OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

MEMORANDUM March 24, 2010

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager, Air Quality Division

THROUGH: Kendal Stegmann, Senior Environmental Manager, Compliance and Enforcement

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review

FROM: Dale Becker, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 97-057-TV (M-10) International Paper - IP Valliant Paper Mill Valliant, McCurtain County, Oklahoma Secs. 26, 27, 28, 33 and 34-T6S-R21E, Lat 33.998  ̊ , Long-95.113  ̊ UTM Zone 15,306.50 Km Easting by 3,763.50 Km Northing
Located One Mile West of Valliant on US-70

SECTION I. INTRODUCTION

International Paper has applied fo r a modification to the Part 70 permit for the IP Valliant Paper Mill (Valliant). The fa cility is currently operating as authorized by Permit No. 97-057-TV.

The proposed modification was submitted to addr ess the Best Available Retrofit Technology (BART) requirements contained in the regional haze program found in Title 40 Part 51, Subpart P, of the Clean Air Act and Subchapter 8, Part 11 of the Oklahoma Admini strative Code (OAC). Facilities with affected equipment were require d to either submit an application for a waiver from BART by December 1, 2006 or to submit a BART determination by March 30, 2007. However, facilities required to submit a perm it application requesting enforceable limits to qualify for a waiver were granted until March 30, 2007 to submit an application. A facility can apply for a waiver if it can be demonstrated through modeling that the affected sources do not

cause or contribute to visibility impairment in any manda tory Class I Federal area. These modeling thresholds are found in OAC 252:100-8-73. Facilities are required to be in compliance with any BART requirements within 5 years of EPA approval of the Oklahoma regional haze State Implementation Plan (SIP).

International Paper conducted a re view of the impact on Class I area s by the affected sources at the Valliant plant. This review indicated that Valliant could cont rol their affected equipment and apply enforceable limits in order to assure the affected sources do not cause or contribute to visibility impairment in any mandatory Class I Fe deral area. Valliant submitted an application to include the limits in its Title V permits which assu re that the facility qualifies for a waiver ofPERMIT MEMORANDUM 97-057-TV (M-10) - 2 -

BART requirements on December 1, 2006; w ith updates received March 30, 2007, August 25, 2008, September 15, 2009 and December 10, 2009. The Title V memorandum and permit have been updated to include the BART requirements.

Valliant has also requested other minor modifications to the facility:

1. On November 18, 2008 the facility requested aut horization to blend small quantities of ultra low sulfur distillate fuel oil into the black liquor fired in the New Recovery Furnace (EUG D6) with the goal of utilizing existing federal tax credits. Fuel o il is to be added to liquor to achieve a 1:1,000 mixture (distillate to black li quor) which will then be introduced into the furnace through existing liquor nozzles. The ma ximum liquor firing capacity will remain unchanged. The potential emissions from firing the blended liquor will not increase since black liquor contains higher concentrations of pot ential pollutants than fuel oil. For example, a gallon of black liquor contains approximately 0.3 lbs of sulfur compared to 0.0001 lbs of sulfur in a gallon of distillate fuel oil. Similarly, a gallon of black liquor contains approximately 0.008 lbs of nitrogen compared to 0.001 lbs in distillate fuel oil. There will no adverse air quality impacts associated with this activity. The limited quantity of fuel oil used
and the low sulfur content of distillate oil en sure that emissions from this change will be negligible. DEQ agrees with this change sin ce it this activity does not contravene any Title V permit condition, is not expressly prohibited by the permit, and does not trigger any new applicable requirements. IP will manage a nd document the quantity of fuel used and its

sulfur content to demonstrate that emissi ons from this activity are insignificant.

2. On March 25, 2009, the facility requested a minor modification to update the No. 2 Brownstock Washing Area (#2 BSW) emission factor for TRS to allow for operational variations. The requested change in emissions are 1.08 lbs/hr (vs. 0.60 current limit) and 4.38 tons/year (vs. 2.41 current limit) an increas e of 1.97 tons) for the #2 BSW. The request also included adding clarifying la nguage to the power boiler description. These adjustments result in no adverse air quality impacts. DE Q approves the change as a minor modification under state regulation 252: 100-8- 7.2(b) since: It does not violate any applicable requirement, or state-only require ments. It does not involve si gnificant changes to existing monitoring, reporting or recordk eeping requirements in the perm it. It does not require or change a case-by-case determination of an em ission limitation or other standard, or a sourcespecific determination for temporary sources of am bient impacts, or a visibility or increment analysis.

3. A change of the compliance reporting periods a nd due dates that are currently tied to the anniversary date of the Title V permit, so that the permittee can time their process of data gathering and compilation with the due dates of the Annual Compliance Certification and the Semi-Annual Monitoring and Deviation Report. There is no physical change, no change in operations, or no change resulting in emissions, associated with this modification to the permit.

The request for waver of BART requirements wa s initially given the permit number of 97-057- TV (M-7) and the two modifications above were initially given the permit number of 97-057-TV (M-10). However, DEQ has determined that all requested modifications can be combined into one permit action. Therefore, this permit will be issued as No. 97-057-TV (M-10) and Permit No. 97-057-TV (M-7) will be withdr awn upon issuance of this permit.PERMIT MEMORANDUM 97-057-TV (M-10) - 3 -

The IP Valliant Paper Mill is a Kraft Proce ss paper mill (SIC 2631, NAIC 32213) in southeast Oklahoma, which is adjacent to a wood chipping facility (Valliant Chips) owned and operated by Valliant Chips, Inc. (a subsidiary of The Pri ce Companies). The determination made by the Air Quality Division (AQD) is that there was no clea r indication that the tw o operations can operate independently of each other and therefore, cannot be considered separate facilities under 40 CFR Part 70. Future modifications and permits of each facility need to be based on the combined emissions from both operations and need to be considered prior to making a determination for each permitting action. Applicability of each opera tion to Part 70 requirements or New Source Review (NSR) requirements should also be based on the combined emissions of the operations. The Part 70 permit for each company’s portion of the facility will only address the equipment owned or operated by each individual company. Ot her than for collocatio n-related purposes, the wood chipping facility is not addr essed in this permit. Emission inventories will be required for

both facilities. Valliant Mill and Valliant Chips will each pay only fees for their own equipment.

Construction authorized by Permits No. 97- 057-C (M-4)(PSD), No. 97-057-C (M-8)(PSD) and No. 97-057-C (M-9)(PSD), involve phased construc tion on several projects at this facility. Permits 97-057-C(M-4)(PSD) and 97-057-C(M- 8)(PSD) were superseded by 97-057-C(M9)(PSD) (with the excepti on of the wastewater pipeline requir ements (M-8), which is included in this operating permit as a part of Phase I). Only those completed in early 2007, including the new recovery furnace, smelt dissolving tank and mix tanks will be addressed in this permit action (Phase I). The construction permit remains in eff ect, at this time. App licable requirements will be incorporated into this opera ting permit upon project completion.

SECTION II. FACILITY DESCRIPTION

Initial construction of the mill began in 1969 and was completed in 1971. The mill produces paper products through the use of chemical dige sters, secondary fiber processing, and paper machines. The primary raw materials used in the production of paper pr oducts at the mill are fiber source materials such as, but not limited to, wood chips from both softwood and hardwood species and old corrugated containers (OCC). In addition to the pulping and paper-making process units, other equipment is involved with recovering the chemicals used to produce virgin pulp. Spent cooking liquor is concentrated and burned (to remove organics and recover heat value) and reacted with lime to regenerate the cooking liquor. The spent lime used for regeneration is recovered, wash ed, and calcinated for reuse. Steam requirements are supplied by two large boilers (Bark Boiler and Power Boile r), a small package boiler and by a recovery
furnace. Steam is also used to drive a turbin e electric generator that supplements the mill’s electric energy needs.

SECTION III. PROCESS DESCRIPTIONS

Operations at the Valliant Mill have been subdivided into si x functional areas. The functional
areas are based on the flow of ma terials within the Valliant Mill and on the various steps in the production process. Emissions units within e ach functional process ar ea are identified. Any particular emissions unit may include more than one significant emission point.PERMIT MEMORANDUM 97-057-TV (M-10) - 4 -

V ALLIANT M ILL F UNCTIONAL A REAS

Functional Area A – Pulping Functional Area E. Chemical Recovery A1 No. 1 Digester System E1 Turpentine Recovery System A2 No. 2 Digester System E2a Spent Liquor Concentration A3 No. 3 Digester System E2b Evaporator Sump

A4 No. 1 OCC Plant E3c -see D6 (Recovery Furnace (New))

A5 No. 2 OCC Plant E3d Spent Liquor Mix Tanks (New) A6 Makedown Pulper E4b Smelt Dissolving Tank (New)

A7 No. 3 OCC Plant E5 Lime Slakers A8 OCC Lightweight Rejects Handling System E6 Causticizing System

E7 Lime Kiln Functional Area B – Brownstock Washing E8 Tall Oil Plant B1 No. 1 Brownstock Washing Area E9 Organic Liquid Storage Vessels B2 No. 2 Brownstock Washing Area E10 Volatile Organic Liquid Storage Tanks B3 No. 3 Brownstock Washing Area

Functional Area C. Paper Making Func tional Area F. Miscellaneous Areas

C1 No. 1 Paper Machine (Stock Prep) F1 Woodyard C2 No. 1 Paper Machine (Wet End) F2 Plant Traffic Road Emissions

C3 No. 1 Paper Machine (Dry End) F3a Wastewater Treatment System C4 No. 2 Paper Machine (Stock Prep) F3b Wastewater Pipeline C5 No. 2 Paper Machine (Wet E nd) F4a NCG Thermal Oxidizer
(decommissioned from normal operation) C6 No. 2 Paper Machine (Dry End) F4b LVHC/HVLC NCG Collection System C7 No. 3 Paper Machine (Stock Prep) F5 Solid Waste Disposal Facility Operations C8 No. 3 Paper Machine (Wet End) F6 Diesel Stormwater Pump C9 No. 3 Paper Machine (Dry End) F7/F9 Wood Chip Screening and Conditioning F10 Steam Stripper System F11 Misc. Insignificant Activities
Functional Area D. Steam Production F13 Petcoke Handling System No. 1

D1 Bark Boiler

D2 Power Boiler D3 Package Boiler D6 New Recovery Furnace (prev. EUG E3c)

Note: D4 Power Boiler #2 – permitted but not constructed; E3a Spent Liquor Mix Tanks (decommissioned); E3b Recovery Furnace (decommissioned); E4a Smelt Dissolving Tanks (decommissioned); F8 Rader Kamyr Chip Air Separation systems (removed in 1985); F1 2 – Wood Chipping operation – owned a nd operated by Valliant Chips, Inc. (The Price Companies).

