NCAC 2Q .0317: AVIODANCE CONDITIONS for 

15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION 

a. In order to avoid applicability of 15A NCAC 2D .0530 for major sources and major modifications, sulfur 

dioxide emissions from boilers Big Bill, Peter G, Riley Coal, and No. 4 Power Boiler shall be limited to 

8,277 tons per 12-month rolling total as approved by the Western North Carolina Air Pollution Control 

Agency in the PSD application and subsequent permit dated July 27, 1984. [15A NCAC 2D .0530] 

Testing [15A NCAC 2D .0501 (c)] 

b. If emissions testing is required, the testing shall be performed in accordance with General Condition JJ found 

in Section 3. If the result of the testing is above the limit given in Section 2.2. A. 2.a. above, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .0530. 

Monitoring, Recordkeeping, and Reporting [15A NCAC 2Q .0508(f)] 

c. For compliance purposes, the following shall be monitored and recorded (in written or electronic format): 

i. the monthly usage of all fuels burned at the facility, categorized by source, for the previous fourteen 

months. The usage must be calculated for each of the three twelve month periods over the previous 

fourteen months; 

ii. the total monthly sulfur dioxide emissions from Big Bill, Peter G, Riley Coal, and No. 4 Power Boiler for 

the previous fourteen months. The sulfur dioxide data shall utilize fuel sulfur sampling results for coal 

and fuel oil. The emissions shall be provided for each of the three twelve month periods over the 

previous fourteen months; and 

iii. The Permittee shall keep each monthly record on file for a minimum of three years. 

The Permittee shall be deemed in noncompliance with 2D .0530 if these requirements are not monitored or if 

the records are not maintained. 

Reporting [15A NCAC 2Q .0508(f)] 

d. The Permittee shall submit a summary report, acceptable to the Regional Air Quality Supervisor, of 

monitoring and recordkeeping activities within 30 days after each calendar year quarter, due and postmarked 

on or before January 30 of each calendar year for the preceding three-month period between October and 

December, April 30 of each calendar year for the preceding three-month period between January and March, 

July 30 of each calendar year for the preceding three-month period between April and June, and October 30 

of each calendar year for the preceding three-month period between July and September. 

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B. Nitrogen Oxides Emissions Allocation-affected Sources: 

1. 15A NCAC 2D .1417 EMISSION ALLOCATIONS FOR LARGE COMBUSTION SOURCES 

a. The facility shall comply with 15A NCAC 2D .1417. The Permittee has the following allocations of nitrogen 

oxide emissions during the May 31, 2004 through September 30, 2004 ozone season and the May 1st through 

September 30th ozone seasons thereafter, from the affected sources as summarized in the table below: 

Source NOX Emission Allocations 

(tons/ozone season) 

2004 

NOX Emission Allocations 

(tons/ozone season) 

2005 

NOX Emission Allocations 

(tons/ozone season) 

2006 and later 

Big Bill Boiler 212 265 141 

Peter G Boiler 187 234 125 

Riley Coal Boiler 358 447 239 

No. 4 Power Boiler 365 456 244 

Riley Bark Boiler 135 169 90 

Monitoring/Recordkeeping [15A NCAC 2D .0508(f), 15A NCAC 2D .1417(e), 15A NCAC 2D .1404(d)] 

b. The sources listed above shall comply with the requirements of 15 A NCAC 2D .1417 using the nitrogen 

oxide budget trading program set out in 15A NCAC 2D .1419 and as follows: 

i. Sources shall using the procedures of and complying with the requirements of 40 CFR Part 96, Nitrogen 

Oxide Budget Trading Program for State Implementation Plans, with the following exceptions: 

 (1) Permit applications shall be submitted following the procedures and schedules in this Section and in 

Subchapter 2Q of this Title instead of the procedures and schedules in 40 CFR Part 96; and 

 (2) The dates and schedules for monitoring systems in 40 CFR Part 96 shall not apply; however, if a 

source operates during the ozone season, it shall have installed and begun operating by May 31, 

2004, a continuous emissions monitoring system that complies with 40 CFR Part 96. 

c. During the ozone season, the Permittee shall show compliance using continuous emissions monitors that meet 

the requirements of 40 CFR Part 75, Subpart H or 40 CFR Part 96 [15A NCAC 2D .1417(e)]. 

d. All emission control devices and techniques installed to comply with 15A NCAC 2D .1417 shall be operated 

during the ozone season as defined above in the manner in which they are designed and permitted to be 

operated. 

e. The Permittee shall submit an application, to revise the permit in order to make a modification or to 

construct and begin operating a control device, before source modification(s) or control device 

installation(s).

Reporting [15A NCAC 2D .1404] 

f. The Permittee shall comply with the reporting requirements of 40 CFR Part 96, Budget Trading Program for 

State Implementation Plans. No later than October 30, the owner or operator shall report to the Director the 

tons of nitrogen oxides emitted during the previous ozone season. The Division of Air Quality shall make this 

information publicly available. 

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C. 40 CFR 63, Subpart S Affected Sources:

Source ID No. Source Description Control ID No Control Description 

Bleaching System Sources 

G05012 No. 1 Hardwood Fiberline 

Bleaching System: 

ES 05-PU-003 D1 (ClO2) Stage Tower 

ES 05-PU-004 D1 (ClO2) Stage Washer 

ES 05-TK-003 D1 (ClO2) Stage Filtrate Tank 

ES 05-PU-010 D2 (ClO2) Stage Tower 

ES 05-PU-012 D2 (ClO2) Stage Washer 

ES 05-TK-011 D2 (ClO2) Stage Filtrate Tank 

05-CD-002-01 No.1 Hardwood Fiberline Bleach Plant 

Wet Scrubber (via closed-vent 

collection system) 

G05013 No. 2 Pine Fiberline Bleaching 

System: 

ES 05-PU-017 D1 (ClO2) Stage Tower 

ES 05-TK-018 D1 (ClO2) Stage Filtrate Tank 

ES 05-PU-021 D2 (ClO2) Stage Tower 

ES 05-TK-027 D2 (ClO2) Stage Filtrate Tank 

05-CD-017-01 No.2 Pine Fiberline Bleach Plant Wet 

Scrubber (via closed-vent collection 

system) 

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C. 40 CFR 63, Subpart S Affected Sources, continued:

Source ID No. Source Description Control ID No Control Description 

LVHC System Sources

G07018 Foul Condensate System: 

ES 07-PU-015 Condensate Stripper 

ES 07-TK-011 Stripper Feed Tank 

ES 07-TK-014 Reflux Tank 

LVHC Foul Gas Collection System 

Cooler 

HVLC Foul Gas Collection System 

Cooler 

ES G09029 

or 

ES G09028 

No. 5 Lime Kiln (primary) 

