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‐ 2014 Draft Questions on Domtar’s 114 Responses

General Questions

 Domtar’s response to EPA states it “objects to each and every instruction and request to the extent that it seeks information protected by attorney/client privilege, the attorney work product doctrine, or any other applicable privilege or restri ction, and Domtar has not included in this response c opies of any such documents protected by such privileges, doctrines, or restrictions.”

- EPA would like clarification as to whethe r certain documents were withheld? Can Domtar give a brief description of the content of those documents?

 There are a couple of vendor proposals provided to us by Domtar that say “business confidential,” it looks like th at designation was made by the vendor. Is Domtar claiming
that these documents are CBI? ( i.e., Document “ASHDOWN-A5-000001” (Turbosonic Evaluation))

 Fuels burned at the No. 1 Power Boiler duri ng the 2009-2011 baseline period were bark, gas, TDF, fuel oil, and fuel cubes. Can you explain what fuel cubes are?

 Fuels burned at the No. 2 Power Boiler duri ng the 2001-2003 baseline were coal, bark, natural gas, TDF, and fuel cubes. Some of the documents provided, including the Lundberg Report stated that you also “plan on burning fuel oil in the future.”

- How does Domtar expect this would affect the boiler’s emissions profile? Does Domtar expect to burn less bark or le ss coal, and burn fuel oil in its place?

Response to Request No. 1 and No. 4

 EPA asked for information related to the c ontrol efficiency of the existing venturi
scrubbers at the No. 2 Power Boiler for th e dates Jan 2001 – Dec 2003. In your response you stated there is no such information available.

- File titled “ASHDOWN-Q1-002323” (2001 Emissions Inventory Forms), p. 7 states the scrubber control e fficiency for SO2 removal at the No. 2 Power Boiler is 98%.

- File titled “ASHDOWN-Q5-000001” (Turbos onic Evaluation), says that the scrubbers were designed to achieve 43% SO 2 removal efficiency, and when tested in 2010 were found to achieve 18% removal efficiency.

- In the SO2 BART analysis Domtar pr ovided, 90% SO2 removal efficiency was assumed. How did Domtar arrive at 90% removal efficiency?

 Excel file “ASHDOWN-Q1-002772” (Monthly Emission Rates), under the first tab, which is titled “Monthly Emission Rates,” fo r the No. 1 Power Boile r, the SO2 monthly average emissions for the 2009-2011 baseline period were overall low. Monthly average emission rates were under 1 lb/hr, with th e exception of a few outliers- Jan + Feb 2009, and Jan 2010 during which the monthly aver age emissions were between 30-43 lb/hr.8

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‐ 2014 Draft Questions on Domtar’s 114 Responses

- Looking at the Excel files with fuel usage data, it looks like those outliers occurred when the boiler was burning fuel oil. It appears that those three outliers were the only 3 months during which fu el oil was burned at the No. 1 Power Boiler during the baseline period. Does Do mtar expect that Power Boiler No. 1 will be burning fuel oil in la rge quantities in the future?

Response to Request No. 5

 In Domtar’s response to Request No. 5, it st ated that any improvement in SO2 removal efficiency from upgrading the existing ventur i scrubbers at the No. 2 Power Boiler would be achieved by installing a new ID fan and increasing the pressure drop, and any improvement in efficiency is not sufficiently quantifiable

- By “not sufficiently quantifiable,” do es Domtar mean that the expected improvement is so small its negligible , or do you mean that there’s no way for you to accurately estimate the improvement you would get from doing the upgrades?

Response to Request No. 6

 The revised BART analysis dated May 16, 2014 e xplains that there is “no existing clear property or adequate struct ure to support the add-on scrubber” for the No. 2 Power Boiler, and so you would have to do some c onstruction and possibly expand the building to make space for the add-on scrubber. From l ooking at the cost evaluation, there is not enough breakdown of costs to be able to tell if any expenses related to making room for the add on scrubber are already included in the cost estimate. Please clarify if they are already included?

Response to Request No. 8

 In the June 29, 2012 proposal Fuel Tech pr ovided for SNCR, they looked at 32.5% and 45% reduction for the No. 1 Power Boiler and 27.5% and 35% for the No. 2 Power Boiler. How did Fuel Tech decide what levels of control to look at? Were these removal efficiency guarantees?

 The Fuel Tech proposal appears to suggest th ey believe SNCR is technically feasible, yet it appears that Domtar has uncertainty in th e level of control SNCR can achieve? Based on your BART analysis and your responses it appears that this is main ly related to the fact that SNCR has a much lower rem oval efficiency for swing boilers.

- But Domtar’s air permit, under the “Proce ss Description” section says the No. 2 Power Boiler is normally base-loaded (but can be operated as a swing boiler as well).

Response to Request No. 78

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‐ 2014 Draft Questions on Domtar’s 114 Responses

 In Domtar’s response to this request, it st ated that for NOx BART for the No. 2 Power Boiler, Domtar considered only the installati on of either Low NOx burners or SNCR, not the combination of the two. Domtar also states that the effectiveness of this combination of controls is difficult to eval uate. Is this related to Domtar’s uncertainty as to what removal efficiency SNCR can achieve for this type of boiler?