Functional Area A - Pulping

Digester Areas (EUGs A1, A2, A3) The Digesters produce pulp by utiliz ing a chemical pulping proce ss in which fiber sources are digested in a water solution of pulping chemicals. This solution chemically dissolves the lignin that holds the fibers together. Each Digester area operates in a similar manner, as described below. The No. 1 and No. 2 Digesters use a Kraf t pulping system, and the No. 3 Digester uses a semi-chemical pulping system.PERMIT MEMORANDUM 97-057-TV (M-10) - 5 -

Fiber source materials are conveyed from “chip silos” to “chip bins”, which are vented to the high volume, low concentration (HVLC) Noncondensib le Gas (NCG) Collection System (EUG F4b). From each chip bin, a meter feeds the material into a steaming vesse l, which heats the material to processing temperature. The steami ng vessels are vented to the Tu rpentine Recovery System (EUG E1).

From the steaming vessels, the fibe r source material is introduced into the Digesters, along with heated cooking liquor. The material is digested as it travels down the Digesters by gravity flow. The No. 1 Digester area includes a pressurized impregnation vessel between the steaming vessel and the Digester. The fi ber source material is steeped in co oking liquor in the impregnation vessel before its introduction into the Digester.

Vapors produced by the cooking process are vented to the Turpentine R ecovery System (EUG E1). The spent cooking liquor, which contains di ssolved lignin and other organic and inorganic materials, is withdrawn from the Digesters. This spent liquor is depressurized in flash tanks and sent to the weak liquor storage ta nks. Vapors from the flash tanks are vented to the Turpentine Recovery System (EUG E1) and/or the steaming vessel.

The digested pulp, also known as brownstock, is withdrawn from the bottom of the Di gesters. The brownstock passes through defibr ators, which mechanically break apart the mostly-digested fibers. The pulp is then sent to a su rge tank that is vent ed to the HVLC NCG Co llection System (EUG F4b).

Repulping Operations (OCC Plants) (EUGs A4, A5, A6, A7) Repulping operations prepare fiber for the pa per machines. Repulping hydromechanically breaks down fiber source materials in water, which allows the fiber stock to be introduced into the paper machine stock preparation equipment. The fiber sources can include, but are not limited to, virgin fiber, as well as preconsumer and postconsumer secondary (recycled) fiber.

The OCC Plants process OCC (old corrugated c ontainer) materials, which include, but are not limited to, old corrugated containers (e.g., cardbo ard boxes), old newspapers , rejected materials from paper machines or box manufacturing fac ilities, and other type s of fiber-containing products.

OCC is received at the Valliant Mill by truck and by rail. Once the OCC is repulped, it then goes through a series of steps to remove heavy and li ght rejects and adequately separate the fibers from each other. Heavy reject materials may be disposed in the mill’s Solid Waste Disposal Facility or transferred off-site. Light rejects ar e pressed to remove water, then may be disposed on site, transferred off-site, or tr ansferred to a receiving bin before being used as a fuel source. The prepared fiber is stored in OCC high densit y storage chests for use in the paper machines.

The Makedown Pulper performs a function similar to the OCC plants. It uses box plant trim, which is a relatively clean fiber source material , and cull rolls from the Valliant Mill paper machines. Fiber prepared in the Makedown Pulper can be introduced into the stock preparation areas of any of the three paper machines. Th ere are no significant emission points associated with the Makedown Pulper.PERMIT MEMORANDUM 97-057-TV (M-10) - 6 -

OCC Lightweight Rejects Handling System (EUG A8) The OCC Lightweight Rejects Baghouse controls pa rticulate emissions from the Bark Surge Bin.

Materials are blown from the OCC Plants to this bin prior to being introduced to the Bark Boiler

fuel stream.

Functional Area B - Brownstock Washing

Brownstock Washing Areas (EUGs B1, B2, B3) The brownstock washing areas include brownsto ck washers and brownstock washer filtrate tanks. Brownstock washing areas 1 and 2 also include a screening process.

Pulp from digester surge tanks is screened in brownstock washing areas 1 and 2 to ensure
uniform fiber size. The flow-thr ough tanks in the screening system are vented to the atmosphere. Pulp, either from the screening systems or from digester surge tanks, is washed over rotary
vacuum drums in the brownstock washers to re move spent cooking chem icals. After being washed, the pulp is transferred to several high dens ity storage silos. The brownstock washers are hooded and are vented from the pulp mill building to the atmosphere.

Filtrate from the brownstock washers is collected into brownstock washer filtrate tanks. From these tanks, filtrate is either reused in the washin g process or is returned to the digester areas.

Brownstock Washing Area 3 performs a similar f unction to that describe d above for Brownstock Washing Areas 1 and 2. However, Brownstock Washing Area 3 washes pulp from the No. 3 Digester, which uses a semi-che mical pulping system. Therefor e, Brownstock Washing Area 3 is not subject to the maximum achievable cont rol technology (MACT) standard for pulp and paper mills (40 CFR Part 63, Subpart S).

Functional Area C - Paper Making

Paper Machine Stock Prepar ation (EUGs C1, C4, C7) Stock preparation is a process of blending the fi bers (stock) with water and other additives for consistency control and to prepare the stock for introduction onto the paper machines. In general, the stock is diluted, blended, and clean ed as it passes from vessel to vessel through the stock preparation process. Stock from various s ources, such as virgin fiber from the digester areas, secondary fiber from the OCC plants, and recycled fiber from the Makedown Pulper, may be blended together in this process. In additi on, fiber recycled from the wet end or the dry end (known as broke) may be processed and a dded to the stock during preparation.

The various chests (vessels) associated with th e stock preparation process are vented either directly to the atmosphere or to the interior of the pape r machine building.

Paper Machine Wet End (EUGs C2, C5, C8) The paper machine wet end forms a base sh eet by means of the primary headbox, which distributes the dilute stock evenly over a con tinuously moving wire screen. Water is removed from the stock by gravity drainage, by vacuum, and by press rolls. Product with additional layers can be produced by using additional headboxes. Until the fiber sheet has dried sufficiently to support its own weight, it is s upported first by the wi re screen and then by a moving felt sheet.PERMIT MEMORANDUM 97-057-TV (M-10) - 7 -

Water removed from the stock during processing, cal led white water, is collected and reused in various mill processes. Various sections of the paper machine wet end are vented to the atmosphere or to the interior of the paper machine building.

Paper Machine Dry End (EUGs C3, C6, C9) The fiber sheet passes from the wet end of the m achine to the dry end, where it is heated on drying cylinders. The sheet is then processed on trimming and winding equipment that produces paper rolls of appropriate width and diameter . Product trimmed from rolls and cull resulting from breaks is reprocessed in the dry end pulper. The recovered fiber is returned to the stock preparation area.

Emissions from the dryer section of each machin e are vented to the atmosphere. The dry end pulpers and other insignificant emission points vent to the interiors of the paper machine buildings.

Functional Area D - Steam Production

Steam Producing Units (EUGs D1, D2, D3, D6) The Valliant Mill currently opera tes three steam-producing boilers: the Bark Boiler, the Power Boiler, and the Package Boiler. A second power boiler (Power Boiler No. 2) was permitted under Permit No. 96-043-C (M-3), but will not be constructed. Steam is also produced by the New Recovery Furnace (D6 – formerly EUG E3c).

Steam from the boilers and the new Recovery Furnace feeds a common steam header. From the header, the steam may be used to generate elec tricity. Steam extracted from the generator and steam that by-passes the generator is fed into the steam distribution syst em for use in various processes. Steam from the Pack age Boiler feeds directly into th e steam distribution system.

The Bark Boiler (EUG D1) burns a variety of fuel s in varying combinations and amounts. Fuels
include but are not limited to w ood residues, OCC rejects, wastewat er treatment sludge, oil, and natural gas. Oils from mill equipment (including small portions of used antifreeze and miscellaneous non-hazardous used pa rts washer fluid) may also be added to the Bark Boiler fuel mixture. The Bark Boiler is also capable of bur ning coal. Particulate em issions from the Bark Boiler are controlled by a wet venturi scrubber. In addition, multiclones are a part of the bark boiler operations. The presence of wood ash a nd the wet venturi scrubber also results in a
reduction in SO 2 emissions. Its emissions are disc harged through a dedicated stack

The Power Boiler (EUG D2) can burn natural gas, oil and propane. Oils from mill equipment (including small portions of used antifreeze and miscellaneous non-hazardous used parts washer fluid) may also be added to the Power Boiler fuel mixture. Exhaust gases are emitted to the atmosphere through a shared stack with the Ta ll Oil Scrubber (Main Stack). The Power Boiler
annual emissions are tracked with th e New Recovery Furnace (Phase I).