(via closed-vent Collection System) 

or 

No. 4 Lime Kiln (backup) 

(via closed-vent Collection System) 

G02004 Digester Area: 

ES 02-PU-001 thru 

ES 02-PU-0018 

18 batch digesters 

ES 02-PU-005 No. 1 Hardwood Blow Tank 

ES 02-PU-006 No. 1 Hwd Fiberline Accumulator 

ES 02-PU-008 No. 1 Hwd Secondary Condenser 

ES 02-PU-003 No. 2 Pine Blow Tank 

ES 02-PU-007 No. 2 Pine Fiberline Accumulator 

ES 02-PU-009 No. 2 Pine Secondary Condenser 

ES G09029 

or 

ES G09028 

No. 5 Lime Kiln (primary) 

(via closed-vent Collection System) 

or 

No. 4 Lime Kiln (backup) 

(via closed-vent Collection System) 

G20060 No. 1 Hardwood Turpentine 

System: 

ES 20-PU-001 Turpentine Entrainment System 

ES 20-PU-002 Turpentine Condenser 

ES 20-TK-003 Turpentine Decanter 

ES 20-TK-004 Turpentine Underflow Tank 

ES 20-TK-005 Turpentine Transfer Tank 

ES G09029 

or 

ES G09028 

No. 5 Lime Kiln (primary) 

(via closed-vent Collection System) 

or 

No. 4 Lime Kiln (backup) 

(via closed-vent Collection System) 

G20061 No. 2 Pine Turpentine System: 

ES 20-PU-006 Turpentine Entrainment System 

ES 20-PU-007 Turpentine Condenser 

ES 20-TK-008 Turpentine Decanter 

ES 20-TK-009 Turpentine Underflow Tank 

ES 20-TK-010 Turpentine Transfer Tank 

ES G09029 

or 

ES G09028 

No. 5 Lime Kiln (primary) 

(via closed-vent Collection System) 

or 

No. 4 Lime Kiln (backup) 

(via closed-vent Collection System) 

G07016 Evaporator Area: 

ES 07-PU-002 Swenson Evaporators 

ES 07-TK-006 Swenson Evaporator Hotwell 

ES 07-PU-003 West GB Evaporators 

ES 07-TK-006 West GB Evaporator Hotwell 

ES G09029 

or 

ES G09028 

No. 5 Lime Kiln (primary) 

(via closed-vent Collection System) 

or 

No. 4 Lime Kiln (backup) 

(via closed-vent Collection System) 

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C. 40 CFR 63, Subpart S Affected Sources, continued:

Source ID No. Source Description Control ID No Control Description 

HVLC System Sources

G03005 No. 1 Hardwood Fiberline 

Brownstock Washing: 

ES 03-PU-001 Washers / Filtrate Tanks 

ES 03-TK-003 Foam Tank No. 1 

ES 03-TK-004 Foam Tank No. 2 

NA NA 

G03006 No. 2 Pine Fiberline Brownstock 

Washing: 

ES 03-PU-032 Washers / Filtrate Tanks (enclosed 

sources) 

ES 03-TL-015 Pre-O2 Feed Tank No. 1 

ES 03-TL-016 Pre-O2 Feed Tank No. 2 

ES 03-TL-017 Pre-O2 Feed Tank No. 3 

NA NA 

G04009 No. 1 Hardwood Fiberline Oxygen 

Delignification: 

ES 04-PU-001 Oxygen Reactor (enclosed source) 

ES 04-TK-005 O2 Blow Tank 

ES 04-PU-002 Post O2 Washer 

ES 04-TK-008 Primary Screen Feed 

ES 04-PU-009 East Decker 

ES 04-PU-004 West Decker 

ES 04-TK-007 Decker Filtrate Tank 

NA NA 

G04010 No. 2 Pine Fiberline Oxygen 

Delignification:

ES 04-PU-014 Oxygen Reactor (enclosed source) 

ES 04-TK-018 O2 Blow Tank 

ES 04-PU-016 Post O2 Washer 

ES 04-PU-015 Decker 

ES 04-TK-017 Decker Filtrate Tank 

NA NA 

G04025 No. 1 Hardwood Fiberline Pulp 

Screening System 

NA NA 

G04026 No. 2 Pine Fiberline Pulp 

Screening System

NA NA 

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C. 40 CFR 63, Subpart S Affected Sources, continued:

The following table provides a summary of limits and standards for the emission source(s) describe above:

Regulated Pollutant Limits/Standards Applicable Regulation

Hazardous Air 

Pollutants 

Bleaching System

10 ppmv total chlorinated HAP 

LVHC System

Route system vents to No. 4 Lime Kiln or No. 5 Lime Kiln 

HVLC System

Route non-exempt system vents to control device complying 

with the requirements of the MACT (See Permit Condition 

2.2 C.1.d) 

No control is required for HAP emissions from brownstock 

washing and oxygen delignification systems under an alternate 

compliance approach using the equivalency by permit option 

authorized under 40 CFR §63.94. (See Permit Condition 2.2 

C.2.) 

Pulping Condensate Collection

Collect a minimum 11.1 pounds HAP per ODTP followed 

by treatment in the Condensate Steam Stripper, meeting: 

92 percent HAP removal, or 10.2 pounds HAP per ODTP 

removal 

15 A NCAC 2D .1111 

(40 CFR 63 Subpart S) 

1. 15A NCAC 2D .1111: MACT 40 CFR 63 SUBPART S 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 

15A NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as promulgated in 40 CFR Part 

63 Subpart S, including Subpart A “General Provisions.” Terms used throughout this section are defined in 

the Clean Air Act as amended in 1990 and in 40 CFR 63.2 and 63.441. Units and abbreviations are defined 

in 40 CFR 63.3 [15A NCAC 2D .1111] 

Emission Limitations [15A NCAC 2D .1111] 

Standards for the Bleaching Systems (40 CFR 63.445) 

b. The Permittee shall meet the following control requirements for bleaching systems using chlorinated 

compounds [40 CFR 63, Subpart 63.445]: 

i. The equipment at each bleaching stage of the bleaching systems, where chlorinated compounds are 

introduced shall be enclosed and vented into a closed vent system meeting the requirements specified in 

40 CFR 63.450 and introduced into the respective Bleach Plant Scrubbers (ID Nos. 05-CD-002-01 and 

05-CD-017-01); 

ii. The scrubbers (ID Nos. 05-CD-002-01 and 05-CD-017-01) shall achieve a treatment device outlet 

concentration of 10 ppmv or less of total chlorinated HAP; and 

iii. The Permittee shall not use hypochlorite or chlorine for bleaching in the bleaching systems listed above. 

