### MDISP2 3 3 Dispersion coefficients from internally calculated sigma v, sigma w using micrometeorological

calculated variables

MROUGH 0 0 PG σ y and σ z not adjusted for roughness

MPARTL 1 1 No partial plume penetration of elevated inversion

MTINV 0 0 Strength of temperature i nversion 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

### CALPUFF Model Input Group 3: Speci es List-Chemistry Options.

CSPEC Modeled1 Emitted2 Dry Deposition3 Output Group

Number

SO 2 

### 1 1 1 0

SO 4 -2 

### 1 1 2 0

NO

x 

### 1 1 1 0

HNO 3 

### 1 0 1 0

NO 3 

### - 1 0 2 0

NH 3 

### 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

### CALPUFF Model Input Group 4: Map Projec tion 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 fo r SW corner of grid cell (1,1) of meteorological grid (km)

YORIGKM - -686.004 Reference Y coordinate fo r 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 co rner of the sampling Grid

JBSAMP - 0 Y index of lower left co rner 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

### CALPUFF Model Input Group 5: Output Options.

Parameter Default PCS Comments

ICON 1 1 Output file CONC.DAT cont aining concentrations is

created

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

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

IVIS 1 0 Output file containing rela tive 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 printe d to output list file every hr

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

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

IPRTU 1 3 Units for line printer output ar e in g/m3 for concentration and g/m2/s for deposition

IMESG 2 2 Messages tracking the progre ss 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 co mplex 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

### 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)

### CALPUFF Model Input Group 7: Dry De position 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 SO 2



### 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 NO

x



### 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 HNO 3



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

CALPUFF Model Input Group 8: Dry Depo sition Parameters for Particles.

Species Default PCS Comments

SO 4 

### 0.48 0.48 Geometric mass mean diameter of SO 4 -2 

### [μm]

NO 3 

### 2.0 0.48 Geometric mass mean diameter of NO 3 - 

### [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 al l species assumed to be 2.0 μm).

CALPUFF Model Input Group 9: Miscella neous Dry Deposition Parameters.

Parameter Default PCS Comments

### 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-irrig ated 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 liqu id precipitation [s -1 

### ] SO 2 

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

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [s -1 

### ]

SO 4 

### 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

6.0E-05 6.0E-05 Scavenging coeffici ent for liquid precipitation [s -1 

### ]

HNO 3 

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

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [s -1 

### ] NO 3 

### 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

8.0E-05 8.0E-05 Scavenging coeffici ent for liquid precipitation [s -1 

### ] NH 3 

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

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [ s-1 

### ] PMC 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [ s-1 

### ] PMF 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [ s-1 

### ] EC 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

1.0E-04 1.0E-04 Scavenging coeffici ent for liquid precipitation [ s-1 

### ] OC 3.0E-05 3.0E-05 Scavenging coeffici ent for frozen precipitation [s -1 

### ]

CALPUFF Model Input Group 11: Chemistry Parameters.

### Parameter Default PCS Comments

MOZ 1 1 Read ozone background concentrations from ozone.dat file (m easured values).

BCKO3 12*80 12*40 Background ozon e concentration (ppb)

BCKNH3 12*10 12*1.22 Background amm onia concentration (ppb)

RNITE1 0.2 0.2 Nighttime NO 2 

### loss rate in percent/hour

RNITE2 2 2 Nighttime NO X 

### loss rate in percent/hour

RNITE3 2 2 Nighttime HNO 3 

### loss rate in percent/hour

MH202 1 1 Background H2O2 

### concentrations (Aqueous phase transformati ons not modeled)

BCKH202 1 1 Background monthly H2O2 

### concentrations (Aqueous phase transfor mations not modeled)

BCKPMF 1. 1. Fine particulate concen tration for SOA Option (micrograms per cubic meter)

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

VCNX 50. 50. VOC/NO

x 

### ratio for SOA Option

### CALPUFF Model Input Group 12: Disp ersion/Computational Parameters.

Parameter Default PCS Comments

SYDEP 550 550 Horizontal size of a puff in meters beyond which the time dependan t dispersion equation of Heffter (1965) is used

MHFTSZ 0 0 Do not use Heffter formulas fo r sigma z

JSUP 5 5 Stability class used to determine dispersion rates for puffs ab ove 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 poin t for determining the transition point betwee n the Schulman-Scire to Huber-Snyder Building Downwash scheme

IURB1 10 10 Lower range of land us e categories for which urban dispersion is assumed

IURB2 19 19 Upper range of land us e 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 a bove 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 turbul ence 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 distan ce 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

### NCOUNT 2 2 Number of iterations us ed when computing the transport wind for a sampling step that includes transitional plume rise

### 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

### SHSPLITH 2.0 2.0 Minimum puff elon gation rate from wind shear before puff may split

CNSPLITH 1.0E-07 1.0E-07 Minimum species concen tration 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 ar ea 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

### 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 emission s scaling factors

NPT2 - 0 Number of point sources with variab le 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 pol ygon 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 sour ces 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 co mbinations 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 lin e source height (m)

### 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 co mbinations 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: Di screte Receptor Information.

Parameter Default PCS Comments

NREC - 52 Number of non-gr idded receptors

## Appendix C

CALPOST Configuration

### APPENDIX C – CALPOST Configuration

The tables below identify the recommended CA LPOST 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?

### 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

### 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 extin ction for sulfate?

LVNO3 T T Compute light extin ction for nitrate?

LVOC T T Compute light extinc tion for organic carbon?

LVMPC T T Compute light extincti on for coarse particles?

LVMPF T T Compute light extincti on for fine particles?

LVEC T T Compute light extincti on 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 fo r 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. car bon extinct. coeff – east

BKSO4 0.23 0.23 Background sulfate ex tinction co eff – east

BKNO3 0.10 0.10 Background nitrate ex tinction co eff – east

### BKPMC 3.00 3.00 Background coarse part . extinction coeff – east

BKSOC 1.40 1.40 Background organic car bon extinct. coeff – east

BKSSOIL 0.50 0.50 Background soil ex tinction co eff – east

BKSEC 0.02 0.02 Background elem. car bon extinct. coeff – east

BEXTRAY 10.0 10.0 Extinction due to Ra yleigh scattering (1/Mm)

### CALPOST Processor Input Gr oup 3: Output Options

Parameter DEFAULT PCS Comments

LDOC F F Print documentation image?

IPRTU 1 3 Print output units (μg/m 3 

### ) for concentrations and (μg/m 2 

### /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’ va lues 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 th reshold for 1 hr averages

THRESH3 -1.0 -1.0 Averaging time th reshold for 3 hr averages

THRESH24 -1.0 -1.0 Averaging time th reshold 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 informat ion for debugging?

## Appendix D

CLASS I Receptors in Lamber t Conformal Coordinates

### 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

### 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

## 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, 2007Blue Ridge Paper Products BART determination



### TABLE OF CONTENTS

Section Page
1.0 Introduction .............................................................................................................. ...... 3

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

2.0 General De scription........................................................................................................ . 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 NO

x 

### 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 DBlue Ridge Paper Products BART determination



### 3 SECTION 1.0

INTRODUCTION

The Blue Ridge Paper Products (BRPP) Canton facility is a bl eached kraft pulp mill producing bleached kraft softwood and hardwood pulp, pape r and paperboard. Existing sources include: five power boilers, a batch digest er 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 pa per 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 Qua lity (NCDAQ) on November 16, 2007.

The requirements for Best Available Retrofit Technology (BART) are se t 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 manda tory Class I federal areas as determined using 40 CFR 51, Subpart P. “BART-eligible” sour ces 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), 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 BA RT eligible: Recovery Boiler 10, Recovery Boiler 11, No. 10 smelt dissolving tank, No. 11 smelt di ssolving 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 ex empted 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 BA RT 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 remainde r of this report contains a review by NCDAQ of the demonstration and analyses presented by Bl ue 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 c ontains the NCASI Corporate Correspondents Memorandum onBlue Ridge Paper Products BART determination



### 4 retrofit controls.

BART will be implemented through a modificati on to Blue Ridge Paper Products Title V air permit. The Title V air permit application im plementing 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 dr aft air permit language implementing the BART requirements may be found in Appendix D.Blue Ridge Paper Products BART determination



### 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), particulate matter (PM), and volatile organic compounds (VOCs), and that fall within 26 industr ial 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 SO 2 

### emissions from combustion of sulfur compounds in the BLOX gases in order to not be considered a signicicantBlue Ridge Paper Products BART determination



### 6 modification under NSR PSD. Therefore, the 5 BA RT-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 98 th 

### percentile change in deciviews 1 

### (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 M ill. 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. Howe ver, 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 deci view is a haze index deri ved from calculated light extinction, such that uniform changes in haziness corre spond 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 ln

e (b ext /10 Mm − 1 ).



### Where b ext 

### =the atmospheric light extinction coefficient, expressed in inverse megameters (Mm − 1 

### ).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.Blue Ridge Paper Products BART determination



### 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 visib ility protection provisions of the Clean Air Act

addresses installation of best available retrof it technology (BART) for certain existing sources. “BART-eligible” sources are those sources bu ilt 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 (SO 2 

### ), nitrogen oxides (NO

x 

### ), particulate matter (PM), and volatile organic compounds (VOCs), and that fall within 26 industr ial 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 98 th 

### percentile change in dv is equal to or greater

than the “contribution threshold.” The contribu tion 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 evaluati ons, States will develop Regional Haze State Implementation Plans (SIPs). States must subm it plans to implement the Regional Haze Rule for EPA review and approval by January 2008.Blue Ridge Paper Products BART determination



### 9 3.2 North Carolina BART Applicability

The BART requirements are implemented through 15A NCAC 2D .0543 “Best Available Retrofit Technology.” This rule implemen ts 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 mode ling 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 wa s 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.Blue Ridge Paper Products BART determination



### 10 SECTION 4.0

BEST AVAILABLE RETROFIT TECHNOLOGY ANALYSIS

4.1 Summary

The sources subject to the Best Available Re trofit Technology (BART) requirements include the two recovery boilers, their associated smelt dissolving tanks, and the BLOX. This section presents the BART analyses for these emissi on 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 ba sis, taking into consideration the technology available, the costs of compliance, the ener gy 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 im provement in visibility which may reasonably be anticipated to result from the use of such technology.”