The Package Boiler (EUG D3) burns only natural ga s. Its emissions are discharged through a

dedicated stack.PERMIT MEMORANDUM 97-057-TV (M-10) - 8 -

The new Recovery Furnace (EUG D6) is used to recover process chemicals from spent liquor from the spent liquor concentra tion area (EUGs E2a and E2b) or spent liquor obtained from offsite. Prior to being burned, the spent liquor ma y pass through the Spent Liquor Mix Tanks (EUG E3d), where it may be mixed with particulat e matter captured in the Recovery Furnace’s electrostatic precipitator (ESP). The spent li quor mix tanks emit through the new Recovery Furnace. The smelt dissolving tank (EUG E4b) also emits through the new recovery furnace. There is an emergency by-pass stack av ailable for the smelt dissolving tank.

The new Recovery Furnace is the primary co ntrol device fro NCGs and SOGs, which was
rerouted from the NCG Thermal Oxidizer. The Lime Kiln still operates as a NCG/SOG combustion source backup and the Thermal Oxidizer is also an emergency backup combustion device (decommissioned from normal operation).

In addition to burning spent liquor and combusting NCGs/SOGs, the Recovery Furnace also uses natural gas and is capable of bur ning other materials that may c ontain spent cooking chemicals, such as soap from the evaporators, brine from th e tall oil reactor, and turpentine. The natural gas total fuel is under an annual 10% capacity limit. Emissions are discharged through a dedicated

stack. Fuel oil is added to li quor to achieve a 1:1,000 mixture (distillate to black liquor) which
will then be introduced into the furnace through existing liquor nozzles. The maximum liquor firing capacity will remain unchang ed. The potential emissions from firing the blended liquor will not increase since black liquor contains higher concentrations of potential pollutants than fuel oil. For example, a gallon of black liquor contains approximately 0.3 lbs of sulfur compared to 0.0001 lbs of sulfur in a gallon of distillate fuel oil. Similarly, a ga llon of black liquor contains approximately 0.008 lbs of nitrogen compared to 0.001 lbs in distillate fuel oil. There will no adverse air quality impacts associated with this activity. The limited quantity of fuel oil used and the low sulfur content of distillate oil ensure that emissions from this change will be negligible. DEQ agrees with this change since it this activity does no t contravene any Title V permit condition, is not expres sly prohibited by the permit, and does not trigger any new applicable requirements. IP will manage and document the quantity of fuel used and its sulfur content to demonstrate that emissions from this activity are insignificant.

Functional Area E - Chemical Recovery

Turpentine Recovery System (EUG E1) The Turpentine Recovery System condenses turp entine from vapors collected from equipment in the Digester areas. The turpentine that is recovered is sold as a by-product. The non-condensable fractions of these vapors are com busted in the new recovery furnace or in the
Lime Kiln. The NCG Thermal Oxidizer is used as a combustion backup.

In the Turpentine Recovery System for the No. 1 and 2 Digester areas, vapors are condensed to a water fraction, a turpentine (liquid) fraction, and a vapor fraction. The water fraction is collected in a series of tanks before being sent to the steam stripper or sewer. The turpentine fraction flows through a degasser to a turpentine decanter, which sepa rates the turpentine from the remaining water. The water is drawn off and se nt to the steam strippe r or the sewer. The turpentine flows to the turpentine receiver and then to a storage tank to await loading into trucks. Low volume, high concentration (LVHC) vapors collected from the system are combusted in thePERMIT MEMORANDUM 97-057-TV (M-10) - 9 -

new recovery furnace or in the Lime Kiln. The NCG Thermal Oxidizer is used as a combustion backup source.

Turpentine storage and loading facilities, the pu mp tank that receives liquid from the cyclone separators, and the collection ta nk are insignificant emission sources that are vented to the atmosphere.

Spent Liquor Concentration (EUG E2a) and Evaporator Sump (EUG E2b) Spent pulping liquor collected in the weak liquor storage tanks is concentrated before it is processed in the new Recovery Furnace. Transfers of spent liquor to or fr om off-site locations may be accomplished at any point in these processes.

Liquor is concentrated by sending it to a multiple-effect evaporator system and super concentrator, where non-contact steam is used to evaporate water from the liquor. Spent liquor leaving the evaporators may be sent to on-site stor age, transferred off-site, or sent on for further

concentration.

During the evaporation process, a fatty substance called soap is removed from the spent liquor by soap skimmers. The soap is sent to the Tall Oil Plant (EUG E8) for conve rsion into tall oil, which is sold as a product.

Recovery Furnace and Spent Liquor Mix Tanks (EUG E3d) The Recovery Furnace (EUG D6) is used to re cover process chemicals from the spent liquor concentration area or spent liquor obtained from of f-site. Prior to being burned, the spent liquor may pass through the new Spent Liquor Mix Tanks (EUG E3d) where it may be mixed with particulate matter captured in the Recovery Furn ace’s electrostatic precipitator (ESP). The spent liquor mix tanks emit through the new recovery furnace.

A molten inorganic residue called smelt forms in th e Recovery Furnace as a result of the burning of spent liquor. The smelt is drawn off into the new Smelt Dissolving Tank (EUG E4b) and used

to initiate the causticiz ing process that regenera tes cooking chemicals. The smelt dissolving tank also emits through the new recovery furnace. There is an emergency by-pass stack available.

Smelt Dissolving Ta nk (EUG E4b) Smelt from the Recovery Furnace fl ows into the Smelt Dissolving Ta nk, where it is dissolved in water or in weak wash, which is water that has been used in the Causticizing System to wash lime mud. The resulting solution, called green liquor , is sent to the Gree n Liquor Clarifier (EUG E6) for further processing. After particulate emissions have been reduced with aqueous sprays, the Smelt Dissolving Tank is vented through the R ecovery Furnace. Airflow from the new Smelt Dissolving Tank (EUG E4b) is routed through the new Recovery Furnace as combustion air make-up. Therefore, the new Smelt Dissolving Tank is not an emissions unit. There is also an emergency bypass for the smelt dissolving tank.

Lime Slakers (EUG E5) The Lime Slakers mix lime with green liquor to in itiate the causticizing pr ocess that regenerates cooking liquor. The lime is fed from lime bins that are filled either from the Lime Kilns or by lime transported from off-site. Green liquor ente rs the Slakers from the green liquor clarifier,PERMIT MEMORANDUM 97-057-TV (M-10) - 10 -

from green liquor storage, or fr om off-site sources. The mixture of green liquor and lime flows from the Slakers through classifiers, which re move unreacted lime and other debris, to the
Causticizers.

Causticizing Area (EUG E6) In the Causticizing area, cooking liquor is rege nerated by reacting green liquor from the Smelt Dissolving Tank with calcium oxide (quick lime). The lime is recovered and re-used in this

process.

Green liquor from the Smelt Dissolving Tank (or from off-site sources) flows to the Green Liquor Clarifier, where heavy partic les, such as undissolved smelt, are allowed to settle out. The settled material, known as dregs, goes to the dreg s filter. The filtrate is returned to the Green Liquor Clarifier, and the remaining dregs are sent to the process sewer, disposed, or transferred

off-site.

Clarified green liquor can be sent to storage, the Digesters, the Lime Slakers, or off-site destinations. After being mixed with lime in th e Slakers, the green liqu or goes through a series of Causticizers (agitated holding ta nks) that provide the residence time needed for the lime to react with the green liquor to regenerate the cooking liquor.

The cooking liquor from the Causticizers flows into one of two clarifiers . The clarified cooking liquor (or cooking liquor from off-site sources) is stored, us ed in the Digesters, or transferred offsite. The material that settles to the botto m of the cooking liquor cl arifiers is lime mud (principally calcium carbonate). The lime mud is washed with water in a Lime Mud Washer. The overflow from the Lime Mud Washer goes to weak wash storage for later use in the Smelt Dissolving Tank and other areas. The washed lime mud is sent to storage tanks and from there
to a Lime Mud Filter. The filtered lime mud w ill be calcined in the Lime Kiln (EUG E7a), converting it back to calcium oxide. This Lime K iln product is transported to the lime bins. If the Lime Kiln is not operating, the lime mud is dispos ed in the on-site So lid Waste Disposal Facility or transferred off-site.

Lime Kiln (EUG E7a) Lime Mud from causticizing is calcined in the Lime Kiln to regenerate calcium oxide (quick lime). The Lime Kiln is fueled by natural gas a nd petcoke and is also used as a backup to the Recovery Furnace (or as backup to the secondary backup Thermal Ox idizer) if it is not being
used to oxidize the collected NCGs and/or Stripper Off Gases (SOGs).

Particulate emissions from the kiln are controlle d by an electrostatic precipitator, which returns

collected lime dust to the kiln.

The regenerated quick lime is transferred to th e Lime Bins which feed the Slakers (EUG E5). The Lime Bins are vented to the Lime Kiln combustion air makeup.