Standards for the LVHC and HVLC pulping systems at kraft processes (40 CFR 63.443(a)). 

c. The Permittee shall meet the following control requirements for the total HAP emissions from the LVHC 

system [40 CFR 63, Subpart 63.443]: 

i. Each LVHC system component shall be enclosed and vented into a closed vent system meeting the 

requirements of 40 CFR 63.450, and routed to: 

A. The Lime Kilns (ID Nos. ES G09028 and G09029) by introducing the HAP emission stream with 

the primary fuel or into the flame zone. 

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d. Except as specified in Specific Condition 2.2.C.2, the Permittee shall meet the following control requirements 

for the HAP emissions from the HVLC system [40 CFR 63, Subpart 63.443] 

i. Unless otherwise exempt per Specific Condition 2.2.C.2 or 40 CFR 63.443, each HVLC system 

component shall be enclosed and vented into a closed vent system meeting the requirements of 40 CFR 

63.450, and routed to a control device meeting the requirements of the MACT. 

A. Pursuant to 40 CFR 63.443(a)(1)(ii)(C), each knotter and screen system with total emissions of less 

than 0.3 pounds of total HAP per ton of ODTP are exempt from the HVLC control requirements of 

Subpart S. Based on the June 2004 exemption analysis, the following sources are exempt: 

(1). ES-04-TK-008, G04025, and G04026. 

B. Pursuant to 40 CFR 63.443(a)(1)(iv)(B), each decker system that does not use any process water 

with a total HAP concentration greater than 400 parts per million by weight are exempt from the 

HVLC control requirements of Subpart S. Based on the June 2004 exemption analysis, the 

following sources are exempt: 

(1). ES-04-PU-009, ES-04-PU-004, ES-04-TK-007, ES-04-PU-015, and ES-04-TK-017. 

e. Periods of excess emissions reported under Sec. 63.455 shall not be a violation of Sec. 63.443 (c) and (d) 

provided that the time of excess emissions (excluding periods of startup, shutdown, or malfunction) divided 

by the total process operating time in a semi-annual reporting period does not exceed the following levels: 

i. One percent for the LVHC System. 

Standards for kraft pulping process condensates (40 CFR 63.446). 

f. The pulping process condensates as identified per 40 CFR 63.446(b) shall be conveyed in a closed collection 

system that is designed and operated to meet the following requirements 

i. Each closed collection system shall meet the individual drain system requirements specified in 40 CFR 

63.960, 63.961, and 63.962, except for closed vent systems; 

ii. Closed vent systems shall be designed and operated in accordance with 40 CFR 63.450; 

iii. The process condensate streams collected in total shall contain a minimum of 11.1 pounds HAP per ton 

of oven dried pulp produced (based on a 30-day rolling average); 

iv. The Stripper Feed Tank (ID Nos. ES 07-TK-011) shall meet the requirements of 40 CFR 63.446(d)(2); 

and 

v. The pulping process condensates collected shall be treated by the Foul Condensate Steam Stripper (ID 

No. ES 07-PU-015) which shall: 

A. Reduce or destroy the total HAPs by at least 92 percent or more by weight; or 

B. Remove a minimum of 10.2 pounds HAP per ton of oven dried pulp (ODTP). 

vi. For the foul condensate steam stripper system used to comply with the requirements specified in 

paragraph 63.446(e)(3) or (5), periods of excess emissions reported under Sec. 63.455 shall not be a 

violation of paragraphs 63.446(d), (e), and (f) provided that the time of excess emissions (including 

periods of startup, shutdown, or malfunction) divided by the total process operating time in a semiannual reporting period does not exceed 10 percent. 

g. Testing [15A NCAC 2D .0501(c)] 

If emissions testing is required, the testing shall be performed in accordance General Condition JJ found in 

Section 3. If the results of this test are above the limits given in Section 2.2 C.1 b. through e. above, the 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

Monitoring for the Bleaching System Scrubbers [15A NCAC 2Q .0508(f)] 

h. The Permittee shall install, calibrate, certify, operate, and maintain according to the manufacturer's 

specifications, a continuous monitoring system (CMS), on the No. 1 Bleach Plant Wet Scrubber (ID No. 05-

CD-002-01). The CMS shall include a continuous recorder. The CMS shall be operated to ensure the 

following operational parameters are maintained [40 CFR 60, Subpart 63.453]: 

i. The minimum pH of the scrubber's effluent shall be 9.23 (averaged over three hours); 

ii. The scrubber's inlet vent gas fan operating status of “on” (on or off based on motor load); and 

iii. The minimum scrubber liquid recirculation rate for the respective scrubber shall be 85.8 gallons per 

minute. 

If any monitoring parameter values are exceeded or if the monitoring procedures are not followed, the 

Permittee shall be deemed in noncompliance with 2D .1111. 

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The Permittee shall install, calibrate, certify, operate, and maintain according to the manufacturer's 

specifications, a continuous monitoring system (CMS), on the No. 2 Bleach Plant Wet Scrubber (ID No. 05-

CD-017-01). The CMS shall include a continuous recorder. The CMS shall be operated to ensure the 

following operational parameters are maintained [40 CFR 60, Subpart 63.453]: 

iv. The minimum pH of each scrubber's effluent shall be 8.38 (averaged over three hours); 

v. The scrubber's inlet vent gas fan operating status of “on” (on or off based on motor load) ; and 

vi. The minimum scrubber liquid recirculation rate for the respective scrubber shall be 27.57 gallons per 

minute. 

If any monitoring parameter values are exceeded or if the monitoring procedures are not followed, the 

Permittee shall be deemed in noncompliance with 2D .1111. 

Monitoring for the LVHC pulping systems Control Devices [15A NCAC 2D .1111] 

i. No control device parameter monitoring is required for pulping vent systems routed to the No. 4 Lime Kiln 

(ID No. ES G09028) or the No. 5 Lime Kiln (ID No. ES G09029). [40 CFR 60, Subpart 63.453] 

Monitoring for the pulping process Condensate Collection:[15A NCAC 2D .1111] 

j. The Permittee shall install, calibrate, certify, operate, and maintain according to the manufacturer's 

specifications, a continuous monitoring system (CMS) to monitor condensate collection. The CMS shall 

include a continuous recorder. The CMS shall be operated to ensure the following operational parameters are 

maintained on a 15-day rolling average of stripper operating days. [40 CFR 60, Subpart 63.453]: 

i. Foul condensates collected in the Stripper Feed Tank shall be equal to or greater than 379 gallons per minute; 

and 

ii. Foul condensates from the Black Liquor Oxidizer gas collection system shall be collected and sent to the 

Stripper Feed Tank. 

If any monitoring parameter values are exceeded or if the monitoring procedures are not followed, the 

Permittee shall be deemed in noncompliance with 2D .1111. 