The BART analysis was conducted with consider ation of the six requirements identified above and the five steps identified in 40 CFR 51 Appe ndix Y “Guidelines for BART Determinations Under the Regional Haze Rule.” Again, these guide lines are not the exclusive means of defining

BART for facilities other than Electric Generati ng 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 retr ofit control option as an air pollution control technology with a practical potential for applica tion to the emissions unit and the regulated pollutant under evaluation. Technologies availabl e for compliance with Best Available ControlBlue Ridge Paper Products BART determination



### 11 Technology (BACT) or Lowest Achievable Em ission Rate (LAER) regulations should be included as part of the BART analysis. Furt hermore, 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 cat egories 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-NO X 

### 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 Environm ental 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 tec hnology could be applied: "availability" and "applicability." ...a technology is considered "available" if the source owner may obtain it through commercial channels, or it is othe rwise 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 unde r consideration. A technology that is available and applicable is technically feasible.” Control technologies that are deemed technically in feasible 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.Blue Ridge Paper Products BART determination



### 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 an alyses to select the control technology that meets the requirements of BART. The analysis evaluates four impacts that would pot entially 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 gui dance 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.Blue Ridge Paper Products BART determination



### 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 solid s 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 emissi ons 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, SO 2 

### , and NO

x 

### . Each of these units are equipped with an ESP that exceeds the particulate emission requirements of 0.044 gr/dscf at 8% O 2 

### 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% O 2 

### for No. 10 Recovery Furnace and 0.007 gr/dscf at 8% O 2 

### 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 NO

x 

### emission control

Compared to a typical power boiler, emissions of NO

x 

### from a recovery furnace are generally quite minimal. The minimal NO

x 

### 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 NO

x 

### .

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

There are several NO

x 

### control technologies that are potentially applicable to combustion sources based on reviews of similar processes and a review of the RBLC database.

1. Low NO

x 

### Burners (LNB) – The use of low NO

x 

### burners is a demonstrated technology installed on many fossil-fuel combustion sources. However, this is not a demonstratedBlue Ridge Paper Products BART determination



### 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

NO

x 

### 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 NO

x 

### control.

2. Flue Gas Recirculation (FGR) – FGR invol ves 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 NO

x 

### . However, as previously stated

thermal NO

x 

### emissions from a recovery furnace are minimal. Therefore, installation of this control technology would not result in significant NO

x 

### reductions and is not

considered further.

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

for the control of NO

x 

### 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 NO

x 

### 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 NO

x 

### 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 NO

x 

### 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 NO

x 

### emissions was observed. Therefore, this control technology is the only option identified as technically feasible for NO

x 

### 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 thisBlue Ridge Paper Products BART determination



### 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 NO

x 

### reduction efficiency of 40% (a reduction of 230 tons per recovery furnace), the cost effectiveness per ton of NO

x 

### 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 NO

x 

### 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 cont ained in the smelt leaving the furnace; however, a small fraction of the compound can be emitted in the form of SO 2 

### . There are a number of factors which are thought to influence the formation of SO 2 

### in the recovery furnace; however, a direct relationship has not been established.

A review of the RBLC database shows that ther e are no add-on control technologies that have been installed solely for the control of SO 2 

### emissions.

An additional source of information on emissions controls is the National Council of Air and Stream Improvement (NCASI) Corporat e Correspondents Memorandum CC 06-014 entitled

“ Retrofit Control Technology Assessment for NO

x 

### , SO 2 

### , 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 ther e are no control measures specific to SO 2 

### 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 SO 2 

### removal from the units.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 comp licated and costly retrofit for the recovery furnaces at the Blue Ridge Cant on 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 potentia l 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 th e 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 e xperience and EPA’s Control Cost Manual. It is important to note that the Blue Ridge Cant on 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 in stallation of a new scrubber on each recovery furnace would require extensive piping and ductwor k 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 el evate the ductwork over roadways. Additionally, a new fan would be required to move the e xhaust through the new ductwork and scrubber to overcome the additional pressure loss. Not only w ould there be capital costs associated with the installation of a fan, but the current power dist ribution system is operating at maximum capacity and a new switch gear would be required.

The expenses associated with the wet scrubbe r 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 cons truction. The capital costs for the installation of a wet scrubber achieving 90% SO2 removal fr om a recovery boiler was estimated to be $26,293,000, and annualized costs at $6,897,430. The cost effectiveness per ton of SO 2 

### 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 imp act 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, th e 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 configurati on 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 Ro ck Class I area. This scenario actually causesBlue Ridge Paper Products BART determination



### 17 a higher delta deciview impact than the modeled current conditions. The num ber 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 Mountai ns. 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 SO 2 

### 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 cau sticizing system to create white liquor for reuse in the pulping process. There are minimal emissions of NO

x 

### , SO 2 

### , and particulate from the smelt dissolving tanks. Blue Ridge Paper does not have site-specific NO

x 

### and SO 2 

### 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 NO

x 

### and SO 2 

### sometimes measured may be a result of

oxidation of ammonia emissions within the NO

x 

### analyzer and oxidation of sulfur in the smelt during smelt-water explosions. Each unit is curre ntly 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 SO 2 

### 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

SO 2 

### 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 th e 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 technica lly feasible control technologies, the visibility improvements that may be obtained from modifica tions to the current smelt tank scrubbers was investigated. A 50 percent improvement over current SO 2 

### and PM emissions would result in a 0.029 deciview improvement could be seen afte r modifying the scrubbers. The cost is $10,384,813/ton/dv for SO 2 

### and $478,016/ton/dv for particulate.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 Sh ining 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 em issions 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 ha ve been determined as BACT for NO

x 

### emissions from smelt tanks. NCASI is not aware of any smelt tanks with NO

x 

### controls installed. Therefore, no further eval uation was conducted for NO

x 

### control technologies for the smelt dissolving tanks.

4.5 BART Analysis for Black Liquor Oxidation System

On April 15, 1998, the EPA promulgated Nati onal Emission Standards for Hazardous Air Pollutants (NESHAP) from the Pulp and Pape r 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 implemen t alternative requirements in the form of permit terms and conditions instead of the require ments 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 Pa per submitted an application on June 17, 2004 to request approval of an alternate compliance appr oach 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 leve l 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 SO 2 

### control. The modeled SO 2 

### emissions represent the vendorguaranteed emission rate at the scrubber outlet. PM and NO

x 

### emissions are minimized by proper operating of the RTO and combustion of natural gas as auxiliary fuel, and no further controls areBlue Ridge Paper Products BART determination



### 19 feasible. The construction of the RTO/Scrubbe r 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 c ontrols 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.

## APPENDIX A

Response to EPA and NPS Comments on BART Permit ApplicationURS 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 Pa per 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 Carolin a 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

### 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, wi th the exception of installation of quaternary air on each re covery furnace (RF).

Blue Ridge Paper Response

The BART-affected units at Blue Ridg e 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 pollu tion 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 fa cility 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 Stre am Improvement (NCASI) through Corporate Correspondents Memorandum CC 06-014 entitled “Retrofit Control Technology Assessment for NO

x 

### , SO 2 

### , and PM Emissions from Kraft Pulp and Paper Mill Unit Operations. ” As the environmental control reference organization for the pul p and paper manufacturers, NCASI follows the industry closely and is awar e 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 fo cused on information available in "Assessment of Control Options for BART Eligible Sources," prepared by NESCAUM, for the Mid-Atlantic/Nor theast Visibility Union Regional Planning Organization. Review of th is document only identified one additional control option for the reduc tion of sulfur dioxide from the Recovery Furnaces. That option is to reduce liquor sulfidity in the black liquor solids. Sulfidity is the ratio of Na 2 

### S to the active alkali, where active alkali is the sum of sodium hydroxide and Na 2 

### S. The Blue Ridge recovery cycle has been balanced with a target sulfidity of 24-26%. Reducing the liquor sulfidity can adve rsely affect pulp quality and the cooking reaction rate. Therefore, reducing liquor sulfid ity is not a viable option for the Blue Ridge Mill.

### 2 2. EPA Comment - Process Changes to Re duce Formation of Emissions from

RFs

Although Table 4-1 indicates that severa l Kraft pulp and paper mills utilize good combustion control practices to minimize sulfur dioxide (SO 2 

### ) 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 SO 2 

### in each RF. An effective approach to minimizing the formation of SO 2 

### 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 "Asse ssment 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 th e lower part of the RF in order to

reduce SO 2 

### emissions, and reducing li quor sulfidity to reduce SO 2 

### emissions from the RFs.

Blue Ridge Paper Response

The referenced document indicates that SO 2 

### 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 th is configuration, the design dry solids firing rate in the recovery furnace is 60 to 65 pe rcent. There is a about a 5 percent loss of Btu heating value in th e 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 re covery furnaces include quaternary air and may have a lower NOx emission ra te 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.

### 3 Modifications that would change th e firing pattern and maintain uniform temperatures in the lower part of the recovery furnace are very similar to the changes proposed for the installati on 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 SO 2 

### controls on the RFs results in lower stack heights and a hi gher modeled delta deciview (dv) than

current conditions due to decreased di spersion 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 SO 2 

### control.

Blue Ridge Paper Response

As stated in the document, the in creased delta deciview from the installation of a scrubber on the recover y furnace exhaust is due to a cooler plume. A GEP analysis was performe d for the facility including the

modeled scrubber stack and all stack heights included in the modeling analyses meet the GEP modeling requirements.

### 4 4. EPA Comment - Lost Production Costs

There is no indication of whether the f acility 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 plan ned 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 re trofit to install a quaternary air system, which results in significant lo st 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 reco very furnaces routinely operates at maximum capacity to meet the producti on 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 dist ribution and the furnaces must also undergo a complete rebalancing of th e air system. The air system is currently run by a forced-draft stea m 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 sy stem, 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 furna ce outage is very limited – one day a most. When a recovery furnace go es 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 pul p must be purchased from outside sources, at a significant cost premium compared to slush pulp manufactured

on-site.

### 5 EPA Comment

When major work is done at a pulp and paper mill, the mill can often increase production significantly prio r 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 fo llowing the planned shutdown.

Furthermore, as mentioned in Comme nt 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 cost s listed in Table 4-2, it is not clear whether the facility considered achieving some additional power generation from its power boilers duri ng the retrofit peri od 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 burni ng black liquor solids must be supplemented by burning additional coal in the mills power boilers and by buying additional power from the commerc ial grid. Blue Ridge generates most, but not all, of its electrical pow er needs. When steam production is down during a recovery furnace outage, the mix of mill generated and purchased power changes. Steam produc tion 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 hi gher than 10 percent would be considered acceptable for wet scrubber installation on a RF at a pulp and

### 6 paper mill, and would be consistent w ith standard industry practice. Also, since this is a "turnkey" installa tion, it is unclear why such a high contingency factor is proj ected. 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, distingu ishes between the contingency

and retrofit factors and recommends k eeping 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, a nd switch gear should be assigned to the retrofit factor since they are a nece ssary 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 unantic ipated cost increase (i.e., outside of the contractor's control), and are not di rectly related to the retrofit factor elements just described. (See page s 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 Tabl e 4-2 did include the retrofit factor. Please refer to Attachment 1 of this correspondence for an updated calculation of costs asso ciated with the installa tion of a wet scrubber on a single recovery furnace. As st ated in EPA’s Cost Control Manual:

“Probably the most subjective part of a cost estimate occurs when the control system is to be inst alled 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 in to 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 ha ve sufficient informati on 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 scr ubber appears to also include the cost

### 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 f actor 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 descri bes contingencies as a category that covers unforeseen co sts 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: Concep ts 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 planne d event, not an unforeseen cost. We note that lost production in terms of pu lp purchase correctly does not appear

to be included in the con tingency cost calculations.