Tall Oil Plant (EUG E8) Tall oil is a heavy organic oil r ecovered and sold for various comme rcial uses. It is produced by the Tall Oil Plant from the soap collected during spent liquor ev aporation (EUGs E2a and E2b). Tall oil is produced by charging the Tall Oil Reactor with soap, water, a nd sulfuric acid. The

reactor and mixture are then heated to produce a batch of tall oil.PERMIT MEMORANDUM 97-057-TV (M-10) - 11 -

After the reaction, the contents of the tall oil reactor settle into three layers. Th e tall oil itself rises to the top of the reactor, from where it is withdrawn to wet tall oil storage tanks. The middle layer is a sludge that cont ains lignin and other organic mate rials. This sludge is drawn off into a sludge storage tank. A predominantly sodium sulfate brine solution collects at the

bottom of the reactor.

The tall oil is transferred from th e storage tanks directly to trans port vessels or to another storage

tank. Tall oil can be loaded in to transport vessels from this storage tank. The sludge is transferred back to the tall oil reactor, caustic is added, and the reactor is heated again in a process known as lignin cook. The resulting material is returned to the evaporator area and mixed with spent liquor for chemical recovery.

A packed bed scrubber controls emissions of total reduced sulfur (T RS) from the tall oil reactor, the wet tall oil tanks, and the brine tank. This scrubber is vent ed to a shared stack with the Power Boiler (existing Main Stack).

Storage Vessels (EUGs E9 and E10) Various lower vapor pressure organic liquids, such as black liquors, tall oil, soaps, and fuel oil,
are stored in tanks and other vessels at the Valliant Mill (EUG E9). Other volatile organic liquids, such as turpentines and gasoline fuel, are stored in smaller tanks at the Valliant Mill (EUG E10).

Functional Area F - Miscellaneous Processes

Woodyard (EUG F1) Woodyard operations include the receipt, storage, and handling of fiber source materials and

solid fuels.

Fiber Source Materials Fiber source materials, such as wood chips, are received by railroad, truck and belt conveyor systems. Railcar rollovers and truck lift dumpers are used to unload the ma terial into receiving pits. The received materials can be stored for late r retrieval or conveyed di rectly to the screening operation.

Material to be stored is stockpi led into storage piles by stackers . Material can be removed from the storage piles by reclaimers. Reclai med material is transferred to Chip Screening/Conditioning (EUGs F7 and F9) and then to chip silos. Undersized (fine) rejects from the scalping screens are conveyed to the Bark Boiler fuel storage pile feed conveyor. Oversized rejects from the scalping screens are either disposed on site or added to the Bark Boiler fuel storage pile. The fiber source material is transfe rred as needed from the chip silos to the chip bins in the Digester area s (EUGs A1, A2, and A3).

Conveyors and transfer point s in the fiber source material ha ndling system are partially covered and/or enclosed. This serves to reduce the potential for fugitive particulate emissions from material handling operations.PERMIT MEMORANDUM 97-057-TV (M-10) - 12 -

Solid Fuels Solid fuels are received by railroad , truck and belt conveyor systems. After receipt, the fuels are conveyed to the fuel stor age pile. Oversized mate rials can be sent offsite or diverted from the fiber source processing/storage area and pa ss through a hogger for size reduction before being stockpiled. Fuel reclaimed from the storage pile is conveyed di rectly to the Bark Boiler. Conveyors and transfer point s in the fuel handling system are pa rtially covered and/or enclosed. This serves to reduce the potential for fugitiv e particulate emissions from material handling operations.

Plant Traffic Road Emissions (EUG F2) Heavy trucks and other vehicles regularly travel on paved and unpa ved roads within the Valliant Mill. These vehicles are expected to cause fug itive dust emissions by the action of their tires on

the surface of the roads.

Any airborne dust generated by vehicle traffic is emitted directly to the atmosphere. The roads on which these vehicles travel are in good repair , and paved roads are cl eaned periodically to minimize the extent of fugitive dust emissions. Unpaved roads are periodically treated to reduce fugitive dust emissions.

Facility vehicles are typically fueled onsite from a gasoline fuel tank (EUG E10). Vehicle traffic occurs in part because of the receipt of raw mate rials, the shipping of fi nished products, and the receipt of materials used in the various processes at the Valliant Mill.

Wastewater Treatment System (EUG F3a) The Valliant Mill Wastewater Treatment System consists of the Bark Ash Dewatering System, the Primary Effluent Clarifier, a Sludge Dewate ring Operation, Aerated Stabilization Basins, and Emergency Storage Ponds. With the excepti on of the Sludge Dewatering Operation, the Wastewater Treatment System (WWTS) componen ts are open to the atmosphere. The Sludge Dewatering Operation is housed in a building with openings (e.g., windows) to the atmosphere. Mainly VOC and reduced sulfur compounds contai ned in mill wastewater are emitted from the system components. A portable Diesel Stormwater Pump (EUG F6) for stormwater management

is utilized as needed.

The Bark Ash Dewatering System receives liquids from the bark ash sand tank. Solids that settle in the Dewatering Ponds are disposed on site. Th e liquid overflow from the Dewatering Ponds is sent to the Runoff Pond. From the Runoff Pond, water overflows to an Aerated Stabilization Basin, while some is recirculated to the bark ash sand tank. The No. 1 Aerated Stabilization Basin can be bypassed, e ither to another basi n or to the Oklahoma Pollutant Discharge Elimination System (OPDES)-permitted outfall.

Other mill wastewater streams are conveyed to the wastewater treatment area by the process sewer system. These streams pass through a bar screen to the Primary E ffluent Clarifier, or bypass the clarifier and mix direc tly with the overflow from the Runoff Pond. Solids from the primary clarifier go to the Sludge Dewatering Oper ation. Solids from this operation will either be used as fuel in the Bark Boiler or disposed on site. The liquid from sludge dewatering is returned to the Primary Effluent Clarifier. Li quid from the clarifier combines with water from the Runoff Pond. Microbial nutrients may be added to the clarifier effluent to aid biodegradationPERMIT MEMORANDUM 97-057-TV (M-10) - 13 -

of organic materials in the liqui d. If necessary, clarifier effluent and runoff pond effluent can be sent to emergency holding ponds. Chemi cals may be used to control WWTS H 2 S or foaming.

From the No. 1 Aerated Stabilization Basin, wastewat er is either discharged or enters the No. 2
Aerated Stabilization Basin for fi nal settling, biodegrada tion, and clarifying. The effluent from
the No. 2 Aerated Stabilization Basin is disc harged via the OPDES-permitted outfall. The
Aerated Stabilization Basins also receive storm water runoff from various points within the Valliant Mill, including the Solid Waste Disposal Facility Collection Pond and the Chip Pile
Collection Pond.

Wastewater Pipeline (EUG F3b) A wastewater pipeline transfers wa stewater effluent from the Vall iant Mill to the Red River. Under normal operating conditions, effluent from the Valliant Mi ll treatment ponds flows to a 48-inch diameter pipeline. The effluent then typically flows by gravity approximately six miles to a collection box. The collection box is mostly closed to the atmosphere and is the emission point for any hydrogen sulfide (H 2 S) formed in the pipeline. From the collection box, the
effluent flows to a 200-foot diffuser at the botto m of the Red River. During periods of heavy rainfall, pumps can be operated to accommodate the increased flow rates.

NCG Collection and Thermal Oxidation (EUG F4) Many sources of NCGs are vented to one of two collection systems for burning. The LVHC streams are relatively low-flow-rate, high-con centration sources of NCGs, whereas the HVLC streams produce more total gas flow but much lower concentrations of NCGs. The following
sources of concentrated NCGs ar e vented to the LVHC system:

• Turpentine recovery condensers

• Turpentine decanters

• Turpentine recovery underflow tanks

• Turpentine degassers

• Turpentine receiver tank

• No. 3 Digester Area flash steam condensers

• Evaporator hotwells

• Steam stripper system

The steam stripper feed tank (EUG F10) collects and routes condensates from various processes at the facility to the LVHC system. The stripper off-gas (SOG) from the steam stripper is routed directly to the combustion unit via an individual line.

The chip bins and digester surg e tanks are vented to the HVLC system (EUG F4b). NCGs from the No. 1 Digester chip bin are routed directly to the combusti on unit through an individual line.

The primary control device for the collected NCGs is the new Recovery Furnace. The backup device is the Lime Kiln (EUG E7a) and if unavaila ble, the NCG thermal oxid izer with a scrubber.
The Thermal Oxidizer has been decommissioned from normal operation. The high-concentration
LVHC and SOG streams are introduced into the recovery furnace combustion zone. The relatively
dilute HVLC stream is used as combustion air. Natural gas is us ed as an auxiliary fuel for start-up

and to stabilize combustion.PERMIT MEMORANDUM 97-057-TV (M-10) - 14 -

During certain start-up operations and upset cond itions, the NCG streams may be released to the atmosphere for a relatively shor t time for safety reasons. These are recognized technological limitations for purposes of excess e missions reporting (OAC 252:100-9-1).

Solid Waste Disposal Facility Operations (EUG F5) A variety of solid wastes are ge nerated as part of the manufact uring processes at the Valliant Mill. Wastes generally are transported via truc ks from the Valliant Mill to the on-site Solid Waste Disposal facility (landf ill) located south of the manuf acturing complex. The trucks regularly travel back and forth between the So lid Waste Disposal Facility and manufacturing areas. The majority of the roads in the manuf acturing complex are paved, while those in the Solid Waste Disposal Facility area are unpaved.

Vehicle traffic related to Solid Waste Dispos al Facility operations may cause fugitive dust emissions by the action of tires on the surface of the roads. In addition, the unloading of waste materials from trucks into the landfill and other associated waste handling operations may generate small amounts of fugitive dust emission s. To limit fugitive em issions, paved roads are periodically cleaned and unpaved roads are periodically treated.