Monitoring for the pulping process condensates Steam Stripper (ID No ES 07-PU-015) [15A NCAC 2D 

.1111]:

k. The Permittee shall install, calibrate, certify, operate, and maintain according to the manufacturer's 

specifications, a continuous monitoring system (CMS) on the Condensate Stripper (ID No ES 07-PU-015). 

The CMS shall include a continuous recorder. The CMS shall be operated to ensure the following 

operational parameters are maintained on a 15-day rolling average of stripper operating days. [40 CFR 60, 

Subpart 63.453]: 

i. Foul condensates feed from the Stripper Feed Tank shall be equal to or greater than 379 gallons per 

minute; 

ii. The temperature of the foul condensates feed shall be equal to or greater than 161Deg. F; and 

iii. Steam feed to the Foul Condensate Stripper shall be equal to or greater than 38,021 lb/hour. 

If any monitoring parameter values are exceeded or if the monitoring procedures are not followed, the 

Permittee shall be deemed in noncompliance with 2D .1111. 

Monitoring for Enclosures and Closed Vent Systems [15A NCAC 2D .1111] 

l. Each enclosure and closed vent system shall meet the monitoring requirements of 40 CFR 63.453. The 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if the monitoring is not performed. 

Recordkeeping/Reporting [15A NCAC 2D .1111] 

m. The results or the CMS monitoring, Enclosure System monitoring, and Closed-Vent System monitoring shall 

be maintained (in written or electronic format) per the requirements of 40 CFR 63.454 and 63.455. The 

Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these records are not maintained. 

n. When actions taken during a startup, shutdown, or malfunction (including an action taken to correct a 

malfunction) are not consistent with the procedures specified in the facility's Startup Shutdown Malfunction 

(SSM) Plan, the Permittee shall record the actions taken for that event for inclusion in the semiannual SSM 

report. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these records are not 

maintained. 

o. When actions taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to 

correct a malfunction) are consistent with the procedures specified in the facility's SSM plan, the Permittee 

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shall keep records for that event that demonstrate that the procedures specified in the SSM plan were 

followed. The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 if these records are 

not maintained. 

Reporting [15A NCAC 2D .1111] 

p. Permittee shall submit a summary report of excess emissions postmarked on or before January 30 of each 

calendar year for the preceding six-month period between July and December and July 30 of each calendar 

year for the preceding six-month period between January and June. All instances of deviations from the 

requirements of this permit must be clearly identified. When no exceedances of an operating parameter have 

occurred, such information shall be included in the report. 

q. The Permittee shall comply with the reporting requirements of 40 CFR 63, Subpart A as specified in Table 1 

of 40 CFR 63.440. 

2. 15A NCAC 2D .1111: MACT 40 CFR 63 SUBPART S via 40 CFR 63.94 Equivalency by Permit – HVLC 

System Sources 

The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A 

NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as promulgated in 40 CFR Part 63 

Subpart S, including Subpart A “General Provisions” as defined per 63.440(g) and indicated per Table 1 of 

Subpart S. As outlined in Table 1, per 40 CFR 63.6(f)(1), these emission standards shall apply at all times except 

during periods of startup, shutdown, and malfunction and as otherwise specified in 40 CFR Part 63, Subpart S. 

Terms used throughout this section are defined in the Clean Air Act as amended in 1990 and in 40 CFR 63.2 and 

63.441. Units and abbreviations are defined in 40 CFR 63.3 [15A NCAC 2D .1111]. 

The authority for the alternate control requirements for Equivalency by Permit (EBP) is given in 40 CFR parts 

63.91 63.94, and 63.99 as promulgated in “Approval of Section 112(l) Authority for Hazardous Air Pollutants; 

Equivalency by Permit Provisions; National Emission Standards for Hazardous Air Pollutants from the Pulp and 

Paper Industry; State of North Carolina”, Federal Register, Vol. 69, No. 70/Monday, April 12, 2004 pp 19106-

19109. Section 63.99 “Delegated Federal Authorities” of Subpart E “Approval of State Programs and Delegation 

of Federal Authorities” was also amended at FR Vol. 69, No. 70/Monday, April 12, 2004 p 19110 to add 

63.99(a)(33)(ii) North Carolina. 

Standards for the affected HVLC pulping system processes [40 CFR Part 63.443 and 63.94] 

a. No later than April 16, 2007, in lieu of controlling the 40 CFR 63, Subpart S-affected HAP emissions from: 

The Brownstock Washing Areas (G03005 and G03006) Sources: 

Vacuum Drum Brown Stock Washers (ID No. ES-03-PU-001); 

Foam Tank No.1 (ID No. ES-03-TK-003); 

Foam Tank No. 2 (ID No. ES-03-TK-004); 

Pre-O2 Washer Feed Tank No. 1 (ID No. ES-03-TL-015); 

Pre-O2 Washer Feed Tank No. 2 (ID No. ES-03-TL-016); 

Pre-O2 Washer Feed Tank No. 3 (ID No. ES-03-TL-017); and 

The Oxygen Delignification Systems (G04009 and G04010) Sources: 

HW O2 Blow Tank (ID No. ES-04-TK-005); 

HW Post O2 Washer (ID No. ES-04-PU-002); and 

HW Post O2 Filtrate Chest (ID No. ES-04-TK-008); 

Pine O2 Blow Tank (ID No. ES-04-TK-018); and 

Pine Post O2 Washer (ID No. ES-04-PU-016). 

The Permittee shall control HAP emissions from the Black Liquor Oxidation (BLOX) System (G08022) 

sources as required below. 

Standards for the BLOX system [40 CFR Part 63.443 and 63.94] 

b. No later than April 16, 2007, the Permittee shall meet the following control requirements for the total HAP 

emissions from the BLOX System (G08022) sources [40 CFR 63.94, Subpart 63.443]: 

i. Each BLOX system component shall be enclosed and vented into a closed vent system meeting the 

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requirements of 40 CFR 63.450 and controlled per the following requirements: 

A. Reduce total HAP emissions by 98 percent or more by weight; or 

B. Reduce total HAP emissions using a thermal oxidizer designed and operated at a minimum 

temperature of 871°C (1600°F) and a minimum residence time of 0.75 seconds. 

c. Periods of excess emissions reported under Sec. 63.455 shall not be a violation of the above requirements 

provided that the time of excess emissions (excluding periods of startup, shutdown, or malfunction) divided 

by the total process operating time in a semi-annual reporting period does not exceed the following levels: 

i Four percent for control devices used to reduce the total HAP emissions from the BLOX system. 