Blue Ridge Paper Response

The terminology used in line one of th e 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 sit uation 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 sc rubber 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 sw itch 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 clos er 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 s ite. 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 op tions proposed in the comments are not feasible. The roads cannot be mo ved due to fire regulations and there are no buildings to be moved.

### 8 Figure No. 1 – Overview of the Canton Mill

### 9 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 th e scrubber liquid and the mill has

claimed SO 2 

### 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 Je t system. While the cost for the scrubber itself is signific ant, the largest cost c ontribution is from the installation of ductwork to route th e exhaust to the unit and modifications to the fan and switch gear. These co sts would be approximately the same no matter the scrubber design.

### 10 EPA Comment

There is no discussion indicating whethe r the facility considered use of caustic as the scrubbing reagent instea d 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 produ ce 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 pe r year and landfill disposal costs are also less than $10,000 dollars per yea r. 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, th e 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 eval uate 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 consid erations should include the assumed pressure drop of the scrubber, and wh at 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 elect ricity costs are $319.00 per hp-yr.

7. EPA Comment - RF Quaternary Ai r 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

### 11 seems extremely high. In 2001, the Ameri can Forest and Paper Association (AF&PA) commissioned BE&K Engineer ing to develop emissions control cost estimates for a variety of scenarios at pulp and paper mills, including the addition of a quaternar y 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 quater nary 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. Th e air system is currently run by a forced-draft steam turbine fan that was originally installed with the recovery furnace. This older techno logy will be more costly to balance than current systems.

The original Kraft pulp recovery furna ce installations at Blue Ridge had 2- stage combustion. These are medium-s ized 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 upgrad e to combustion staging. Champion International, the predecessor comp any to Blue Ridge, studied various options for combustion control impro vements to the Canton Mill recovery furnaces in the 1980s. The cost of various upgrade options were estimated including quaternary air and alternati ve configuration black liquor fuel guns. However, the upgrade to tertiary air and BLOX that were undertaken were the only practical modifications fo r 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 quaternar y air and alterna tive configuration black liquor fuel guns. The availabl e Champion International engineering evaluations from the 1980s were r eviewed and the previous conclusions were validated - addition of quaterna ry 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

### 12 air staging equipment, modifying and moving the existing combustion air ports in the furnace (all ASME code ve ssel welding) and reinstallation of the existing along with new combus tion air ductwork and fans. New combustion air controls are necessary . The design considerations for changing black liquor fuel guns are simila r. This is not a simple swap out of equipment. Alternative black liq uor 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 recover y furnaces to quaternary air and alternative fuel guns is based on th e 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. Re trofit will require a major reworking of the entire furnace combustion air and liquor firing equipment and controls.

8. EPA Comment - Supporting Docume ntation 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 describe d 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 wa s used preparing the original cost analysis. Attachment 1 to this lett er 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 s ubject 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 se ek 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 su ch as what year the quote for the

### 13 original RF was received.

Blue Ridge Paper Response

Because of time constraints in the pre paration of the original document, it was not possible to obtain a vendor q uote for the specific installation at Blue Ridge. However, in responding to these comments we have contacted

vendors and included their co rrespondence 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 th is "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 accepta ble 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 co stly to obtain, the use of the sixtenths factor to adjust cost s is appropriate since the purpose of this effort is regulatory applicability.

### 14 9. EPA Comment - Capital Recovery Factor (CRF) Calculations

The facility should justify its capita l recovery cost assumptions of an equipment life of 10 years w ith 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: Chemic al 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 equipmen t life and an interest rate of seven percent. Note that changing the a ssumptions 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 anal yses. 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 polluti on 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 stru cture of their business . Furthermore, a number of air regulations allow sources of pollution to petition for extensions on deadlines, variances from the regula tion, or exemption from installing control devices, based upon the econo mic 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 acce ptable 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 abo ve. The 15% rate is being used to account for the project costs as well as for the lost capital available for

### 15 funding other projects that could have positive return on investment at the

mill. The recovery furnaces are curren tly more than 40 years old, assuming a useful life of 15 years would not be appropriate for this application. Therefore, all calcul ations have been completed using 10

years.

### 16 Enclosure 2

1. EPA Comment

Table 5-1 indicates a 31.25-meter decreas e 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 cons idered in the development of the new stack height for this SO 2 

### 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 im pact has shifted sl ightly to another geographical location in the Shin ing Rock and Great Smoky Mountain

Class I areas. With decreased SO 2 

### emissions from installation of the scrubber, the expected re sult is that the visibility impact should also decrease. The analysis should provi de 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 loca tion. Since the CALPUFF model is evaluating long-range transport effects, moving the stack 300 feet on the property would have a negligible im pact 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 sc rubber from $12,177 per ton to $15,372 per ton.

It should be noted that while SO 2 

### emissions from the recovery furnaces are lower after the installation of a scru bber, 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 exclus ion 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 assumpti ons supporting the emission rates are correct and the supporting documentation is submitted.

### 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 preparat ion of the Annual Air Emissions Inventory.

The other known source of NOx emi ssions data from recovery furnaces comes from NCASI Technical Bulletin No. 884. However, the test data presented in this document is the resu lt 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 th e 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 spec ified 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 appr oach to that required in 40 CFR Subpart S for the high-volume, low-con centration (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 wi th 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 desi red level of benef it at two of the five Class I areas, but the other thr ee Class I areas being affected by the facility could also be consid ered 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 locate d approximately 11 kilometers south of

### 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. M odeled values were less than 0.5 dv

at the other Class I areas and are deemed insignific ant based on EPA’s guidance regarding single source contribut ion 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 va lues greater than 0.5 dv.

5. EPA Comment

Addition of a wet scrubber should al so reduce fine particulate matter (PM2.5), including condensable PM, whic h is not controlled by the ESP. The impact of additional PM control ach ieved 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 Ro ck). Also, the PM emissions are based on the most recent compliance test . These data likely represent the best ESP operating conditions, which ma y 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 in stalled on the units. Appendix Y to 40 CFR 51 states the following:

“If you find that a BART source has c ontrols already in place which are the most stringent controls availabl e (note that this means that all possible improvements to any control devices have been made), then it is not necessary to comprehensively co mplete 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% O 2 

### for No. 10 Recovery Furnace and 0.007 gr/dscf at 8% O 2 

### for No. 11 Recovery Furnace. The purpose of

the stack test was to demonstrate co mpliance with MACT emission limits at a level that represents at least 90 percent of capac ity. Therefore, during the test, the mill was operated at high ca pacity and Blue Ridge continues to

### 19 operate the recovery furnaces under the conditions during the test to ensure on-going compliance.

Therefore, potential retrofit contro l technologies for particulate matter emissions from the recovery furnaces was not further evaluated since the units are already equipped with th e 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 l oading to the device would be minimal as shown by the test results provided above, ther efore, 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 visib ility 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 (a s 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 NNCA SI) related to measurement of PM2.5 emissions. The current use of EPA Method 202 by the industry appears to be underreporting PM2.5 em issions, 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 "artifact s" resulting from conversion of SO2 to sulfates (i.e., to SO3 and then to H2SO4). The reported condensable PM is "corrected" by subtracting th e sulfate fraction from the total

condensable PM emissions. This "cor rection" results in biasing the

measured emissions low. It is not cl ear whether this type correction was done for the reported emissions used in this modeling analysis. The State may want to clarify how EP A Met hod 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 Divi sion of Air Quality guidance for Annual Air Emissions reporting purposes.

### 20 7. EPA Comment

Modeling performed at 1-km grid reso lution - 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 mode ling 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 do cument, which says that sourcereceptor distances less than about 50 km may require grid resolution less than l-km if complex terrain effect s 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 be tween 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 modeli ng 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 Ca rolina Division of Air Quality.

8. EPA Comment

Results tables specified in the VIST AS Protocol - The VISTAS Protocol provides standard table formats fo r 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 pe riod, 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 s uggested that similar tables be

included in the determina tion report. Also, documenta tion that addresses the development of the baseline mode ling 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.

### 21 Blue Ridge Paper Response

The April 27, 2006 BART Exemption Modeling Report has been previously submitted to NCDAQ. The Octobe r 2006 date used by EPA in the comment above appears to be a typographi cal error. Additional copies may be provided upon request.

9. EPA Comment

Deciview Thresholds - The document stat es in several places that “... the change in modeled visibility impact...is less than the 1 deciview threshold of human perception for changes in visibili ty.” This statement implies that the

controls are not c onsidered 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 BA RT determination analysis the degree of visibility improvement that is co nsidered significant enough to warrant BART controls. Rather, a State has flex ibility in setting absolute thresholds and determining the weight and signif icance to be assigned to each BART factor. (See 70 FR 39170, 1 st 

### 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 “vis ibility 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 c ontrol 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 Clas s 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 impairmen t in a Class I area if the modeled 98 th


### percentile change in dv is equal to or greater than the “contribution

threshold.” The contribution threshol d is 0.5 deciview. Since the modeled change in visibility for each cont rol scenario is less than the 0.5 dv contribution threshold as compared to natural conditions, it is appropriate

to state that a control scenario woul d not result in a humanly perceptible change as compared to natural conditions.

### 22 Furthermore, the existing regional haze in the subject Cla ss I areas is on the order of 35 dv. Based on the mode ling 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.

### 23 Enclosure 3

EPA Comment - Below are clarifications we wish to note on certain statements in the text. (The locatio n 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 addi ng 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 f acility which operates with controls under similar conditions. Another way of stating this is as follows.

If comparable emissions units ar e 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 es timates 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 correct ed 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 reques ted change. If the North Carolina Division of Air Quality requests a co mplete 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

### 24 Regional Haze regulations at 40 CF R 51.308 (b) is: “ ... no later than December 17,2007.”

Blue Ridge Paper Response

Blue Ridge acknowledges the reques ted change. If the North Carolina Division of Air Quality requests a co mplete amended document then the change will be incorporated into the text. We would note that this is only an editorial change, both statem ents 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 comp arison on page 2-5. We recommend excluding LOS documentation since, as the report indicates, this specific approach is not appropria te for BART mode ling purposes. (b) The document provides selected de finitions from 40 CFR 51. We wish to clarify that the definiti ons 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 th at the line-of-sight approach is the technically appropriate refin ed method for evaluating visibility impacts for BART exemption modeling when compari ng a single source to the humanly perceptible change value of 1 deciview. Furthermore, this is consistent with the definition and scie ntific 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 Ha ze Index as an Indi cator for Regional Haze,” if a shorter LOS distance than the background visual range (natural conditions) is used in perf orming 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 th e background visual range, then it would require a higher d eciview 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 woul d 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 calc ulates 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.