Wood Chip Screening & Conditioning (EUGs F7 and F9) The Valliant Mill operates wood chip screening and conditioning equipment for processing wood chips prior to being pulped. This area currently consists of bar screens, chip conditioners, and two air density separators.

Steam Stripper System (EUG F10) The steam stripper feed tank (EUG F10) collects and routes condensates from various processes at the facility to the LVHC system. The stripper off-gas (SOG) from the steam stripper is routed directly to the combustion unit via an individual lin e. In the event that the new Recovery Furnace becomes unstable or must be taken off-line, the Li me Kiln (EUG E7a) is us ed to thermally oxidize
all the SOGs or the second ary backup is the Therma l Oxidizer (EUG F4).

Miscellaneous Insignificant Activities (EUG F11)
The Valliant Mill has several activities that are insignificant in nature such as storage tanks and emergency engines.

Petcoke Handling System No. 1 (EUG F13)
Petcoke is delivered to the mill via trucks. The petcoke is transferred from the truck trailer to a storage silo using pneumatic conveya nce. The silo is equipped with a bin vent that allows for air displacement when the silo is being filled with pe tcoke. The bin vent is e quipped with a filter to aid in product recovery. From the storage silo, the petcoke is pneumatically conveyed to the kiln

burner.PERMIT MEMORANDUM 97-057-TV (M-10) - 15 -

SECTION IV. EQUIPMENT

The numbering of emission points is repeated he re from the permit application, e.g. “E-A4,C.” The applicant has requested that heat input capacity fo r several units be ke pt confidential. The
information in the column named ‘Construction Date’ reflects the date the unit was constructed or changes that resulted in permitting activities.

EUG A1 – No. 1 Digester System

Emission Point EU Name/Model Construction

Date E3c (New Recovery Furnace) or E7 (Lime Kiln) or F4

(Backup NCG

Thermal Oxidizer) #1 Pre-Steaming Chip Bin

Pre-1972/2005 #1 Steaming Vessel #1 Digester Impregnation Vessel (vented to #1 digester sys) #1 Surge Tank 1A First Stage Flash Tank 1B First Stage Flash Tank Second Stage Flash Tank

Secondary Flash Tank

EUG A2 – No. 2 Digester System

Emission Point EU Name/Model Construction

Date E3c (New Recovery Furnace) or E7 (Lime Kiln)

or F4 (Backup
NCG Thermal Oxidizer) #2 Chip Bin

Pre-1972/2005 #2 Steaming Vessel #2 Digester #2 Surge Tank Primary Flash Tank Parallel Primary Flash Tank Secondary Flash Tank

EUG A3 – No. 3 Digester System

Emission Point EU Name/Model Construction

Date E3c (New Recovery Furnace) or E7 (Lime Kiln)

or F4 (Backup
NCG Thermal Oxidizer) #3 Chip Bin

Pre-1972/2005 #3 Steaming Vessel #3 Digester #3 Surge Tank Primary Flash Tank Secondary Flash TankPERMIT MEMORANDUM 97-057-TV (M-10) - 16 -

EUG A4 – 1 OCC Plant

Emission Point EU Name/Model Construction

Date

A4 No. 1 OCC Plant 1981/ 2005

The OCC Plants are defined by the Pulp & Paper Industr y MACT as “secondary fiber operations,” subject to the MACT only if bleaching were to occur. No bleaching is conducted at

this mill.

EUG A5 – No. 2 OCC Plant

Emission Point EU Name/Model Construction

Date

A5 No. 2 OCC Plant 1990/2005

EUG A6 – Makedown Pulper

Emission Point EU Name/Model Construction

Date

A6 Makedown Pulper Pre-1972/2005

EUG A7 – No. 3 OCC Plant

Emission Point EU Name/Model Construction

Date

A7 No. 3 OCC Plant 2000/2005

EUG A8 – OCC Lightweight Rejects Handling System

Emission Point EU Name/Model Construction

Date

A8 & A8b (baghouse stack) OCC Lightweight Reje cts Handling System 1990/2001/2005 OCC Lightweight Rejects Receiving Bin

EUG B1 – No. 1 Brownstock Washing Area

Emission Point EU Name/Model Construction

Date

B1 No. 1 Brownstock Washing Area

Pre-1972 E-B1, B Brownstock Washer 1A E-B1, C Brownstock Washer 1B

EUG B2 – No. 2 Brownstock Washing Area

Emission Point EU Name/Model Construction

Date

B2 No. 2 Brownstock Washing Area Pre-1972/1981 E-B2, A 1 s t Stage Brownstock Washer E-B2, B 2nd Stage Brownstock WasherPERMIT MEMORANDUM 97-057-TV (M-10) - 17 -

EUG B3 – No. 3 Brownstock Washing Area

Emission Point EU Name/Model Construction

Date

B3 No. 3 Brownstock Washing Area

Pre-1972 E-B3, A Brownstock Washer- A Line E-B3, B Brownstock Washer- A Line E-B3, C Brownstock Washer- B Line E-B3, D Brownstock Washer- B Line

Number 3 brownstock washing area is a “semi- chemical” operation as defined in 40 CFR 63.441 to be a HVLC (high volume low concentration) operation. The MACT for the Pulp and Paper Industry. 40 CFR 63.443(b) specifies standards only for the LVHC (low volume high concentration). This unit is ther efore not subject to this MACT.

EUG C1 – No. 1 Paper Mach ine (Stock Preparation)

Emission Point EU Name/Model Construction

Date

C1 No. 1 Paper Machine (stock preparation) Pre-1972/1990/
1996/2005

EUG C2 – No. 1 Paper Machine (Wet End) EUG C3 – No. 1 Paper Machine (Dry End)

Emission Point EU Name/Model Construction

Date C2,A Fourdrinier

Pre-1972/1990/
1996/2005 C2,B Vacuum Pumps/ Vacuum Flume C2,D Press Section C3,A Dryer Section

The “Fourdrinier” operation refers to a rotating cy lindrical wire mesh screen used for draining water from pulp.

EUG C4 – No. 2 Paper Mach ine (Stock Preparation)

Emission Point EU Name/Model Construction

Date

C4 No. 2 Paper Machine (stock preparation) Pre-1972 / 2000

/2005

EUG C5 – No. 2 Paper Machine (Wet End) EUG C6 – No. 2 Paper Machine (Dry End)

Emission Point EU Name/Model Construction

Date C5,A Fourdrinier

Pre-1972 / 2000

/2005 C5,B Press Section C5,D Vacuum Pumps/ Vacuum Flume C6,A Dryer SectionPERMIT MEMORANDUM 97-057-TV (M-10) - 18 -

EUG C7 – No. 3 Paper Mach ine (Stock Preparation)

Emission Point EU Name/Model Construction Date

C7 No. 3 Paper Machine (stock preparation) 1981 / 2002 /2005

EUG C8 – No. 3 Paper Machine (Wet End) EUG C9 – No. 3 Paper Machine (Dry End)

Emission Point EU Name/Model Construction Date C8,A Fourdrinier

1981 / 2002 / 2005 C8,B Press Section C8,D Vacuum Pumps/ Vacuum Flume C9,A Dryer Section

EUG D1 – Bark Boiler (Subject to BART)

Emission Point EU Name/Model MMBTUH Construction

Date

Bark Boiler Stack Bark Boiler Confidential Pre-1972/1983 The Valliant Mill has applied for a BART Waiver for the Bark Boiler.

EUG D2 – Power Boiler (Subject to BART)

Emission Point EU Name/Model MMBTUH Construction

Date

Main Stack Power Boiler Confidential Pre-1972 The Valliant Mill has applied for a BART Waiver for the Power Boiler.

EUG D3 – Package Boiler (Subject to BART)

Emission Point EU Name/Model MMBTUH Construction

Date

D3 Package (gas-fired)

Boiler Confidential 1985

This package boiler was manufactured in 1969 but was not installed at the mill until 1985.

EUG D4 - Permitted, but will not be constructed.

EUG D6 – New Recovery Furnace (“No. 2”) Formerly E3c

Emission Point EU Name/Model Construction Date E3c (New Recovery Furnace Stack) Recovery Furnace 2006PERMIT MEMORANDUM 97-057-TV (M-10) - 19 -

EUG E1 – Turpentine Recovery System

Emission Point EU Name/Model Construction

Date

E3c (New Recovery Furnace) or E7 (Lime Kiln)

or F4 (Backup
NCG Thermal Oxidizer) 2-Stage Condenser (No. 1 Fiber Line)

Pre-1972 Degasser No. 1 Turpentine Decanter No. 1

Underflow Tank No. 1 Secondary Condenser (No. 2 Fiber Line) Degasser No. 2 Turpentine Decanter No. 2

Underflow Tank No. 2 Turpentine Receiving Tank Flash Steam Condenser (No. 3 Fiber Line)

EUG E2a – Spent Liquor Concentration

Emission Point EU Name/Model Construction

Date E3c (New Recovery Furnace) or E7 (Lime Kiln)

or F4 (Backup
NCG Thermal Oxidizer) No. 1 Evaporator Hotwell

Pre1972/1981/2006 No. 2 Evaporator Hotwell

Crystalizer

Super Concentrator System

Evaporators are defined by 40 CFR Part 63, Subpart S to be an “LVHC” system.

EUG E2b – Evaporator Sump

Emission Point EU Name/Model Construction

Date E2b,A Evaporator Sump Pre-1972

The evaporator sump is part of the wastewater collection system. As such, it does not meet the definitions in the Pulp & Paper MACT for either “evaporator system” or “process wastewater treatment system.”