When excess emissions exceed the level set forth in Section 2.2 C.2.c.i, the facility shall be deemed in noncompliance with 15A NCAC 2D .1111 via 40 CFR 63.94. 

d. The Black Liquor Oxidation (BLOX) System thermal oxidizer is permitted to burn only BLOX gases and 

natural gas as an auxiliary fuel. 

e. The Permittee must operate and maintain the emission source(s) in accordance with the procedures specified 

in the facility's start-up, shut-down, and malfunction (SSM) plan. At all times, including periods of startup, 

shutdown, and malfunction, the Permittee shall operate and maintain the emission source(s), including 

associated air pollution control equipment, in a manner consistent with good air pollution control practices for 

minimizing emissions at least to the levels required by all relevant standards. Malfunctions shall be corrected 

as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan. 

Testing [15A NCAC 2D .0501(c), 40 CFR 63.94, 40 CFR 63.457] 

f. If emissions testing is required, the testing shall be performed in accordance General Condition JJ found in 

Section 3. If the results of this or any testing are above the limits contained herein, the Permittee shall be 

deemed in noncompliance with 15A NCAC 2D .1111 via 40 CFR 63.94. 

i. Pursuant to 40 CFR 63.457(a), an initial performance test is not required to show compliance with the 

HAP destruction efficiency if the Permittee selects the compliance method per paragraph 2.2 C.2.b.i.B. 

Otherwise, a performance test shall be conducted no later than April 16, 2007 and in accordance with 

General Condition JJ found in Section 3 of this permit and with the requirements of 40 CFR 63.457. 

ii. If emission testing is required for parity demonstration, the testing shall be done in accordance with 

General Condition JJ found in Section 3 of this permit, and the test methods and procedures contained in 

40 CFR 63.457. The testing will consist of (1) determining the emissions from the sources that were 

subject to 40 CFR 63 Subpart S as identified in 2.2 C.2.a. but are not controlled under the EBP option 

and (2) the uncontrolled emissions from the BLOX system. If the emissions from (1) above exceed the 

emissions from (2) above then the facility shall be deemed in non-compliance with 15A NCAC 2D .1111 

via 40 CFR 63.94. 

Production Monitoring for Parity with 40 CFR 63, Subpart S [40 CFR 63.94] 

g. To assure continuing parity, the hardwood pulp production shall not exceed 83 percent of the total pulp 

production on a 12-month rolling average basis. The Permittee shall keep records of the monthly hardwood 

pulp production and the monthly total pulp production. 

i. The initial 12-month rolling average shall cover the period May 2007 through April 2008. 

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111 via 40 CFR 63.94 if the 

monitoring is not performed, or if the 12 month rolling average hardwood pulp production exceeds 83 percent 

of the total pulp production. 

Monitoring for BLOX System Control Device [40 CFR 63.453(a),(b),(n),(o), 40 CFR 63.94] 

h. The Permittee shall install, calibrate, operate, and maintain according to the manufacturer’s specifications, a 

continuous monitoring system (CMS) to measure the temperature in the thermal oxidizer firebox or in the 

ductwork immediately downstream of the firebox and before any substantial heat exchange occurs. The CMS 

shall include a continuous recorder. The CMS shall be operated to ensure the following operational 

parameters are maintained [40 CFR 63, Subpart 63.453 and 40 CFR 63.94]: 

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i. If, prior to April 16, 2007, the Permittee elects to comply with paragraph 2.2 C.2.b.i.A , the minimum 

operating temperature established during testing conducted per 2.2 C.2.f. shall be recorded and 

maintained. This permit shall be administratively amended prior to April 16, 2007 to incorporate the 

minimum temperature determined during the initial performance testing. 

If, after April 16, 2007, the Permittee elects to comply with paragraph 2.2 C.2.b.i.A, the minimum 

operating temperature shall be established during testing conducted per 2.2 C.2.f. This permit shall be 

administratively amended to incorporate the new minimum operating temperature determined during this 

performance testing prior to using the operating temperature as a measurement of compliance. 

An alternate minimum operating temperature may be established per additional approved testing 

performed per 2.2 C.2.f. This permit shall be administratively amended to incorporate the new minimum 

operating temperature determined during this additional performance testing prior to using the new 

operating temperature as a measurement of compliance. 

ii. If the Permittee elects to comply with paragraph 2.2 C.2.b.i.B , then a minimum operating temperature of 

871°C (1600°F) shall be recorded and maintained. 

Operation of the black liquor oxidation system control device (ID. No. CD-BLOXRTO) below established 

minimum operating temperatures (as set forth in Section 2.2 C.2.h.i or ii, as appropriate), or failure to perform 

the required monitoring shall be reported as a period of excess emissions. 

Standards for Enclosures and Closed Vent Systems [40 CFR 63.450, 40 CFR 63.94] 

i. The Black Liquor Oxidation System enclosure and closed vent system shall meet the requirements of 40 CFR 

63.450. 

Monitoring for Enclosures and Closed Vent Systems [40 CFR 63.453, 40 CFR 63.94] 

j. The Black Liquor Oxidation System enclosure and closed vent system shall meet the monitoring 

requirements of 40 CFR 63.453. The Permittee shall be deemed in noncompliance with 15A NCAC 2D 

.1111 via 40 CFR 63.94 if the monitoring is not performed. 

Recordkeeping/Reporting [40 CFR 63.454; 63.455, 40 CFR 63.94] 

k. The results of the CMS monitoring, Enclosure System monitoring, and Closed-Vent System monitoring shall 

be maintained (in written or electronic format) per the requirements of 40 CFR 63.454 and 63.455. 

l. The results of the monthly hardwood and total pulp production monitoring required by condition 2.2 C.2.g 

shall be maintained in written or electronic format. 

m. When actions taken during a startup, shutdown, or malfunction (including an action taken to correct a 

malfunction) are not consistent with the procedures specified in the facility's Startup Shutdown Malfunction 

(SSM) Plan, the Permittee shall record the actions taken for that event for inclusion in the semiannual SSM 

report. 

n. When actions taken by the Permittee during a startup, shutdown, or malfunction (including actions taken to 

correct a malfunction) are consistent with the procedures specified in the facility's SSM plan, the Permittee 

shall keep records for that event that demonstrate that the procedures specified in the SSM plan were 

followed. 

Reporting [40 CFR 63.454; 63.455, 40 CFR 63.94] 

o. Beginning with the semi-annual period that ends June 30, 2007, the Permittee shall submit a summary report 

of excess emissions postmarked on or before January 30 of each calendar year for the preceding six-month 

period between July and December and July 30 of each calendar year for the preceding six-month period 

between January and June. All instances of deviations from the requirements of this permit must be clearly 

identified. When no exceedances of an operating parameter have occurred, such information shall be included 

in the report. This report shall also include the 12-month rolling average percent hardwood pulp production 

for each month in the reporting period, or the average percent hardwood pulp production since April 16, 2007 

if 12 months of data are not yet available. 

p. The Permittee shall comply with the reporting requirements of 40 CFR 63, Subpart A as specified in Table 1 

of 40 CFR 63.440. 

q. As required in 63.455(b), the Permittee shall submit, with the initial notification report and update every two 

years thereafter, a non-binding control strategy report containing, at a minimum, the information specified in 

63.455(b)(1)-(3) in addition to the information required in 63.9(b)(2) of 40 CFR 63 Subpart A. 