### 25 5. Permit Changes (Section 4.2, PA-4)

The document asserts that the electrostatic precip itators (ESPs) on each RF

exceed the Maximum Achievable C ontrol 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 avai lable 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 th e 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 Ta bles 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 en able reviewers to find the referenced portions of the docum ent. 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/I ttncatc1/products.htm/#cccinfo. )

Blue Ridge Paper Response - The cost estimate for the installation of a scrubber on the recovery furnaces ha s been revised and is included in Attachment 1 to this correspondence.

7. Table 4-1 – “Summary of RBLC Data base 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, Pro cess 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 he re for your convenience:

### 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 Corporat ion, 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 perfor med, 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 incl ude all or exclude a ll 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 St ep 5 of the BART Guidelines. The second paragraph of this section states : “If the net visibility improvement is less than the humanly perceptible cha nge, 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 Guidelin es provide flexibility to the States with setting thresholds and weighing each of the BART factors. (See 70 FR 39170, 1 st 

### col., July 6, 2005.) All of the stat utory factors should be used in

the determination of whether or not BA RT 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.

### 27 9. 22 nd 

### highest values for the two wors t-case years (Section 5.8. P. 5-7) Page 5-7 of the document states that a spreadsheet was used to determine

the 22 nd 

### highest values for the two worst-case years. The 98 th 

### percentile value for an individual year is the 8 th 

### highest value, so it is unclear why the report references the 22 nd 

### highest value. This appears to be a typographical

error.

Blue Ridge Paper Response - This is a typographica l error in the report;

the 8 th 

### highest value was the re ported modeling result.

### 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 deci view threshold of human perception for changes in visibility...Therefore, BART is no further controls.” Further, page 4-3 states, “If the net visibility im provement is less than the humanly perceptible change, then there is no n eed for the facility to implement the control technologies because the resu lting visibility impacts would be negligible.” We acknowle dge 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 desc ribed in Appendix Y to 40 CFR 51. The following 5-step process was utilize d 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 Effect iveness 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 SO 2 

### from the recovery furnaces:

• BRP refers to a vendor quote for th e 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 sw itch gear installation is missing and should be provided.

• If waste caustic is available from th e bleach plant – if there is one – it could be used as the scrubbing r eagent, thus reducing reagent and disposal costs – this should be investigated.

• The Capital Recovery Factor is in flated. The OAQPS Control Cost

### 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 defin ed in the revised table.

Blue Ridge is currently limited by the am ount 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 scr ubbing 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 recover y 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 cont rolling 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 in flated. 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 produ ction are accounted in the Indirect

Installation Cost. The Indirect Installati on 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

### 30 information provided by the National C ouncil for Air and Stream Improvement. Please refer to Corporate Corres pondents Memorandum CC 06-014 entitled “Retrofit Control Technology Assessment for NO

x 

### , SO 2 

### , and PM Emissions from Kraft Pulp and Paper Mill Unit Operations. ” In fact, the memorandum indicates that the installation of quate rnary air reduces NOx emissions by 20- 40%. Therefore, we have been conservative in our inclusion of 40%.

### 31 Attachment 1

Revised Cost Estimate

### Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recover y 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 ($/given) Cost 4 ($) 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 shapes 2 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 shapes 2 Outlet ductwork to scrubber , 13'x13' x 50' long, 2205 SS 1 Inlet ductwork to scrubber , 13'x13' x 300' long, 2205 SS 1 Given Information Alloy Fabricated Materials - Ductwork

Stack, 100 ft tall, 12' dia. (erected price, including foundations)

### Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recover y 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 Investmen t

$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 Investmen t

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

### Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recover y 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 Labo r $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 Facto r

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

### Blue Ridge Paper Products, Inc.

Canton, North Carolina

Table 4-2. Cost Estimate for Installation of a Wet Scrubber on Recover y 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"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 Corporation1600 Perimeter Park Drive, Suite 1 00 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 SystemCynthia,

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 perhour. H2SO4 emissions from the unit are 0

. 1 8 p ounds 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 solely responsible for checking for the presence of "Viruses" or other "Malware". MECS, Inc. accepts no liability for any damage caused by any such code transmitted by or accompanying this e-mail or any attachment.

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## URS Corporation

DynaWave Tailgas Scrubber Design Conditions

Inlet Conditions

Scrubber Inlet Flow Rate, acfm 365,500

SO 2 

### , lb/hr 128

Temperature, oF 260

Scrubber Operations Summary

SO 2 

### Removal Efficiency* 90

SO 2 

### 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% Na 2 

### SO 3 

### )

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.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 HThomas 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 s hould not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any attachments or copies

.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

## APPENDIX B

NCASI Corporate Correspondents Memorandum on Retrofit Controls

# 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 NO

x 

### , SO 2 

### and PM Emissions

The attached document “Retrofit Control Technology Assessment for NO

x 

### , SO 2 

### 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 d eals with the three main pollutants of concern for BART analyses, namely NO

x 

### , SO 2 

### 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, c ontrol 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 theoreticallyapplicable, retrofitting the technology to an older existing unit requires consideration of unitspecific and location-specific factors. In many s ituations, 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 andmaintenance 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 Regiona l Center office, phone (352) 331-1745, ext 226;

email asomeshwa r @ncasi.org

.

AttachmentNational Council for Air and Stream Improvement 

### Retrofit Control Technology Assessment for NO

x 

### , SO 2 

### 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 applicab ility of currently available emission control technologies for NO

x 

### , SO 2 

### and particulate matter (PM) to various pulp and paper mill sources. The three main unit operations in a kraft pulp mill that emit NO

x 

### , SO 2 

### 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 on ly fossil fuels. Particulate emissions can also result from lime slakers and smelt dissolving tank s. 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-specifi c engineering analysis. However, it must be clearly noted that for any retrofit technology, s ite-specific considerations for a given emission source may disqualify a particular control tec hnology 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 f acilities 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 technolog ies problematic or very expensive.

2.0 Kraft Recovery Furnaces

2.1 NO

x 

### Control

Compared to coal- or residual oil-fired boilers of similar capacity, NO

x 

### emissions from kraft recovery furnaces are generally quite low, typica lly in the 60 to 130 ppm range. These low NO

x 

### 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 NO

x 

### formation resulting predominantly from “fuel NO

x 

### ” mechanisms (insufficient temperatures for “thermal NO

x 

### ” formation), (c) the highly staged combustion design of recovery furnaces, and (d) the existence of sodi um fumes that might participate in “in-furnace”

NO

x 

### 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 NH 3 

### and partly as N 2 

### , 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 N 2 

### . A review of the theoretical kinetics governing the reactions between NH 3 

### , NO, and O 2 

### suggests that, in the presence of2 June 4, 2006

National Council for Air and Stream Improvement 

### excess O 2 

### , a decrease in temperature decreases the degree of oxidation of NH 3 

### to NO, thus implying that fuel NO

x 

### generation during black liquor combus tion 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 SO 2 

### emissions from the furnace. Most of the NO is formed by oxidation of the NH 3 

### volatilized during pyrolysis of the liquor droplets. Very little NO is formed from the N in th e 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 additi onal NO contribution from char burning.

Some have observed that NO

x 

### emissions increased when firing liquors with increasing liquor solids contents. However, this may have had less to do with thermal NO

x 

### or an “in-furnace” capability of alkali fume to capture NO

x 

### as suggested by some, but more to do with a possible

effect on increased conversion of ammonia to NO w ithin the furnace due to an increase in lower furnace temperatures resulting from firing higher solids liquors.

2.1.1 Low NO

x 

### Burners

The use of low-NO

x 

### 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 st aged 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 NH 3 

### 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 NO

x 

### levels is feasible using such air staging. However, to make it feasible to inst all a quaternary air system a recovery furnace typically needs to be fairly large in size. Thus this option woul d not be feasible for most BARTeligible recovery furnaces, since units built in th e 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 b ack to the combustion zone, primarily with the intention of reducing thermal NO

x 

### . Thermal NO

x 

### is, however, not a concern in recovery furnaces, as discussed earlier. FGR would add additional g as volume in the furnace, increasing velocities and potentially causing more liquor carryover, which would result in increased fouling of the recovery furnace tubes.June 4, 2006 3

National Council for Air and Stream Improvement 

### 2.1.4 Oxygen Trim + Water Injection

Oxygen-trim + water injection, a NO

x 

### 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 unaccep table 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 in formation on the extended use of SNCR on an operating kraft recovery furnace. Short-term t ests 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 NO

x 

### 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. Althoug h steam is generated from liquor combustion, certain chemical recovery steps have to be acco mplished inside the furnace. It is not known whether the injection of NO

x 

### -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 NO

x 

### -NH 3 

### reactions available in smaller furnaces, (3) impact on fireside deposit buildup due to reduced chloride purging from long-term NH 3 

### /urea use and resulting impact on tube corrosion and fouling, and (4) potential for significant NH 3 

### slip and plume opacity problems due to NH 4 

### Cl emissions. Unless these concerns ar e 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 ne ver 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 im pediment 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 NO

x 

### . 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 NO

x 

### emissions might be the only technologically feasible option at the present time for NO

x 

### reduction. However, the effect of such air staging on emissions of other pollutants, chiefly SO 2 

### , 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 NO

x 

### emissions from black liquor combustion in a recove ry furnace. Unfortunately, this factor is beyond the control of pulp mill operators.4 June 4, 2006

National Council for Air and Stream Improvement 

### 2.2 SO 2 

### Control

Black liquor contains a significant amount of sulfur, nominally 3 to 5% by weight of the dissolved solids. While the vast majority of th is sulfur leaves the furnace in the smelt product, a small fraction (generally under 1%) can escape in gaseous or particulate form. Average SO 2 

### concentrations in stack gases can range from nearly 0 to 500 ppm, although most furnaces currently operate with <100 ppm SO 2 

### in stack emissions. Factors which influence SO 2 

### levels are liquor sulfidity, liquor solids content, stack oxyg en content, furnace load, auxiliary fuel use, and furnace design. However, none of these factors h as exhibited a consistent relationship with SO 2 

### emissions. At the present time, it is generally unde rstood 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 SO 2 

### 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 SO 2 

### 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 SO 2 

### 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 re moval. Another scrubber following an ESP was

installed on a furnace with a direct contact eva porator 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 SO 2 

### emissions, the removal costs in terms of dollars per ton of SO 2 

### removed would be large due to high gas flows and site-specific retrofit considerations. Significant capital would be re quired 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, uncontro lled 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 par ticulate 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 co mprised 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 a dditional add-on control devices more difficult.