EUG E3a – Spent Liquor Mix Ta nks – decommissioned (2006)

Emission Point EU Name/Model Construction

Date

Main Stack Spent Liquor Mix Tank/Spent Liquor Day

Tank Pre-1972

EUG E3b – Recovery Furnace– decommissioned (2006)

Emission Point EU Name/Model Construction

Date

Main Stack Recovery Furnace Pre-1972PERMIT MEMORANDUM 97-057-TV (M-10) - 20 -

EUG E3c – see EUG D6

EUG E3d – New Spent Liquor Mix Tanks

Emission Point EU Name/Model Construction Date E3c (New Recovery Furnace Stack) Spent Liquor Day Tank/Spent Liquor Mix

Tank 2006

EUG E4a – Smelt Dissolving Ta nks– decommissioned (2006)

Emission Point EU Name/Model Construction

Date E4a ( Smelt Dissolving Tanks Stack) Smelt Dissolving Tank “A” Pre- 1972 Smelt Dissolving Tank “B”

EUG E4b –New Smelt Dissolving Tank

Emission Point EU Name/Model Construction Date E3c (New Recovery

Furnace stack) or E4b (Smelt Dissolving Tank Emergency Vent) Smelt Dissolving Tank 2006

EUG E5 – Lime Slakers

Emission Point EU Name/Model Construction

Date E-E5, A (Lime Slaker Scrubber Stack) No. 1 Lime Slaker

Pre-1972/1998 E-E5, B (Lime Slaker Scrubber Stack) No. 2 Lime Slaker

Permit No. 96-043-C (PSD) required that the stack s be extended or cont rol devices added to reduce ambient PM impacts. This has been achieved.

EUG E6 – Causticizing System

Emission Point EU Name/Model Construction

Date

E6 (2 Stacks) No. 1a Causticizer

Pre-1972/2001 No. 2 Causticizer

No. 1b Causticizer

No. 3 CausticizerPERMIT MEMORANDUM 97-057-TV (M-10) - 21 -

EUG E7a – Lime Kiln (Subject to BART)

Emission Point EU Name/Model Construction

Date

E7,A (Lime Kiln)
Stack Lime Kiln No. 1 Pre1972/1992/2003

/2005 No. 1 Lime Bin

No. 2 Lime Bin

No. 3 Lime Bin The Lime Kiln is subject to 40 CFR Part 63, S ubpart S as a back-up air pollution control device. Subpart MM was promulgated on January 12, 2001, to regulate lime kiln s directly, and the compliance date was March 13, 2004.

EUG E8 – Tall Oil Plant

Emission Point EU Name/Model Construction Date

Main Stack Tall Oil Plant which includes: Pre-1972 Capacity,

Gallons Construction

Date

#1 Wet Tall Oil Tank 20,000 1970

#2Wet Tall Oil Tank 20,000 1970

Tall Oil Tank 153,000 1970

A scrubber was added to this unit in 1989. That addition reduced VOC emissions; therefore it was not defined as a “modification” requiri ng permitting. This EUG is a HVLC system, for which no standards are specified for existing equipment under the Pulp & Paper Industry MACT. Other tanks in the tall oil plant are included on the insignificant list.

EUG E9 – Organic Liquid Storage Vessels are addressed in Section V, “Insignificant
Activities.”

EUG E10 – Small Volatile Organic Liquids Stor age Tanks are addressed in Section V, “Insignificant Activities.”

EUG F1 – Woodyard

Emission Point EU Name/Model Construction

Date F1 (fugitive emissions) Woodyard Pre-1972

EUG F2 – Plant Traffic Road Emissions

Emission Point EU Name/Model Construction

Date F2 (fugitive emissions) Plant Traffic on Roads Pre-1972/2003PERMIT MEMORANDUM 97-057-TV (M-10) - 22 -

EUG F3a – Wastewater Treatment System

Emission Point EU Name/Model* Construction

Date

3a (fugitive emissions) Solid Waste Disposal Facility Collection

Pond 1991

Chip Pile Runoff Pond 1991

Process Sewer Pre-1972 Primary Effluent Clarifier Pre-1972

No. 1 Aeration Lagoon Pre-1972 No. 2 Aeration Lagoon Pre-1972 WWTS Emergency Storage Ponds 1983 F3,H Sludge Press 1991 F3,I Sludge Press 1991
* Terminology matc hes OPDES permit.

EUG F3b – Wastewater Pipeline

Emission Point EU Name/Model Construction

Date

F3b Waste Water Pipeline 2003

EUG F4a – NCG Thermal Oxidizer EUG F4b – LVHC/HVLC NCG Collection System

Emission Point EU Name/Model Construction

Date E3c (New Recovery Furnace) or E7 (Lime Kiln)

or F4 (Backup
NCG Thermal Oxidizer) Thermal Oxidation System LVHC Collection System HVLC Collection System

1989/

2000 No. 1 Digester System No. 2 Digester System No. 3 Digester System Turpentine Recovery System Spent Liquor Concentration Steam Stripper System

EUG F5 – Solid Waste Disposal Facility Operations

Emission Point EU Name/Model Construction

Date F5 (fugitive emissions) Solid Waste Disposal Facility Pre-1984

EUG F6 – Diesel Stormwater Pump

Emission Point EU Name/Model Construction

Date

F6 166 HP Diesel Engine Driving a Water Pump 1995PERMIT MEMORANDUM 97-057-TV (M-10) - 23 -

EUG F7 – Wood Chip Screening and Conditioning Unit – No. 3 Line

Emission Point EU Name/Model Construction

Date

F7 Chip Bar Screen (Screening & Dropping) 1996

ADS-1 Air Density Separator F7 Chip Conditioner

EUG F8 - has been retired

.

EUG F9 – Wood Chip Screening and Conditioning Unit – No. 1 Line

Emission Point EU Name/Model Construction

Date F9 Chip Bar Screen (Screening & Dropping)

1998 ADS-2 Air Density Separator F9 Chip Conditioner

EUG F10 – Steam Stripper System

Emission Point EU Name/Model Construction

Date F4 (NCG Thermal Oxidizer) Steam Stripper 2000 Foul Condensate Storage (Steam Stripper Feed ) Tank

EUG F11 – Miscellaneous Insignificant Activities are addressed in Section V.

EUG F13 – Petcoke Handling System No. 1 is addressed in Section V.

SECTION V. INSIGN IFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100- 8, Appendix I, are listed below. Recordkeeping for activities indicated with an asterisk, “*”, is listed in the Specific Conditions.PERMIT MEMORANDUM 97-057-TV (M-10) - 24 -

EUG E9 – Organic Liquid Storage Vessels

Emission

Point EU Name/Model Capacity,
Gallons Construction

Date 164100010 No. 1 Weak Black Liquor Tank 793,090 1995 164100110 No. 2 Weak Black Liquor Tank 793,090 1995

164100210 Boilout Tank 426,263 1991

164101310 51% Black Liquor Tank 793,090 1994/2006 164101710 No. 2 Fuel Oil Storage Tank 1,523,381 1990 164101810 “Neutral-Sulfite Semi-Chemical (NSSC)” Weak Liquor Tank 842,428 1990

164102511 73% Black Liquor Storage Tank 603,400 1995/2006

E-E2,L “Super Bowl” Temporary Storage Area 10,000,000 1990 164110110 Foul Condensate Storage (Steam Stripper Feed) Tank 350,000 2000

174102010 No. 2 Green Liquor Storage Tank >20,000 1997

08301 80% Liquor Storage Tank ~125,000 2006 Due to the vapor pressure of the liquids per 60.110(b), Subpart Kb does not apply. By the definitions in Subpart S, the Valliant mill is cons idered an “existing” sour ce. Therefore the black liquor storage tanks in this EUG ar e not regulated by Subpart S.

EUG E10 - Small Volatile Or ganic Liquids Storage Tanks

Emission

Point EU Name/Model Capacity,
Gallons Construction

Date

GAS-01 Gasoline Fuel Tank 1,950 1987 034120510 Turpentine Storage Tank 28,000 1971 All other insignificant tanks are on the insignificant list.

EUG F13 – Petcoke Hand ling System No. 1

Emission Point EU Name/Model Construction

Date

F13 Petcoke Handling System No. 1 2005

Emissions associated with the Petcoke Ha ndling system are insignificant in nature.

Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generations or for peaking power service not EUG F11 – Miscellaneous Insign ificant Activities

Emission Point EU Name/Model Construction

Date

F11-1 100 KW Caterpillar D100PI Emergency

Generator 1971

F11-2 150 KW Caterpillar D336 Emergency

Generator 1990

F11-3 700 KW Pipeline Basin Emergency Generator 2003 F11-4 25 KW Pipeline Valve HousePERMIT MEMORANDUM 97-057-TV (M-10) - 25 -

exceeding 500 hours per year. The f acility includes four diesel-powered emergency generators totaling 975 kW (1,307 HP) located at the facility.

Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). This cat egory includes the administration building boiler with 2.5 MMBTUH heat input and a sm all boiler in the personnel building.

* Emissions from fuel storage/dispensing equipmen t operated solely for f acility owned vehicles if fuel throughput is no t more than 2,175 gallons/day, averaged over a 30-day peri od. The facility includes a vehicle gasoline fueling tank (GAS-01). The mill also has several diesel tanks with a vapor pressure less than 1.0 psia and less than 10,000 gallons.

Gasoline and aircraft fuel handli ng facilities, equipment, and st orage tanks except those subject
to New Source Performance Standards and st andards in OAC 252:100-37-15, 39-30, 39-41, and 39-48. The facility includes a dies el fuel dispensing operation.