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D. 40 CFR 63, Subpart MM Affected Sources:

Source ID No. Source Description Control ID No Control Description

ES G08020 No. 10 Recovery Furnace 08-CD-001-01 Wet Bottom electrostatic precipitator 

ES G08021 No. 10 Smelt Dissolving Tank 08-CD-011-01 Chevron Mist Eliminator 

ES G08023 No. 11 Recovery Furnace 08-CD-002-01 Wet Bottom electrostatic precipitator 

ES G08024 No. 11 Smelt Dissolving Tank 08-CD-012-01 Chevron Mist Eliminator 

ES G09028 No. 4 Lime Kiln 08-CD-009-01 Flooded Disk-type wet scrubber 

ES G09029 No. 5 Lime Kiln 09-CD-010-01 MicroMist venturi scrubber 

The following table provides a summary of limits and standards for the emission source(s) described above:

Regulated 

Pollutant 

Limits/Standards Applicable Regulation 

Hazardous 

Air 

Pollutants 

No. 4 Lime Kiln

PM emissions shall be no greater than 0.10 gr/dscf, corrected to 

10% oxygen. 

No. 5 Lime Kiln

PM emissions shall be no greater than 0.10 gr/dscf, corrected to 

10% oxygen. 

No. 10 Recovery Furnace

PM emissions shall be no greater than 0.032 gr/dscf, corrected to 

8% oxygen. 

No. 11 Recovery Furnace

PM emissions shall be no greater than 0.032 gr/dscf, corrected to 

8% oxygen. 

No. 10 Smelt Dissolving Tank

PM emissions shall be no greater than 0.268 gr/dscf. 

No. 11 Smelt Dissolving Tank

PM emissions shall be no greater than 0.239 gr/dscf. 

Overall Chemical Recovery System PM Limit

Total PM emissions from the Nos. 4 and 5 Lime Kilns, Nos. 10 

and 11 Recovery Furnaces, and Nos. 10 and 11 Smelt Dissolving 

Tanks shall be no greater than 1.49 lb/TBLS. 

15A NCAC 2D .1111 

(40 CFR 63, Subpart MM) 

1. 15A NCAC 2D .1111: MACT 40 CFR 63 SUBPART MM 

a. The Permittee shall comply with all applicable provisions, including the notification, testing, reporting, 

recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 

15A NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as promulgated in 40 CFR Part 

63 Subpart MM, including Subpart A “General Provisions” as defined per 63.440(g) and indicated per 

Table 1 of Subpart MM. As outlined in Table 1, per 40 CFR 63.6(f)(1), these emission standards shall apply 

at all times except during periods of startup, shutdown, and malfunction and as otherwise specified in 40 CFR 

Part 63, Subpart MM. Terms used throughout this section are defined in the Clean Air Act as amended in 

1990 and in 40 CFR 63.2 and 63.861. Units and abbreviations are defined in 40 CFR 63.3. [15A NCAC 2D 

.1111] 

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Emission Limitations [15A NCAC 2D .1111] 

b. Emissions of PM from the Nos. 4 and 5 Lime Kilns, Nos. 10 and 11 Recovery Furnaces, and Nos. 10 and 11 

Smelt Dissolving Tanks shall not exceed the limits presented in the Table 2.2 D-1 below: [63.865(a)] 

Table 2.2. D-1 

Varaible Description Units Value Basis 

ELPM Bubble Limit for MACT MM lb/ton BLS 1.490 (Eqn 1 in MACT MM) 

No. 10 Recovery Furnace No 10 (RF10) 

ERRF emission limit for RF10 lb/ton BLS 0.827 (Eqn 2 in MACT MM) 

F1 conversion factor Min-lb/day-gr 0.206 set value 

CEL, RF emission limit for RF10 gr/dscf 0.032 mill-specific 

QRF measured stack flowrate from RF10 dscfm 176,354 mill-specific 

BLSRF measured BLS firing rate of RF10 ton BLS/d 1,405 mill-specific 

No. 11 Recovery Furnace (RF11) 

ERRF emission limit for RF11 lb/ton BLS 0.785 (Eqn 2 in MACT MM) 

CEL, RF emission limit for RF11 gr/dscf 0.032 mill-specific 

QRF measured stack flowrate from RF11 dscfm 163,503 mill-specific 

BLSRF measured BLS firing rate of RF11 ton BLS/d 1,373 mill-specific 

 

PRRFtot total BLS firing rates, all RF's ton BLS/d 2,778 (BLSRF1) +...+ (BLSRFi) 

ERRFtot calculated emission rate, all RF's lb/ton BLS 0.807 (Eqn 5 in MACT MM) 

 

No. 10 Smelt Dissolving Tank (SDT-10) 

ERSDT emission limit for SDT-10 lb/ton BLS 0.400 (Eqn 3 in MACT MM) 

CEL, SDT emission limit for SDT-10 gr/dscf 0.268 mill-specific 

QSDT measured stack flowrate from SDT-10 dscfm 10,183 mill-specific 

BLSSDT measured BLS firing rate of RF10*100% ton BLS/d 1,405 mill-specific 

No. 11 Smelt Dissolving Tank (SDT-11) 

ERSDT emission limit for SDT-11 lb/ton BLS 0.399 (Eqn 3 in MACT MM) 

CEL, SDT emission limit for SDT-11 gr/dscf 0.239 mill-specific 

QSDT measured stack flowrate from SDT-11 dscfm 11,115 mill-specific 

BLSSDT measured BLS firing rate of RF11*100% ton BLS/d 1,373 mill-specific 

 

PRSDTtot total BLS firing rates, all RF's ton BLS/d 2,778 same as PRRFtot

ERSDTtot calculated emission rate, all SDT's lb/ton BLS 0.399 (Eqn 5 in MACT MM) 

 

No. 4 Lime Kiln (LK-4) 

ERLK emission limit for LK-4 lb/ton BLS 0.295 (Eqn 4 in MACT MM) 

CEL, LK emission limit for LK-4 gr/dscf 0.100 mill-specific 

QLK measured stack flowrate from LK-4 dscfm 13,557 mill-specific 

CaOLK measured lime production from LK-4 ton CaO/d 89 mill-specific 

BLStot total BLS firing rates, all RF's ton BLS/d 2,778 

No. 5 Lime Kiln (LK-5) 

ERLK emission limit for LK-5 lb/ton BLS 0.277 (Eqn 4 in MACT MM) 