Increasing liquor firing density (ton/day/ft 2 

### ) 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.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 bette r overall PM capture efficiencies. However, this option is expected to be quite cost ineffectiv e 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 NO

x 

### Control

NO

x 

### emissions from lime kilns result mainly from foss il fuel burning (natural gas and fuel oil). A recent NCASI study involving NO

x 

### testing at 15 lime kilns verified that “thermal” NO

x 

### was the sole mechanism operative in gas-fi red kilns, while the “fuel” NO

x 

### mechanism was mostly operative in oil-fired kilns. Gas-fired kiln NO

x 

### emissions appeared to be strongly dependent on the dry-end lime temperature. Oxygen availabilit y in the combustion zone was determined to be the key factor in oil-fired kilns. NO

x 

### 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 NO

x 

### 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 NO

x 

### .

A BACT analysis conducted for a new lime k iln in 1997 concluded that the use of low NO

x 

### 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

NO

x 

### burners' is considered a misnomer in the rota ry kiln industry. In boiler burners where the combustion air can be staged, 'low NO

x 

### ' 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 NO

x 

### to some extent. Effectively, the NO

x 

### 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 NO

x 

### 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, NO

x 

### 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 modifi cations. 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.6 June 4, 2006

National Council for Air and Stream Improvement 

### 3.2 SO 2 

### Control

Sulfur dioxide is formed in lime kilns when fuel oil or petroleum coke is burned as primary fuel.

SO 2 

### 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 SO 2 

### . 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, a nd 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 SO 2 

### removal process since the scrubbi ng solution becomes alkaline from the captured lime dust. Consequently, even though the potential for SO 2 

### formation in a kiln that burns sulfur-containing fuels with or without NCGs/SOGs is high, most lime kilns emit very low

levels of SO 2 

### (~50 ppm). Some kilns do, however, occasionally emit higher levels of SO 2 

### (50 to 200 ppm). Not much is known about why this happens.

Emission test data show that SO 2 

### concentrations do not appear to be related to either the fuel type (oil, gas) or the presence or absence of concen trated 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 SO 2 

### generated from the oil, NCG/SOGs, or lime mud was captured within the kiln. For kilns with wet scrubbers (majority) that have high SO 2 

### emissions, alkali addition to the scrubbing fluid could further reduce the SO 2 

### 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. Mechan ical 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 μ m.

Kraft lime kiln PM emissions are typically cont rolled 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 SO 2 

### . The wet scrubber acts as an

additional alkaline SO 2 

### scrubber since it captures alkaline PM leaving the kiln. Just as for recovery furnaces, with the implementation of MA CT II limitations in 2004, most lime kilns are operating at or below NSPS levels. Any a dditional 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 ma y 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.June 4, 2006 7

National Council for Air and Stream Improvement 

### 4.1 Natural Gas-Fired Boilers

Gas-fired boilers are usually not equi pped with particulate collectors. SO 2 

### emissions depend on the sulfur content of the gas, which is typically negligible. NO

x 

### 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 NO

x 

### formed in natural gas-fired boilers and turbines. The two most prev alent ones are flue gas recirculation (FGR) and

low-NO

x 

### burners. FGR reduces formation of thermal NO

x 

### by reducing peak temperatures and limiting availability of oxygen. Low-NO

x 

### burners reduce formation of thermal NO

x 

### by delayed combustion (staging) resulting in a cooler flame. In conjunction with FGR, the burners can

achieve NO

x 

### emission reductions of 60 to 90%. Othe r techniques include staged combustion and gas reburning. In general, these techniques have been incorporated in newer boilers and thus

their NO

x 

### emissions are lower than those of older units.

There are also add-on control technologies that can reduce NO

x 

### emissions from gas-fired boilers such as selective non-catalytic reduction (SN CR) and selective catalytic reduction (SCR). However, since most of the pulp and paper indus try 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-combusti on control. Fuel substitution reduces SO 2 

### and NO

x 

### and involves burning an oil with lower S or N c ontent, respectively. Particulate emissions are lower when burning lower sulfur content oils, especially distillate oil.

4.2.1 NO

x 

### Control

For boilers burning residual oil, fuel NO

x 

### is the dominant mechanism for NO

x 

### 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 NO

x 

### formed in fuel oil-fired boilers, including low excess air, burners out of service, biased-burner firing, flue gas recirculation, overfire air, and low-NO

x 

### burners. NO

x 

### 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. NO

x 

### 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 th e 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 SO 2 

### Control

SO 2 

### emissions are controlled by a number of commercialized post-combustion flue gas desulfurization (FGD) processes which u se an alkaline reagent to absorb SO 2 

### in the flue gas and produce a sodium or calcium sulfate compound. Th e FGD technologies may be wet, semi-dry or dry depending on the state of the reagent as it leaves the absorber vessel.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 NO

x 

### Control

NO

x 

### emissions from coal-fired boilers can be controlled by a) combustion controls and b) postcombustion controls. Combustion controls invol ve 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-NO

x 

### burners and overfire air (OFA) have been successfully applied to tangential- and wa ll-fired units, whereas reburning is the only current option for cyclone boilers. For large base-load ed coal-fired boilers, the most developed and widely applied post-combustion NO

x 

### control technology is SCR. Catalyst deactivation and

residual NH 3 

### slip are the two key operating considera tions in an SCR system. There is only limited experience with the use of SNCR systems on industrial coal-fired boilers. NO

x 

### reductionsfrom 30-70% and from 60-90% may be expected from use of SNCR and SCR systems on baseloaded coal-fired boilers, respectively. SNCR h as 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 NO

x 

### 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 SO 2 

### Control

Just as in fuel oil combustion, criteria pollutants can be controlled by fuel substitution/alteration, combustion modification and post-combustion control. SO 2 

### reductions can be achieved by burning a coal with lower S content. SO 2 

### emissions can be controlled by a number of commercialized post-combustion flue gas desulfur ization (FGD) processes which use an alkaline reagent to absorb SO 2 

### in the flue gas and produce a sodium or calcium sulfate compound. The FGD technologies may be wet, semi-dry or dry de pending 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 c onsiderations include space restraints in many

facilities.

4.3.3 Particulate Matter Control

Particulate emissions from coal-fired boilers are cont rolled by using a) ESPs, b) fabric filters (FF) or c) venturi scrubbers. Multi-cyclones are ge nerally used as precleaners upstream of more efficient ESPs or FFs. The key operating parame ters 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. Da ta for ESPs applied to coal-fired boilers showJune 4, 2006 9

National Council for Air and Stream Improvement 

### fractional collection efficiencies greater than 99% for fine (<0.1 μ m) and coarse particles (>10

μ m) and a reduction in collection effici ency for particles between 0.1 and 10 μ m. Operational parameters that affect fabric filter collecti on efficiency include air-to-cloth ratio, operating pressure loss, cleaning sequence, interval be tween 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 μ m particle.

4.4 Wood-Fired Boiler Emissions

4.4.1 NO

x 

### Control

Most large wood-fired boilers used in the pulp and paper industry are of the spreader stoker design. NO

x 

### 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 NO

x 

### controls difficult to implement. Spreader stoker boilers inherently practice staged combustion, which lowers NO

x 

### emissions, but within limits.

Fuel NO

x 

### is the dominant NO

x 

### formation mechanism operative during wood combustion. Fuel

NO

x 

### 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 NO

x 

### .

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% NO

x 

### reduction during periods of air quality problems. The problem with control of the requi red temperature window is an inherent difficulty with use of SNCR for load-following boilers, whet her 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 l east 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 st oker 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 NO

x 

### 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 contro l 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 fe w units. Wet scrubbers are widely used, operating at gas pressure drops ranging from 6 to 25” H 2 

### O. Liquid to gas ratios in the venturi system typically range from 8 to 10 gal H 2 

### O/1000 acfm saturated. Solids buildup in the recirculation loop rarely is allowed to exceed 5% by wei ght. 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 ESPs10 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 ft 2 

### /1000 acfm. Power requirements range from 1 50 to about 400 watts per acfm. To address fire concerns, ESPs on wood-fired boilers are so metimes 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 electri cal 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 bo ilers are combination boilers that may burn other sulfur-containing fuels. Thus, a change in the c ontrol 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 SO 2 

### 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, whic h is largely calcium and sodium carbonates and sulfates. Scrubbers are generally employed to captu re 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 s odium carbonate, followed by sodium sulfate. Roughly 90% (by weight) of the particles ha ve equivalent aerodynamic diameters under 10 μ m, and 50% have diameters under 1 μ m. 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 c ontrol 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.

## APPENDIX C

Public Notice for BART Title V Air Permit Modification

### 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 Qu ality (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 determinati ons 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, 1 st 

### 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 re views 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

### 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 a dditional 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

## APPENDIX D

Draft Air Permit

### 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) speci fied 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 cer tification are contained in General Condition P in

Section 3 of Part I. The current owner is responsible for subm itting 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, a nd 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 adjudicator y 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

### 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 obt ained upon request from the Office of Administrative Hearings. Unless a request for a hearing is made pur suant 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 P ermit issued by the Division of Air Quality prior

to construction. Failure to do so is a violatio n 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 ???, ???? un til 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 con cerning 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

### 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 PlantEmission 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 generato rs used in the fire control system G23066.f-gen One 64 horsepower and one 227 horsepow er 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

## 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 re voked, 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, cond itions, and limitations within th is permit. This permit is issued under the provisions of Article 21B of Chapter 143, Gene ral Statutes of North Carolina as amended, and Title 15A North Carolina Administrative Codes (15A NCAC), S ubchapters 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 submitte d a complete Air Quality Perm it 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

### 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 Li mitations 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 CONDITIONSPermit 08961T?? DRAFT Page 3



# PART I

The Division of Air Quality (DAQ), the United States Environm ental Protection Agency (EPA), and citizens as defined under the Federal Clean Air Act have the authority to enforce the term s, conditions, and limitations contained in Part I of this perm it 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 pe rmit is based on plans, specifications, oper ating 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 po llution control devices and appur tenances:

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 NAPermit 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, oneoxygen blow tank, and postO2 washers

No. 2 Pine Fiberline oxygen delignification system including one O2 reactor, oneoxygen 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 NAPermit 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 NAPermit 08961T?? DRAFT Page 6

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)Permit 08961T?? DRAFT 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 MicroMist TM
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)Permit 08961T?? DRAFT 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)Permit 08961T?? DRAFT Page 9

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 NAPermit 08961T?? DRAFT 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 15 A NCAC 2Q .0503(8).Permit 08961T?? DRAFT Page 11



## 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 de vice(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 st andards for the emission s ource(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 av eraged 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 pr ocedures per Specific Condition 2.2 .C. to insure that

the emissions are routed to either the No. 4 Lime K iln (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.Permit 08961T?? DRAFT 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-mont h 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 st andards for the emission s ource(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 Delig nification System (ID No. G04010).