* Emissions from storage tanks constructed with a capacity less than 39, 894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The facility includes a 28,000-gallon turpen tine storage tank (EUG 10).

Site restoration and/or bioremediation activities of <5 years expected duration. None listed but may be conducted in the future.

Hydrocarbon-contaminated soil aer ation pads utilized for soils ex cavated at the facility only. None listed but may be conducted in the future.

*Non-commercial water washing operations an d drum crushing operati ons (less than 2,250 barrels/year) of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material. The facility includ es a drum reclamation operation. The facility also occasionally disposes of empty barrels on-site or recycles them for scrap metal.

Hazardous waste and hazardous materials drum st aging areas. The facility includes a waste

accumulation area.

Sanitary sewage collection and treatment faciliti es other than incinerators and Publicly Owned Treatment Works (POTW); Stacks or vents for san itary sewer plumbing trap s are also included (i.e., lift station).

Emissions from landfills and land farms unless othe rwise regulated by an applicable state or federal regulation. The facility operates a non -hazardous Solid Waste Disposal Facility (EUG F5).

Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. Th e facility includes additional chemical storage for maintenance purposes.

Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. These operati ons are conducted as part of routine maintenance.PERMIT MEMORANDUM 97-057-TV (M-10) - 26 -

* Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. The application listed a total of 263 insignificant activit ies. The insignificant activities included in this category are denoted as such in the in significant activities list maintained and updated on

site.

SECTION VI. EMISSIONS

Valliant Mill has examined aspects of all majo r production areas at the plant to determine the maximum material process rates in order to calcul ate emission rates. Two distinct process rates for each production area or emissions unit have been determined:

• Maximum Short-Term Process Rate

• Maximum Sustainable Process Rate

The maximum short-term process rate is the maximum production rate achievable in one hour. The maximum sustainable process rate is the annual average of the estimated production rate at which a source can operate within its physical a nd operational design. In general, short-term (less than or equal to daily averaging periods) emissions are based on the maximum short-term process rates and long-term (gr eater than daily) average emissions are based on the maximum sustainable process rates.

The Valliant Mill has examined various source s to determine appropriate emission factors, including stack tests, mass bala nces, U.S. EPA AP-42, NCASI t echnical bulletins, vendor data, and regulatory limits. In all cases, engineering judgment is applied to determine the most suitable emission factor for a particular source. For most sources and pollutants, the selected “base emission factor” is then multiplied by a “safety factor” to obtain an “adjusted emission factor.” A safety factor is applied to accoun t for short-term fluctuations in emissions or anomalous stack test conditions that may have affected a given set of testing results. The adjusted emission factor can then be multiplied by a process rate to calculate an emission rate. It should be noted, however, that not all emissi on factors incorporate a safety factor.

The application has requested that all emission factors be kept c onfidential since they were the product of a lengthy and expens ive research project.

Additional rates for Baseline Emissions, Baselin e Accommodated, and Proj ected Actual were utilized (252:100-8-31).

There are 10 primary discharge points for air emissions tabulated following.PERMIT MEMORANDUM 97-057-TV (M-10) - 27 -

SIGNIFICANT DISCHARGE POINTS Discharge
Point Height

Feet Diameter

Inches Flow Rate
ACFM Temperature

o F Main Stack (serves Power Boiler, and Tall Oil System) 296 174 879,812 439

New Recovery Furnace 2 296 149” 7/16 --

Lime Kiln 148 70 71,677 469

Bark Boiler 246 132 242,905 133

Lime Slaker No. 1 50 30 9,876 196

Lime Slaker No. 2 50 30 9,876 196

Brownstock Washer 1 83 28 12,988 110 Package Boiler 69 60 96,368 677

NCG Thermal Oxidizer 119 28 25,092 670 OCC Rejects Baghouse 135 39 10,200 70
1 - All emissions from the Brownstock Washing Area are assumed to emit from one set of washers, since they operate mutually exclusively. 2 - Emissions from the Smelt Dissolving Tank a nd the Spent Liquor mix tanks are routed through the new recovery furnace. Flow rate and Temperature will be provided to DEQ with stack test results .PERMIT MEMORANDUM 97-057-TV (M-10)- 28 -CRITERIA POLLUTANT EMISSIONS SUMMARY (Phase I)EUG OperationPM10CO SO2NOx VOC****TRS***Leadlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYA7No 3 OCC Plant Fugitives-- -- -- -- ---- -- -- 25.06 99.6 -- -- -- --A8OCC Lightweight RejectsHandling System0.46 1.9 -- -- -- -- -- -- -- -- -- -- -- --B1No. 1 Brownstock Washing -- -- -- -- -- -- -- -- 26.57 108.60 0.83 3.37 -- --B2No. 2 Brownstock Washing -- -- -- -- -- -- -- -- 19.19 77.58 1.08 4.38 -- --B3No. 3 Brownstock Washing -- -- -- -- -- -- -- -- 14.76 58.18 0.46 1.81 -- --C1, C2 & C3 No. 1 Paper Machine 3.6 13.14 -- -- -- -- -- -- 310.64 1133.81 -- -- -- --C4, C5 & C6 No. 2 Paper Machine 1.70 6.35 -- -- -- -- -- -- 146.69 548.02 -- -- -- --C7, C8 & C9 No. 3 Paper Machine 1.95 6.57 -- -- -- -- -- -- 168.26 566.92 -- -- -- --D1Bark Boiler90.0 306.6 6,626.7 11399.39 720.0 254.48 270.0 840.08 51.1 174.31 -- -- 0.08 0.29D2 PowerBoiler171.092.991,486.81022.407.49-- -- 0.02D3 PackageBoiler 1.89 6.50 16.2355.860.130.4321.6774.58 17.2 59.1 --------D6New Recovery Furnace 49.07482.561155.39657.3941.256.22 20.25 0.003D2/D6 Comb. Annual Emissions668.3533.97139.43956.0136.90.079E2b Evaporator Sump -- -- -- -- -- -- -- -- 52.63 213.01 16.07 65.05 -- --E5,A &B Slaker Vent No. 1 & 2 0.12 0.39 -- -- -- -- -- -- 66.74 219.27 0.17 0.55 -- --E6Causticizer Vents Combined -- -- -- -- -- -- -- -- 61.88 203.29 0.17 0.55 -- --E7aLime Kiln1.93 5.37 36.30 101.07 14.64 40.72 50.40 140.18 12.00 33.39 2.40 6.68 0.11 0.32E8Tall Oil Plant-- -- -- -- -- -- -- -- 84.56 370.39 0.36 1.56 -- --Unloading at Dumps 1.6 1.5 -- -- -- -- -- -- -- -- -- -- -- --Pulping Material Pile 2.1 1.9 -- -- -- -- -- -- 0.3 1.2 -- -- -- --Hog Fuel Storage Piles 0.5 0.4 -- -- -- -- -- -- 0.1 0.3 -- -- -- --F2 FacilityTraffic 4.5 19.8 -- -- ---- -- -- -- ---- -- -- --PERMIT MEMORANDUM 97-057-TV (M-10)- 29 -EUG OperationPM10CO SO2NOx VOC TRS** *Leadlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYlb/hrTPYaste DF* Road Emissions 6.6 5.8 -- -- -- -- -- -- -- -- -- -- -- --F3aWastewater TreatmentSystem-- -- -- -- -- -- -- -- 312.57 1264.98 27.30 126.80 -- --F3b Wastewater Pipeline** -- -- -- -- -- -- -- -- -- -- -- -- -- --F4a&F4bNCG Collection 7.60.441.591.10.70.5-- --F5 Solid Waste DF* Operations 7.58 1.95 -- -- -- -- -- -- -- -- -- -- -- --F6 Diesel Stormwater Pump 0.4 1.5 1.4 5.9 0.1 0.3 3.9 17.1 0.1 0.6 -- -- -- --F7 &F9No 3 Chip & No 1 ChipScreening/Conditioning1.26 5.16 -- -- -- -- -- -- 4.73 19.11 -- -- -- --Plant-Wide Fugitives -- -- -- -- ---- -- -- 23.77 528.89 26.2 102.5 -- --F11 Misc. Insignificant Activities0.7 0.2 2.1 0.5 0.6 0.2 9.7 2.4 0.8 0.2TOTALS 656 2,546 9,445 14,591 2,652 8,712 1,278 5,353 1,135 4,432 216 844 0 2*DF = Disposal Facility *** TRS as H2S   VOC emissions limitations expressed as propane, methanol, alpha-pinene or a combination. ** WWTS Pipeline H2S 1.98 lb/hr TPY 8.67PERMIT MEMORANDUM 97-057-TV (M-10) - 30 -

Thermal Oxidizer TPY emissions are accounted fo r by the new recovery furnace when operating in backup mode ~June 2007.

VOC emission limitations were initially expressed as carbon in the Title V permit application as well as in previous permits for this facility because; “as-carbon” was used in the mid-1980s, since Method 25A actually measured a signal given off by carbon reacti ng with oxygen in the instrument. If the organic molecules had si ngle bonds, double bonds, or even triple bonds, the signal was the same. So since the measurement me thod couldn’t distinguish the actual form of the VOC, EPA (Laxmi Kesari) sent out a guidance document allowing the wood products industry to express VOC as ca rbon. By 1996, EPA reversed thei r position and said VOC should be shown as it actually is emitted. Remembering the limitati ons of Method 25A, you have to
convert the measured results to an as-emitted mo lecular weight. More recent guidance from EPA (June 2006) indicated no data is readily available for pulp and pape r mills. It was requested for purposes of New Source Review that VOCs be converted from as-carbon basis.