CEL, LK emission limit for LK-5 gr/dscf 0.100 mill-specific 

QLK measured stack flowrate from LK-5 dscfm 24,681 mill-specific 

CaOLK measured lime production from LK-5 ton CaO/d 173 mill-specific 

 

PRLKtot 

(CaOtot) total lime production, all LK's ton CaO/d 262 (CaOLK1) + ...+ (CaOLKi) 

ERLKtot calculated emission rate, all LK's lb/ton BLS 0.284 (Eqn 5 in MACT MM) 

 

ERtot Total emission rate, all sources lb/ton BLS 1.489 (Eqn 6 in MACT MM) 

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c. The chemical recovery system emission limits must be re-established if either (1) the air pollution control 

system for the No. 4 or 5 Lime Kiln, No. 10 or 11 Recovery Furnace, or No. 10 or 11 Smelt Dissolving Tank 

is modified (as defined in 63.861) or replaced, or (2) the No. 4 or 5 Lime Kiln, No. 10 or 11 Recovery 

Furnace, or No. 10 or 11 Smelt Dissolving Tank is shut down for more than 60 consecutive days. 

[63.862(a)(1)(ii)(D)] 

Testing [15A NCAC 2D .1111] 

d. If emissions testing is required to re-establish the chemical recovery system emission limits, emissions testing 

shall be performed according to the procedures in 63.7, 63.865, and General Condition JJ. If the results of 

the testing indicate that the chemical recovery system emission rate is greater than the emission limits 

presented in the table above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .1111. 

[63.865] 

Monitoring [15A NCAC 2D .1111] 

e. The Permittee must install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS) 

at the outlet of No. 10 Recovery Furnace ESP (08-CD-001-01) and No. 11 Recovery Furnace ESP (08-CD-002-

01) that can be used to determine opacity at least once every successive 10-second period and calculate and 

record each successive 6-minute average opacity using the procedures in 63.6(h) and 63.8. The COMS data 

must be reduced as specified in 63.8(g)(2). If these monitoring procedures are not followed, the Permittee 

shall be deemed in noncompliance with 15A NCAC 2D .1111. [63.864(d)(10)] 

f. The Permittee must install, calibrate, maintain, and operate a continuous monitoring system that can be used 

to determine and record the pressure drop and the scrubbing liquid flow rate on the No. 4 Lime Kiln Scrubber 

(08-CD-009-01), No. 5 Lime Kiln Scrubber (09-CD-010-01), No. 10 Smelt Dissolving Tank Scrubber (08-CD011-01), and No. 11 Smelt Dissolving Tank Scrubber (08-CD-012-01). Pressure drop and scrubbing liquid 

flow rate must be monitored at least once every successive 15-minute period using the procedures in 63.8(c), 

as well as the following procedures [63.864(e)(10) and (13)]: 

i. The monitoring device used for the continuous measurement of the pressure drop of the gas stream 

across the scrubber must be certified by the manufacturer to the accurate to within a gauge pressure of 

±500 pascals (±2 inches of water gauge pressure); and 

ii. The monitoring device used for continuous measurement of the scrubbing liquid flow rate must be 

certified by the manufacturer to be accurate within ±5 percent of the design scrubbing liquid flow rate. 

If these monitoring procedures are not followed, the Permittee shall be deemed in noncompliance with 15A 

NCAC 2D .1111. 

g. The Permittee may base operating ranges on values recorded during the initial performance tests or conduct 

additional performance tests for the specific purpose of establishing operating ranges, provided that test data 

used to establish the operating ranges are or have been obtained using the test methods required in Subpart 

MM. The Permittee must certify that all control devices and processes have not been modified subsequent to 

the testing upon which the data used to establish the operating parameter ranges were obtained. The 

Permittee may establish expanded or replacement operating ranges during subsequent performance tests using 

the test methods in 63.865. The Permittee must continuously monitor each parameter and determine the 

arithmetic average value of each parameter during each performance test. Multiple performance tests may be 

conducted to establish a range of parameter values. [63.864(j)] 

h. The Permittee is required to implement corrective action, as specified in the startup, shutdown, and 

malfunction plan prepared under 63.866(a), if the following monitoring exceedances occur [63.864(k)(1)]: 

i. For Nos. 10 and 11 Recovery Furnaces, when the average of ten consecutive 6-minute averages results in 

a measurement greater than 20 percent opacity; 

ii. For Nos. 4 and 5 Lime Kiln and Nos. 10 and 11 Smelt Dissolving Tanks, when any 3-hour average wet 

scrubber parameter value is outside the range of values established during performance testing as 

indicated in the table above. 

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i. The Permittee is in violation of 63.862 if the following monitoring exceedances occur [63.864(k)(2)]: 

i. For Nos. 10 and 11 Recovery Furnaces, when opacity is greater than 35 percent for 6 percent or more of 

the operating time within any quarterly period; 

ii. For Nos. 4 and 5 Lime Kilns and Nos. 10 and 11 Smelt Dissolving Tanks, when six or more 3-hour 

average parameter values within any 6-month reporting period are outside the range of values established 

during performance testing as indicated in Table 2.2 D-2 below: 

Table 2.2 D-2 

Source 

Decription 

Parameter Values 

No. 4 Lime Kiln 1. Scrubber recirculation liquid flow [FT1958] shall be no less than 289 gpm (3-hour average), 

and 

2. Scrubber differential pressure [PT0018] shall be no less than 20 in. H2O (3-hour average). 

No. 5 Lime Kiln 1. Scrubber venturi liquid flow [FT3173] shall be no less than 224 gpm (3-hour average), 

2. Scrubber quench liquid flow [FT3172] shall be no less than 152 gpm (3-hour average), and 

3. Scrubber differential pressure shall be no less than 19.2 in. H2O (3-hour average).

No. 10 Smelt 

Dissolving Tank 

1. Scrubber liquid flow to spout floor [FT1580] shall be no less than 51 gpm (3-hour average), 

2. Scrubber liquid flow to firing floor [FT1581] shall be no less than 35 gpm (3-hour average), 

and 

3. Scrubber pressure drop [FT1582] shall be no less than 0.22 in H2O.

No. 11 Smelt 

Dissolving Tank 

1. Scrubber liquid flow [FT0201] shall be no less than 85 gpm (3-hour average), and 

2. Scrubber pressure drop [PT1584] shall be no less than 0.04 in H2O.

j. For purposes of determining the number of non-opacity monitoring exceedances, no more than one 

exceedance will be attributed in any given 24-hour period. [63.864(k)(3)] 