The following table provides a summary of limits and st andards for the emission s ource(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 .1111Permit 08961T?? DRAFT Page 13



### D. White Liquor Oxidizer (ID No. G04011) equi pped with a chevron demister (ID No. 04-CD021-01)

The following table provides a summary of limits and st andards for the emission s ource(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation

particulate E = 4.10 x P 0.67

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 sha ll 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 pe rform 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 ma intained in a logbook (written or electronic format) on-site and made available to an authorized representativ e 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 mainte nance performed on the demister within 30 days of a written request by the DAQ. f. The Permittee shall submit a summary report of monito ring 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 betw een January and June. All instances of deviations from the requirements of this permit must be clearly identified.Permit 08961T?? DRAFT 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 sh all 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 th e monthly observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-norma l 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 em ission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the lim it 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 correct ed 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 re quest. 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 t hose 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 m onitoring 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.Permit 08961T?? DRAFT Page 15



### BLEACHING (Area 05)

E. The No. 1 Hardwood Fiberline Bleaching System (ID No. G05012) consisting of: a chlorine dioxide stage (D1), extraction st age (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 st age (Eo), final chlorine dioxide stage (D2), towers and filtrate tanks of the pine bleach ing 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 controlle d 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 st andards for the emission s ource(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 .1111Permit 08961T?? DRAFT Page 16



### Chlorine Dioxide Preparation (Area 06)

F. Chlorine dioxide generation syst em (ID No. G06014) consisting of : one R-8 chlorine dioxide generator (ID N o. 06-PU-002) and three chlorine dioxide solution storage tanks (125,000 gallons capa city, 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 ra te, ID No. 06-CD-002-01) either normally in

series with the No. 1 Hardwood Fiberline Bl eaching 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 st andards for the emission s ource(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 cal endar 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 calenda r 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 in strumentation 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 represen tative 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-mont h period between January and June. All instances of deviations from the requirements of this permit must be clearly identified.Permit 08961T?? DRAFT Page 17



### 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 st andards for the emission s ource(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 pr ocedures per Specific Condition 2.2 .C. to insure that

the emissions are routed to either the No. 4 Lime K iln (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-mont h period between January and June. All instances of deviations from the requirements of this permit must be clearly identified.Permit 08961T?? DRAFT Page 18



### H. Eight (8) Weak Black Liquor Storage Tanks (ID No. G07086)

The following table provides a summary of limits and st andards for the emission s ource(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. G 07018) (40CFR60, Subpart BB) consisting of: the Condensate Stripper (ID No. 07-PU-015) a nd associated Stripper Feed Tank (ID No. 07-TK-011) and Reflux Ta nk (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 st andards for the emission s ource(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 pr ovisions, 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 “Gener al 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 pr ocedures 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 nonc ompliance 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 calibra te, maintain, and operate a monitoring device for measuring the combustion temperature at the point of in cineration 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-mont h period between January and June. All instances of deviations from the requirements of this permit must be clearly identified.Permit 08961T?? DRAFT Page 19



### J. Four (4) Heavy Black Liquor Storage Tanks (ID No. G07019)

The following table provides a summary of limits and st andards for the emission s ource(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-ch amber, 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 st andards for the emission s ource(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 Perm ittee 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 frequenc y 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.Permit 08961T?? DRAFT Page 20

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, reco rdkeeping, 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 sh all 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 (writte n 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 dete rmine 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 fu el 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 fu el oil supplier certifications and calculated emission rates postmarked on or before January 30 of each cale ndar 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 requi rements 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 EMISSIONSPermit 08961T?? DRAFT Page 21

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 ma intain 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 ex cluded 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 fro m the determinations in pa ragraphs b.i. and b.ii. above, if the excess emissions are exempted accord ing to the procedures set out in 2D .0535(c). All periods of excess emissions shall be included in the determinations in paragra phs b.i. and b.ii above until such time that the excess emissions are exempt ed 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 m onitoring data postmarked on or before January 30 of each calendar year for the preceding six-month peri od 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, m easured 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, unl ess 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 r ecords are not maintained, the Permittee shall bePermit 08961T?? DRAFT Page 22

deemed in noncompliance with 15A NCAC 2D .0528, ex cept 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-mont h period between January and June. All instances of deviations from the requirements of this permit must be clearly identified.Permit 08961T?? DRAFT Page 23



### 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-fi eld 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 st andards for the emission s ource(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 per cent 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 Perm ittee 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 frequenc y 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 partic ulate 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 Subpa rt MM as specified in the monito ring, recordkeeping, and reporting requirements of Section 2.2 D. However, excess em issions shall be in reported in accordance with 15APermit 08961T?? DRAFT Page 24

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 syst em (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 peri od 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.Permit 08961T?? DRAFT Page 25

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 sh all 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 (writte n 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 dete rmine 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 fu el 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 fu el oil supplier certifications and calculated emission rates postmarked on or before January 30 of each cale ndar 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 requi rements 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, m easured 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, unl ess an alternative monitoring and quality assurance program is approved by the DAQ. The monitoring system downtime shall not exceed 5 percent. If anyPermit 08961T?? DRAFT Page 26

12-hour block average exceeds the limit above or the r ecords are not maintained, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0528, ex cept 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-mont h 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 st andards for the emission s ource(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-sp ecified 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 th e 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 RT O 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 th is 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 notPermit 08961T?? DRAFT Page 27

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 Sec tion 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 sh all 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 su lfur dioxide emissions from the BLOX System (G08022) shall be recorded monthly in a logbook (written or electronic fo rmat), 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-mont h 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 tota led 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 ch evron 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 ch evron 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 st andards for the emission s ource(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 BARTPermit 08961T?? DRAFT Page 28

1. 15A NCAC 2D .0508: PARTICULATES FROM PULP AND PAPER MILLS

a. Emissions from the production of pulp and paper that ar e discharged from these sources into the atmosphere shall not exceed 0.6 pounds of particulate matter per e quivalent 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 th is 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 sha ll 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 th e monthly observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-norma l 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 em ission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the lim it 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 correct ed 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 madePermit 08961T?? DRAFT Page 29

available to an authorized representative upon re quest. 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 t hose 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 m onitoring 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 th e 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 Perm ittee 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 cale ndar year of the effective date of Permit No. 08961T08 unless an alternate date is approved by the DAQ. The te sting 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 m onitoring 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.Permit 08961T?? DRAFT Page 30



### 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 m illion Btu per hour maximum permitted heat input rate, with gas igniters; ID No. G09029) equipped with a 4-stage MicroMist TM



### 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) fr om the Condensate Stripper System (ID No. G07018).

The following table provides a summary of limits and st andards for the emission s ource(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 ar e discharged from these sources into the atmosphere shall not exceed 0.5 pounds of particulate matter per e quivalent 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 Perm ittee 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 - Genera l Condition JJ. Testing shall be completed and the results submitted within the calendar year of the e ffective date of Permit No. 08961T08 unless an alternate date is approved by the DAQ. The testing shall be perform ed 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 th e 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). Particul ate matter emissions from the No. 5 Lime Kiln ( ID

No. G09029 ) shall be controlled by the 4-stage MicroMist TM 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, recordkeep ing, and reporting requirements of Section 2.2 D. However, excess emissions shall be in reported in accordance with 15A NCAC 2D .0535 as outlined inPermit 08961T?? DRAFT Page 31

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 sha ll 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 sh all 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 th e 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 SO 2 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 pe riod 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-mi nute 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 ar e 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 sha ll 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 thePermit 08961T?? DRAFT Page 32

corresponding date and time(s) shall substitute for th e daily observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-nor mal 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 correct ed 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 re quest. 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 t hose 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 m onitoring 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 aver aged 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 su lfide, 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 lim it 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, sha ll 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-mont h 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:Permit 08961T?? DRAFT Page 33



### 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 st andards for the emission s ource(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 sha ll 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 th e 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 Permitt ee 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 represen tative 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 pe riod 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 notmore than once in any hour and not more than four times in any 24-hour period. In no event shall the sixPermit 08961T?? DRAFT Page 34

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 sh all 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 th e monthly observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-norma l 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 em ission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the lim it 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 correct ed 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 re quest. 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 t hose 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 pe riod 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.Permit 08961T?? DRAFT Page 35



### 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 st andards for the emission s ource(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 these sources sha ll 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 Perm ittee 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 represen tative 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 pe riod 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.Permit 08961T?? DRAFT Page 36

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 sh all 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 th e monthly observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-norma l 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 em ission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the lim it 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 correct ed 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 re quest. 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 t hose 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 pe riod 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 st andards for the emission s ource(s) described above:

Regulated Pollutant Limits/Standards Applicable Regulation

Toxic Air Pollutants State Enforceable Only (See Section 2.3.A.) 15A NCAC 2D .1100Permit 08961T?? DRAFT Page 37



### 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 st andards for the emission s ource(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 sour ces 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 th e 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 fl owmeter on each scrubber. To ensure compliance and the effective operation of the scrubbers, the Permitt ee 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 authori zed 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 re quired 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 prescr ibed operating range for the scrubber(s); andPermit 08961T?? DRAFT Page 38

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-mont h 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 mo re 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 peri od. 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 sh all 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 th e monthly observation. The Permittee shall establish “normal” for the source in the first 30 days followi ng 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-norma l 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 em ission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8) is below the lim it 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 correct ed 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 re quest. 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 t hose 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 pe riod 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.Permit 08961T?? DRAFT Page 39



### POWER (Area 11)

T. Power Boilers:

Coal -fired Big Bill utility boiler (364 million Bt u 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 millio n 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 st andards for the emission s ource(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 Mon itoring Requirements

(40 CFR 51, Appendix P) 15A NCAC 2D .0606

sulfur dioxide Monitoring Requirements (See Condition 2.1 T. 2) 15A NCAC 2D .0608Permit 08961T?? DRAFT Page 40

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 testi ng 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 alternat e date is approved by the DAQ. The testing shall be performed annually thereafter. If the results of the tes ting demonstrate results at less than 80 percent of the limit above, the testing frequency may reduced to every perm it 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 controlledby 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 parame ters 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 perm it 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 outsi de the prescribed range, the Permittee shall inspect the ESP for malfunctions, take the necessary measures to co rrect any problems, and return the parameter to the proper range within the monitoring period.

