8‐4‐2014

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 restriction, and Domtar has 

not included in this response copies of any such documents protected by such privileges, 

doctrines, or restrictions.” 

- EPA would like clarification as to whether 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 that 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 during 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 during 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 less coal, and burn fuel oil in its place?

Response to Request No. 1 and No. 4 

 EPA asked for information related to the control efficiency of the existing venturi 

scrubbers at the No. 2 Power Boiler for the 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 efficiency for SO2 removal at the No. 2 Power Boiler is 

98%. 

- File titled “ASHDOWN-Q5-000001” (Turbosonic Evaluation), says that the 

scrubbers were designed to achieve 43% SO2 removal efficiency, and when tested 

in 2010 were found to achieve 18% removal efficiency. 

- In the SO2 BART analysis Domtar provided, 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,” for the No. 1 Power Boiler, the SO2 monthly 

average emissions for the 2009-2011 baseline period were overall low. Monthly average 

emission rates were under 1 lb/hr, with the exception of a few outliers- Jan + Feb 2009, 

and Jan 2010 during which the monthly average emissions were between 30-43 lb/hr. 
8‐4‐2014

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 fuel oil was burned at the No. 1 Power 

Boiler during the baseline period. Does Domtar expect that Power Boiler No. 1 

will be burning fuel oil in large quantities in the future? 

Response to Request No. 5 

 In Domtar’s response to Request No. 5, it stated that any improvement in SO2 removal 

efficiency from upgrading the existing venturi 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,” does 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 explains that there is “no existing clear 

property or adequate structure to support the add-on scrubber” for the No. 2 Power 

Boiler, and so you would have to do some construction and possibly expand the building 

to make space for the add-on scrubber. From looking 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 provided 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 they believe SNCR is technically feasible, yet 

it appears that Domtar has uncertainty in the level of control SNCR can achieve? Based 

on your BART analysis and your responses it appears that this is mainly related to the 

fact that SNCR has a much lower removal efficiency for swing boilers. 

- But Domtar’s air permit, under the “Process 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. 7 
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Draft Questions on Domtar’s 114 Responses

 In Domtar’s response to this request, it stated that for NOx BART for the No. 2 Power 

Boiler, Domtar considered only the installation 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 evaluate. Is this related to Domtar’s uncertainty as to what 

removal efficiency SNCR can achieve for this type of boiler?