Recordkeeping [15A NCAC 2D .1111] 

k. The Permittee must develop and implement a written plan as described in 63.6(e)(3) that contains specific 

procedures to be followed for operating and maintaining the source during periods of startup, shutdown, and 

malfunction, and a program of corrective action for malfunctioning process and control systems used to 

comply with Subpart MM. In addition to the information required in 63.6(e), the plan must include the 

requirements given in 63.866(a)(1) and (2). [63.866(a)] 

l. The Permittee must maintain records of any occurrence when corrective action is required under condition 

2.2.D.1.h, and when a violation is noted under condition 2.2.D.1.i. [63.866(b)] 

m. In addition to the general records required by 63.10(b)(2), the Permittee must maintain records of the 

following information [63.864 (c)]: 

i. Records of black liquor solids firing rates in units of ton/d for Nos. 10 and 11 Recovery Furnaces; 

ii. Records of CaO production rates in units of ton/d for Nos. 4 and 5 Lime Kilns; 

iii. Records of parameter monitoring data required under condition 2.2.D.1.f, including any period when the 

operating parameter levels were inconsistent with the levels established during the initial performance 

test or subsequent testing, with a brief explanation of the cause of the deviation, the time the deviation 

occurred, the time corrective action was initiated and completed, and the corrective action taken; 

iv. Records and documentation of supporting calculations for the chemical recovery system emissions limit; 

v. Records of monitoring parameter ranges established under condition 2.2.D.1.g; and 

vi. Records of the hours of operation for Nos. 4 and 5 Lime Kilns, Nos. 10 and 11 Recovery Furnaces, and 

Nos. 10 and 11 Smelt Dissolving Tanks. 

Reporting [15A NCAC 2D .1111] 

n. After the Director has approved the emissions limits for any process unit, the Permittee must notify the 

Director before any of the following actions are taken [63.867(b)]: 

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i. The air pollution control system for any process unit subject to Subpart MM is modified or replaced; 

ii. The No. 4 or 5 Lime Kiln, No. 10 or 11 Recovery Furnace, or No. 10 or 11 Smelt Dissolving Tank is 

shut down for more than 60 consecutive days; 

iii. A continuous monitoring parameter or the value or range of values of a continuous monitoring parameter 

for any process unit subject to Subpart MM is changed; or 

iv. The black liquor solids firing rate for No. 10 or No. 11 Recovery Furnace during any 24-hour averaging 

period is increased by more than 10 percent above the level measured during the most recent 

performance test. 

o. If the Permittee (1) modifies the air pollution control device for the No. 4 or 5 Lime Kiln, No. 10 or 11 

Recovery Furnace, or No. 10 or 11 Smelt Dissolving Tank or (2) shuts down the No. 4 or 5 Lime Kiln, No. 

10 or 11 Recovery Furnace, or No. 10 or 11 Smelt Dissolving Tank for more than 60 consecutive days, or (3) 

increases the black liquor solids firing rate for the No. 10 or No. 11 Recovery Furnace during any 24-hour 

averaging period by more than 10 percent above the level measured during the most recent performance test, 

the Permittee must recalculate the overall PM emissions limit for the Nos. 4 and 5 Lime Kilns, Nos. 10 and 

11 Recovery Furnaces, and Nos. 10 and 11 Smelt Dissolving Tanks and resubmit the documentation required 

in 63.865 to the Director. All modified PM emissions limits are subject to approval by the Director. 

[63.867(b)] 

p. The Permittee must report quarterly if measured parameters meet any of the conditions specified in condition 

2.2.D.1.i. This report must contain the information specified in 40 CFR 63.10(c) as well as the number and 

duration of occurrences when the source met or exceeded the conditions in condition 2.2.D.1.h, and the 

number and duration of occurrences when the source met or exceeded the conditions in condition 2.2.D.1.i. 

All instances of deviations from the requirements of this permit must be clearly identified in the report. 

Reporting excess emissions below the violation thresholds of conditions 2.2.D.1.h and i does not constitute a 

violation of the applicable standard. [63.867(c)] 

i. When no exceedances of parameters have occurred, the Permittee must submit a semiannual report 

stating that no excess emissions occurred during the reporting period. 

ii. The Permittee may combine excess emissions and/or summary reports for the facility for Subpart MM 

and Subpart S. 

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2.3 STATE ONLY ENFORCEABLE REQUIREMENTS

A. North Carolina Air Toxics 

1. 15A NCAC 2D .1100 Control of Toxic Air Pollutants 

TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING REQUIREMENT - Pursuant to 15A 

NCAC 2D .1100 “Control of Toxic Air Pollutants,” and in accordance with the approved application for the 

Bleached Filtrate Recycle (BFR) Process dated April 24, 2000 for an air toxic compliance demonstration, the 

following permit limits shall not be exceeded: 

Emission Source(s) Toxic Air 

Pollutant(s) 

Emission Limit(s) 

Facility-Wide Limit excluding unadulterated fuel combustion 

sources 

Acetaldehyde 35.75 lb/hour 

Facility-Wide Limit excluding unadulterated fuel combustion 

sources 

Formaldehyde 2.75 lb/hour 

Facility-Wide Limit excluding unadulterated fuel combustion 

sources 

Manganese 3.24 lb/hour 

Facility-Wide Limit excluding unadulterated fuel combustion 

sources 

Phenol 9.15 lb/hour 

2. 15A NCAC 2Q .0705 Existing Facilities and SIC Calls 

a. Air Permit Application Submittal Requirements - In accordance with 15A NCAC 2Q .0705(b), for sources at a 

facility subject to a MACT standard, excluding the MACT for combustion sources, an air permit application shall 

be required demonstrating compliance with 15A NCAC 2D .1100 “Control of Toxic Air Pollutants”: 

i. at the same time the facility submits an air permit application to comply with the last MACT standard 

(excluding the MACT for combustion sources); or 

ii. on or before the last MACT standard (excluding the MACT for combustion sources) compliance deadline 

date. To allow the Division time to process an application before the compliance deadline date you should 

submit an application no later than three month prior to the compliance deadline date if you need a 

construction/operation permit for the installation of a control device(s) to comply with either 2D .1100 or the 

last MACT standard (excluding the MACT for combustion sources). 

b. The permit application demonstrating compliance with 15A NCAC 2D .1100 shall include an evaluation for all 

toxic air pollutants covered under rule 15A NCAC 2D .1104 for all sources at the facility, excluding those sources 

exempt from evaluation under 15A NCAC 2Q .0702. If the facility has already demonstrated facility-wide 

compliance with 2D .1100 the application should include the date of compliance demonstration, air permit 

number, and a list of applicable toxic pollutants. 

c. Compliance Deadline Date Requirement - The facility shall be in compliance with the 15A NCAC 2D .1100 

Toxic Air Pollutants rule by the same deadline date that it is required to be in compliance with the last MACT 

standard (excluding the MACT for combustion sources) [April 17, 2007]. 

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