Notwithstanding any prior reduced testing frequency a llowed 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 Pe rmittee 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 monitori ng 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.Permit 08961T?? DRAFT Page 41

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 pe riod 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 fo rmed 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 sh all monitor the sulfur content and heat content of the coal by using coal supplier certification per total ship ment received. The results of the coal supplier certifications shall be recorded in a logbook (writte n or electronic format) and include the following

information: i. the name of the coal supplier; ii. a statement verifying that the methods used to dete rmine 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 nonc ompliance 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 y ear 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 require ments 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 th e limit given in Section 2.1 T. 3. a. above, the PermitteePermit 08961T?? DRAFT Page 42

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 th e 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 ove r 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 ma intain 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 ex cluded 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 fro m the determinations in pa ragraphs b.i. and b.ii. above, if the excess emissions are exempted accord ing to the procedures set out in 2D .0535(c). All periods of excess emissions shall be included in the determinations in paragra phs b.i. and b.ii above until such time that the excess emissions are exempt ed 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 m onitoring data postmarked on or before January 30 of each calendar year for the preceding six-month peri od 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 electrosta tic precipitators. These sources shall be deemed toPermit 08961T?? DRAFT Page 43

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, adju sted for monitor downtime (MD) as calculated below. In addition, these sources shall be deemed to be pr operly 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 m onitor 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 fo r 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.Permit 08961T?? DRAFT Page 44



### 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 NO X 

### burner components, a Separated Over Fire Air (SOFA) system, a urea-based Selective Non-Catalytic Reduction (SNCR) NO X 

### emission reduction system (ID No. 11-CD-006-02), a nd 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 st andards for the emission s ource(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 = [(E

c )(Q

c ) + (E

o )(Q

o )]/Q t 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 .0530Permit 08961T?? DRAFT Page 45

1. 15A NCAC 2D .0519: CONTROL OF NITROGEN OXIDES EMISSIONS

a. Emissions of nitrogen oxides from these sources wh en 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 ar e 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 PERFORM ANCE STANDARDS (40 CFR PART 60 SUBPART D)

a. The Permittee shall comply with all applicable pr ovisions, 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 CF R 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.Permit 08961T?? DRAFT Page 46

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 w ithin the 180 days of the effective date of Permit No. 08961T08 unless an alternate date is approved by th e DAQ. The testing shall be performed annually thereafter. If the results of the testing demonstrat e 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 sh all 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 perm it 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 outsi de the prescribed range, the Permittee shall inspect the ESP for malfunctions, take the necessary measures to co rrect any problems, and return the parameter to the

proper range.

Notwithstanding any prior reduced testing frequency a llowed 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 Pe rmittee 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 monitori ng 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 fo r good operation and maintenance (O&M) practices in accordance with 40 CFR Part 60, Subpart A, Secti on 60.11(d); Subpart D, Section 60.45; and the EPA Region IV Continuous Emission Monitor Enforcement Plan (CEP).Permit 08961T?? DRAFT Page 47

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 di oxide emissions by fuel sampling and analysis. m. As required by 15A NCAC 2D .0524 under 40 CFR Subpa rt D, 60.45, to assure compliance, the Permittee

shall monitor the sulfur and heat content of all th e 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 dete rmine 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. Th e 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 em ission rate (pounds per million Btu heat input) shall be

calculated in accordance with with Method 19 of 40 CF R 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 Subpa rt D, 60.45, to assure compliance, the Permittee

shall monitor the sulfur content and heat content of th e 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 dete rmine 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 requi rements 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)Permit 08961T?? DRAFT Page 48

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 oxide s standard in Section 2.1.U.2.b above shall be determined based on any three-hour period during whic h the average emissions (arithmetic average of three contiguous one-hour periods) exceed the applicable standard.

When operated outside of the timeframe required unde r 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-mont h 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 fo llowing 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 fu el 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 pe riod 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.Permit 08961T?? DRAFT Page 49



### 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 diamet er 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 Mon itoring 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 Secti on 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 th e monitoring, recordkeeping, and reporting requirements per Specific Conditions 2.1 V. 2. d-h. The Permittee sh all be deemed in noncompliance with 2D .0503 if the monitoring and recordkeeping is not maintained.Permit 08961T?? DRAFT Page 50

2. 15A NCAC 2D .0504: PARTICULATES FROM WOOD BURNING INDIRECT HEAT EXCHANGERS

a. Emissions of particulate matter from this source sha ll 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 Secti on 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 Perm ittee shall demonstrate compliance with the emission limit(s) above by testing the boiler for particulate ma tter in accordance with a testing protocol approved by the DAQ. Details of the emissions testing and repor ting 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 te sting 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 ma intain 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 sour ce(s) is not operating, a record of this fact along with the corresponding date and time shall substitute for th e 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 prescr ibed value(s) or if these records are not maintained. e. If the scrubber liquid flow rate or pressure drop readi ngs 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, di scussed 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 prescrib ed 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 orPermit 08961T?? DRAFT Page 51

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-mont h 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 sh all monitor the sulfur content and heat content of the coal by using coal supplier certification per total ship ment received. The results of the coal supplier certifications shall be recorded in a logbook (writte n or electronic format) and include the following

information: i. the name of the coal supplier; ii. a statement verifying that the methods used to dete rmine 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 ra te (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 nonc ompliance 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 y ear 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 require ments 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 wh en 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 hourPermit 08961T?? DRAFT Page 52

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 ar e 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 ma intain 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 ex cluded 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 fro m the determinations in pa ragraphs b.i. and b.ii. above, if the excess emissions are exempted accord ing to the procedures set out in 2D .0535(c). All periods of excess emissions shall be included in the determinations in paragra phs b.i. and b.ii above until such time that the excess emissions are exempt ed 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 ar e 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 m onitoring data postmarked on or before January 30 of each calendar year for the preceding six-month peri od 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)Permit 08961T?? DRAFT Page 53

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 Ba rk 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 monito rs 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 multicyc lone and scrubber. These sources shall be deemed to be properly operated and maintained if the percenta ge 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, adju sted for monitor downtime (MD) as calculated below. In addition, these sources shall be deemed to be pr operly 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 m onitor 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 fo r 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 peri ods due to unreliability of the COMS on the Riley Bark Boiler due to uncombined water in the stack shall be clearly identified.Permit 08961T?? DRAFT Page 54



### 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 st andards for the emission s ource(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 s ources 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 cy clone 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’ a nd cyclones’ structural integrity.

The Permittee shall be deemed in noncompliance with 15A NCAC 2D .0 515 if the ductwork, bagfilters, and cyclones are not inspected and maintained.

d. The results of inspection and mainte nance shall be maintained in a logbook (written or electronic format)

on-site and made available to an authorized representative upon re quest. 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 mainte nance 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 monitori ng 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 betw een January and June. All instances of deviationsPermit 08961T?? DRAFT Page 55

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-mi nute 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 sh all observe the emission points of the sources for any

visible emissions above normal. The Permittee shall esta blish “normal” for the source in the first 30 days following the effective date of permit 08961T08. If vi sible emissions from any source are observed to be above normal, the Permittee shall either: i. take appropriate action to correct the above-norma l 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 em ission 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 correct ed 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 re quest. 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 t hose 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 obs ervations 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.Permit 08961T?? DRAFT Page 56



### 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 st andards for the emission s ource(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, a nd 13-CD-020-01), respectively.

The following table provides a summary of limits and st andards for the emission s ource(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 s ources 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 a ssure 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 represen tative 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.Permit 08961T?? DRAFT Page 57

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 obs ervations 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 mo re than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may ex ceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no even t 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 th is 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 sh all observe the emission points of the sources for any

visible emissions above normal. The Permittee shall esta blish a “normal” for the source in the first 30 days following the effective date of permit 08961T08. If vi sible emissions from any source are observed to be above normal, the Permittee shall either: i. take appropriate action to correct the above-norma l 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 em ission 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 correct ed 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 re quest. 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 t hose 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 obs ervations 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.Permit 08961T?? DRAFT Page 58



### WASTEWATER TREATMENT PLANT (Area 16)

Z. WTP Primary Clarifiers (ID No. G16081) a nd WTP Aeration and Digestion Basins (ID No. G16082)

The following table provides a summary of limits and st andards for the emission s ource(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. G 19058) and Rewinders on Trim System #2 (ID No. G19059)

The following table provides a summary of limits and st andards for the emission s ource(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 s ources 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 peri od. 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 sh all observe the emission points of the sources for anyPermit 08961T?? DRAFT Page 59

visible emissions above normal. The Permittee shall esta blish a “normal” for the source in the first 30 days following the effective date of permit 08961T08. If vi sible emissions from any source are observed to be above normal, the Permittee shall either: i. take appropriate action to correct the above-norma l 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 em ission 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 correct ed 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 re quest. 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 t hose 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 obs ervations postmarked on or before January 30 of each calendar year for the preceding six-month period betw een 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.Permit 08961T?? DRAFT Page 60



### 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 st andards for the emission s ource(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 st andards for the emission s ource(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 N o. G24087) and No. 2 Pine Fiberline Deckers (ID No. G24088)

The following table provides a summary of limits and st andards for the emission s ource(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 st andards for the emission s ource(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 s ources 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 hourPermit 08961T?? DRAFT Page 61

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 th e 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 th e 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 mo re 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 peri od. 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 th e 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 pr ovisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard

15A NCAC 2D .1111 “Maximum Achievable Control T echnology” (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.Permit 08961T?? DRAFT Page 62



## 2.2- Multiple Emission Sources Specific Limitations and Conditions

A. Prevention of Significant Deteri oration (PSD) BACT-affected Sources:

1. 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION

a. The Permittee shall comply with all applicable pr ovisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements in accordance with 15A NCAC 2D .0530, “Prevention of Significant Deterioration of Air Quality” as prom ulgated 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, Pe ter 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, Pete r 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 th e 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 Perm ittee shall demonstrate compliance with the emission limit(s) above by utilizing the test results of the par ticulate matter testing requi red 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 monito red and recorded (in written or electronic format):

i. the monthly usage of all fuels burned at the fac ility, 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 r ecordkeeping 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.Permit 08961T?? DRAFT Page 63

Reporting [15A NCAC 2Q .0508(f)] f. The Permittee shall submit a summary report, accepta ble 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 preced ing 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, R iley 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 th e 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 monito red and recorded (in written or electronic format): i. the monthly usage of all fuels burned at the fac ility, 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 da ta shall utilize fuel sulfur sampling results for coal and fuel oil. The emissions shall be provided fo r 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, accepta ble 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 preced ing 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.Permit 08961T?? DRAFT Page 64



### 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 Sept ember 30, 2004 ozone season and the May 1st through September 30th ozone seasons thereafter, from the aff ected sources as summarized in the table below:

Source NO X Emission Allocations (tons/ozone season)

2004 NO X Emission Allocations (tons/ozone season)

2005 NO X 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 re quirements 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 comply ing 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 th e procedures and schedules in this Section and in Subchapter 2Q of this Title instead of the pro cedures 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 sha ll 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 comp liance 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 manne r 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 opera ting 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.Permit 08961T?? DRAFT Page 65



### 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 (ClO 2 ) Stage Tower

ES 05-PU-004 D1 (ClO 2 ) Stage Washer

ES 05-TK-003 D1 (ClO 2 ) Stage Filtrate Tank

ES 05-PU-010 D2 (ClO 2 ) Stage Tower

ES 05-PU-012 D2 (ClO 2 ) Stage Washer

ES 05-TK-011 D2 (ClO 2 ) 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 (ClO 2 ) Stage Tower

ES 05-TK-018 D1 (ClO 2 ) Stage Filtrate Tank

ES 05-PU-021 D2 (ClO 2 ) Stage Tower

ES 05-TK-027 D2 (ClO 2 ) Stage Filtrate Tank 05-CD-017-01 No.2 Pine Fiberline Bleach Plant Wet Scrubber (via closed-vent collection system)Permit 08961T?? DRAFT Page 66



### 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)Permit 08961T?? DRAFT Page 67



### 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-O 2 Feed Tank No. 1

ES 03-TL-016 Pre-O 2 Feed Tank No. 2

ES 03-TL-017 Pre-O 2 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 O 2 Blow Tank

ES 04-PU-002 Post O 2 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 O 2 Blow Tank

ES 04-PU-016 Post O 2 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 NAPermit 08961T?? DRAFT Page 68



### C. 40 CFR 63, Subpart S Affected Sources, continued:

The following table provides a summary of limits and st andards for the emission s ource(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 pr ovisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard

15A NCAC 2D .1111 “Maximum Achievable Control T echnology” (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 Bl each 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.Permit 08961T?? DRAFT Page 69

d. Except as specified in Specific Condition 2.2.C.2, th e 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 Cond ition 2.2.C.2 or 40 CFR 63.443, each HVLC system component shall be enclosed and vented into a clos ed 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 deck er 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 pe riods 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 i ndividual 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 tota l 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 us ed 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) provi ded that the time of excess emissions (includingperiods 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 (C MS), 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 ma intained [40 CFR 60, Subpart 63.453]: i. The minimum pH of the scrubber's efflue nt 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 fo r 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.Permit 08961T?? DRAFT Page 70

The Permittee shall install, calibrate, certify, operate, and maintain according to the manufacturer's specifications, a continuous monitoring system (C MS), 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 ma intained [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 fo r 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 opera ted to ensure the following operational parameters are maintained on a 15-day rolling average of stri pper 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 ro lling 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 sh all be equal to or greater than 161Deg. F; and iii. Steam feed to the Foul Condensate Stripper sh all 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 take n for that event for inclusion in the semiannual SSM report. The Permittee shall be deemed in noncomplian ce 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 procedur es specified in the facility's SSM plan, the PermitteePermit 08961T?? DRAFT Page 71

shall keep records for that event that demonstrate th at 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 betw een 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 identifie d. 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 requireme nts 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 provi sions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A

NCAC 2D .1111 “Maximum Achievable Control Tec hnology” (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 defi ned in 40 CFR 63.3 [15A NCAC 2D .1111].

The authority for the alternate control requirements fo r Equivalency by Permit (EBP) is given in 40 CFR parts 63.91 63.94, and 63.99 as promulgated in “Approval of S ection 112(l) Authority for Hazardous Air Pollutants; Equivalency by Permit Provisions; National Emission Sta ndards 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 HV LC 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-O 2 Washer Feed Tank No. 1 (ID No. ES-03-TL-015);

Pre-O 2 Washer Feed Tank No. 2 (ID No. ES-03-TL-016);

Pre-O 2 Washer Feed Tank No. 3 (ID No. ES-03-TL-017); and

The Oxygen Delignification Systems (G04009 and G04010) Sources : HW O 2 Blow Tank (ID No. ES-04-TK-005);

HW Post O 2 Washer (ID No. ES-04-PU-002); and

HW Post O 2 Filtrate Chest (ID No. ES-04-TK-008);

Pine O 2 Blow Tank (ID No. ES-04-TK-018); and

Pine Post O 2 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 m eet 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 thePermit 08961T?? DRAFT Page 72

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 therma l oxidizer designed and operated at a minimum temperature of 871°C (1600°F) and a mi nimum 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 pe riods 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 re duce the total HAP emissions from the BLOX system.

When excess emissions exceed the level set forth in Sec tion 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 opera te 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 accord ance 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 sha ll 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 pe rmit and with the requirements of 40 CFR 63.457.

ii. If emission testing is required for parity demonstr ation, 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) determ ining 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 Pe rmittee 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 te mperature in the thermal oxidizer firebox or in the ductwork immediately downstream of the firebox and befo re any substantial heat exchange occurs. The CMS

shall include a continuous recorder. The CMS sha ll be operated to ensure the following operational parameters are maintained [40 CF R 63, Subpart 63.453 and 40 CFR 63.94]:Permit 08961T?? DRAFT Page 73

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 c onducted 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 comp ly with paragraph 2.2 C.2.b.i.A, the minimum operating temperature shall be established during tes ting conducted per 2.2 C.2.f. This permit shall be administratively amended to incorporate the new mi nimum 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 add itional approved testing performed per 2.2 C.2.f. This permit shall be admi nistratively amended to incorporate the new minimum operating temperature determined during this add itional 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 clos ed 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 a nd 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 take n 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 procedur es specified in the facility's SSM plan, the Permittee shall keep records for that event that demonstrate th at 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 J une 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 paramete r have occurred, such information shall be included in the report. This report shall also include th e 12-month rolling average percent hardwood pulp production for each month in the reporting period, or the aver age 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 requireme nts 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 cont aining, 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.Permit 08961T?? DRAFT Page 74Permit 08961T?? DRAFT Page 75



### 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 st andards for the emission s ource(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 pr ovisions, including the notification, testing, reporting, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard

15A NCAC 2D .1111 “Maximum Achievable Control T echnology” (MACT) as promulgated in 40 CFR Part 63 Subpart MM, including Subpart A “General Provisi ons” as defined per 63.440(g) and indicated per Table 1 of Subpart MM. As outlined in Table 1, pe r 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 sec tion are defined in the Clean Air Act as amended in

1990 and in 40 CFR 63.2 and 63.861. Units and abbreviati ons are defined in 40 CFR 63.3. [15A NCAC 2D .1111]Permit 08961T?? DRAFT Page 76

Emission Limitations [15A NCAC 2D .1111]

b. Emissions of PM from the Nos. 4 and 5 Lime Kiln s, 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

EL PM Bubble Limit for MACT MM lb/ton BLS 1.490 (Eqn 1 in MACT MM )

No. 10 Recovery Furnace No 10 (RF10)

ER RF 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

C EL, RF emission limit for RF10 gr/dscf 0.032 mill-specific Q RF measured stack flowrate from RF10 dscfm 176,354 mill-specific

BLS RF measured BLS firing rate of RF10 ton BLS/d 1,405 mill-specific No. 11 Recovery Furnace (RF11)

ER RF emission limit for RF11 lb/ton BLS 0.785 (Eqn 2 in MACT MM )

C EL, RF emission limit for RF11 gr/dscf 0.032 mill-specific Q RF measured stack flowrate from RF11 dscfm 163,503 mill-specific

BLS RF measured BLS firing rate of RF11 ton BLS/d 1,373 mill-specific

PR RFtot total BLS firing rates, all RF's ton BLS/d 2,778 (BLS RF1 ) +...+ (BLS RFi )

ER RFtot calculated emission rate, all RF's lb/ton BLS 0.807 (Eqn 5 in MACT MM )

No. 10 Smelt Dissolving Tank (SDT-10)

ER SDT emission limit for SDT-10 lb/ton BLS 0.400 (Eqn 3 in MACT MM )

C EL, SDT emission limit for SDT-10 gr/dscf 0.268 mill-specific Q SDT measured stack flowrate from SDT-10 dscfm 10,183 mill-specific

BLS SDT measured BLS firing rate of RF10*100% ton BLS/d 1,405 mill-specific No. 11 Smelt Dissolving Tank (SDT-11)

ER SDT emission limit for SDT-11 lb/ton BLS 0.399 (Eqn 3 in MACT MM )

C EL, SDT emission limit for SDT-11 gr/dscf 0.239 mill-specific Q SDT measured stack flowrate from SDT-11 dscfm 11,115 mill-specific

BLS SDT measured BLS firing rate of RF11*100% ton BLS/d 1,373 mill-specific

PR SDTtot total BLS firing rates, all RF's ton BLS/d 2,778 same as PR RFtot ER SDTtot calculated emission rate, all SDT's lb/ton BLS 0.399 (Eqn 5 in MACT MM )

No. 4 Lime Kiln (LK-4)

ER LK emission limit for LK-4 lb/ton BLS 0.295 (Eqn 4 in MACT MM )

C EL, LK emission limit for LK-4 gr/dscf 0.100 mill-specific Q LK measured stack flowrate from LK-4 dscfm 13,557 mill-specific

CaO LK measured lime production from LK-4 ton CaO/d 89 mill-specific

BLS tot total BLS firing rates, all RF's ton BLS/d 2,778 No. 5 Lime Kiln (LK-5)

ER LK emission limit for LK-5 lb/ton BLS 0.277 (Eqn 4 in MACT MM )

C EL, LK emission limit for LK-5 gr/dscf 0.100 mill-specific Q LK measured stack flowrate from LK-5 dscfm 24,681 mill-specific

CaO LK measured lime production from LK-5 ton CaO/d 173 mill-specific

PR LKtot (CaO tot ) total lime production, all LK's ton CaO/d 262 (CaO LK1 ) + ...+ (CaO LKi )

ER LKtot 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 )Permit 08961T?? DRAFT Page 77

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 ch emical 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 thes e 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 ope rate 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 succe ssive 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 meas urement 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 r ecorded during the initial performance tests or conduct additional performance tests for the specific purpose of es tablishing 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 a nd 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 operati ng ranges during subsequent performance tests using

the test methods in 63.865. The Permittee must c ontinuously 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 ac tion, as specified in the startup, shutdown, and malfunction plan prepared under 63.866(a), if the fo llowing 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.Permit 08961T?? DRAFT Page 78

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 [P T0018] shall be no less than 20 in. H 2 O (3-hour average).

No. 5 Lime Kiln 1. Scrubber venturi liquid flow [FT3173] sha ll 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. H 2 O (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 H 2 O.

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 H 2 O.

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 maintaini ng 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 inform ation 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 not ed 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 unde r condition 2.2.D.1.f, including any period when the operating parameter levels were in consistent with the levels esta blished 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 cond ition 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)]:Permit 08961T?? DRAFT Page 79

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 th e No. 10 or No. 11 Recovery Furnace during any 24-hour averaging period by more than 10 percent above the le vel 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 Disso lving Tanks and resubmit the documentation required

in 63.865 to the Director. All modified PM emissi ons limits are subject to approval by the Director. [63.867(b)]

p. The Permittee must report quarterly if measured parame ters 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 exceed ed the conditions in condition 2.2.D.1.h, and the

number and duration of occurrences when the source me t or exceeded the conditions in condition 2.2.D.1.i. All instances of deviations from the requirements of th is 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 occu rred, 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.Permit 08961T?? DRAFT Page 80



### 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 LI MITATION 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 NC AC 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 cont rol 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].