For most wood products, EPA recommended as alpha-pinene (C10H16), which means multiplying the as-carbon weight by 1.13. For most combustion sources, as-propane is sufficiently conservative; you multiply the as- carbon value by 1.22. These work unless you have a significant amount of oxygen in the VOC, as with methanol or formaldehyde. Only the paper
machines and wastewater treatment units have much methanol. In these the “as-carbon” emissions have been multiplied by 2.7. The br ownstock washers have been converted to a combined alpha-pinene/methanol factor. VOCs ha ve been evaluated with alpha-pinene for the chip handling, chip and bark stacks, etc. and me thanol for other process areas, paper machines and WWTS and propane for all other sources.

HAPs and SubChapter 42 Pollutant Emissions Emissions of Subchapter 42 compounds for each primary source at the Valliant Mill were determined using emission factors taken from Na tional Council of the Paper Industry for Air and Stream Improvement (NCASI) Technical bulletins, U.S. EPA AP-42 reference documents, or mill data. Since every pulp and paper product manufacturing facility is unique, the NCASI

bulletins and AP-42 reference documents do not always contain sufficient data to accurately estimate emissions of all Subchapter 42 compound emissions. When a ppropriate, engineering judgment was used to apply mill data, which may or may not be specific to the Valliant Mill, to estimate emissions of Subchapter 42 compounds.PERMIT MEMORANDUM 97-057-TV (M-10) - 31 -

HAP Emissions

CAS Number HAP Emissions

lb/hr TPY 75070 Acetaldehyde 6.21 27.20 98862 Acetophenone 0.13 0.57

107028 Acrolein 1.47 6.40

71432 Benzene 1.20 5.27 92524 Biphenyl 0.04 0.19

75150 Carbon disulfide 0.37 1.60

56235 Carbon tetrachloride 3.42 14.97 463581 Carbonyl sulfide 0.01 0.04

108907 Chlorobenzene 0.29 1.27

67663 Chloroform 2.83 12.39

98828 Cumene 0.16 0.70 100414 Ethyl benzene 0.19 0.85 50000 Formaldehyde 12.11 53.06

118741 Hexachlorobenzene <0.01 <0.01 77474 Hexachlorocyclopentadiene 0.02 0.09

110543 Hexane 3.27 14.33 7647010 Hydrochloric acid 10.76 47.15

67561 Methanol 354.11 1,551.02 108101 Methyl isobutyl ketone 3.82 16.74 75092 Methylene chloride 2.33 10.22 108383 m-Xylene 0.94 4.11 91203 Naphthalene 0.36 1.59 95476 o-Xylene 0.65 2.86

108952 Phenol 0.27 1.19 7723140 Phosphorus 0.10 0.44

123386 Propionaldehyde 0.26 1.12 106423 p-Xylene 1.42 6.20

7782492 Selenium 0.14 0.61

100425 Styrene 1.54 6.75

108883 Toluene 0.80 3.50 79016 Trichloroethylene 1.68 7.36 108054 Vinyl acetate 0.01 0.03 75014 Vinyl chloride 0.02 0.08 79005 1,1,2-Trichloroethane 1.07 4.70 120821 1,2,4-Trichlorobenzene 2.95 12.94

TOTAL 414.95 1,817.54 This facility is a majo r source of HAP emissions.PERMIT MEMORANDUM 97-057-TV (M-10) - 32 -

SECTION VI. BART. REVIEW

To be an affected BART source, a so urce must meet the following criteria:

*the source must fall within the 26 source ca tegory list, *have units which were put in pl ace during the 1962 to 1977 time frame, *and have potential emissions of air pollutants (NO

x , SO 2 , PM 10 , PM 2.5 ) which may reasonably
cause or contribute to vi sibility impairment above 250 TPY from affected units.

In support of BART applicability and permitting activ ities for International Paper's Valliant Mill the following summarizes the modeling results for the BART applicability analysis as requested by Oklahoma DEQ in a letter dated March 28, 2008. The emission rates have been revised to reflect maximum allowable hourly emissions from the sources potentially subject to BART at the Mill. The model results indicate that the proposed emission rates will not exceed the BART threshold of 0.5 ~dv for the 98th pe rcentile impact at any of the four nearest Clas s I Areas. The Class I Areas of concern and distance from the Mill are provided below.

Class I Area Name Distance from source Caney Creek Wilderness 98 km Hercules-Glades Wilderness 354 km Upper Buffalo Wilderness 253 km Wichita Mountains National Wildlife Refuge 337 km

BACKGROUND

The Valliant Mill applied for a BART waiver on December 1, 2006. As part of the waiver application, the Mill proposed to limit emissions from the facility in order to achieve the BART waiver. However, DEQ expressed concern that the modeled emission rates were not representative of maximum hist orical operations and noted th at the maximum 24-hour average emission rate during the 2001 to present timeframe was the appropriate scenario to model. The Mill applied for and obtained a new constr uction permit, (No. 97-057-C (M-9) PSD), that allowed the construction of several new sources and the modification of existing sources. As part of the permitting process, the Mill modi fied existing permit limits to accommodate the potential changes to the Mill. A Title V ope rating permit (No. 97-057-TV) incorporating these changes was issued on October 17, 2008.

Upon review of the BART waiver application, DEQ noted that the emi ssion rates contained in Title V permit No. 97-057-TV, did not corres pond with the emission rates in the BART submittal. International Paper has revised mode ling results to demonstrate compliance with the BART threshold of 0.5 ~dv for the 98th percentile impact at any of the four nearest Class I Areas, as requested by DEQ. These modeled emissi on are rates being incor porated into the Title V operating permit as emission limits which will b ecome effective five years after the date of EPA’s approval of the DEQ's BART State Implem entation Plan. Emissions in this modified permit have been revised to reflect the most curre nt and accurate emission rates available for the
Mill.PERMIT MEMORANDUM 97-057-TV (M-10) - 33 -

SOURCE EMISSIONS AND PARAMETERS

Revised emissions at the Mill include the Bark Boiler, Power Boiler, Package Boiler, and the existing Lime Kiln system. As part of the BA RT analysis process, International Paper has discovered that in order to not exceed the BA RT threshold of 0.5 deciview (~dv) for the 98th percentile impact while operating the Bark Boiler using fuel oil, operati ons would have to be limited significantly. As part of the PSD pe rmit application, the Mill requested permitting of multiple operating scenarios (described in the app lication as Phases 3A and 3B). Since the Mill is permitted to operate under eith er scenario, it was necessary to demonstrate BART-waiver status for both situations. In addition, in order to maintain some operational flexibility, International Paper has opted to model two operational scenarios for Phase 3B emissions. The modeled scenarios are as follows:

*Phase 3A - Bark Boiler emissions were not mo deled as it has been removed from operation in the Phase 3A scenario and fuel sulfur content in the Power Boiler was reduced to a level
that assured no modeled exceedance of the BART threshold occurred; *Phase 3B (fuel oil) - emissions from the Bark Boiler and Power Boiler were based on continuously firing fuel oil; and *Phase 3B (non-fuel oil in Bark Boiler) - emi ssions from the Bark Boiler were based on burning bark/wood waste, while emissions from the Power Boiler were based on firing fuel
oil.

Summaries of changed rates are included in the tables below.

EMISSION RATES (PREVIOUSLY PERMITTED PHASE 3A)

Point

ID Source Name S0 2 lbs/hr S0 4 lbs/hr NO X lbs/hr PM 10 lbs/hr PM 2.5 lbs/hr EC
lbs/hr SOA
lbs/hr

D1 Bark Boiler -- -- -- -- -- -- -- D2 Power Boiler 1,486.80 65.10 255.60 104.31 -- -- 23.94 D3 Package Boiler 0.13 -- 21.67 0.47 1.42 -- --

E5 Lime Slakers -- -- -- -- 0.12 -- --

E7 Lime Kiln System (Phase 2 Limits) 14.65 1.80 85.59 6.47 2.06 0.19 0.07

Note: PM speciation for the Power Boiler is based on AP-42 (9/98) Table 1.3-1 & 1.3-2, NO.6 oil fuel

ESTIMATED EMISSION RATES (24-HOU R AVERAGE) (REVISED PHASE 3A)

Point

ID Source Name S0 2 lbs/hr S0 4 lbs/hr NO X lbs/hr PM 10 lbs/hr PM 2.5 lbs/hr EC
lbs/hr SOA
lbs/hr

D1 Bark Boiler -- -- -- -- -- -- --

D2 Power Boiler 933.91 31.45 255.60 121.38 -- -- 1.61 D3 Package Boiler 0.13 -- 21.67 0.47 1.42 -- --

E5 Lime Slakers -- -- -- -- 0.12 -- --

E7 Lime Kiln System (Phase 2 Limits) 14.65 1.80 85.59 6.47 2.06 0.19 0.07

Note: PM speciation for the Power Boiler is based on AP-42 (9/98) Table 1.3-1 & 1.3-2, NO.6 oil fuelPERMIT MEMORANDUM 97-057-TV (M-10) - 34 -

EMISSION RATES (PREVIOUSLY PERMITTED PHASE 3B)

Point

ID Source Name S0 2 lbs/hr S0 4 lbs/hr NO X lbs/hr PM 10 lbs/hr PM 2.5 lbs/hr EC
lbs/hr SOA
lbs/hr

D1 Bark Boiler 720.00 22.35 270.00 1.80 88.20 -- -- D2 Power Boiler 1,486.80 65.10 255.60 104.31 -- -- 23.94 D3 Package Boiler 0.13 -- 21.67 0.47 1.42 -- --

E5 Lime Slakers -- -- -- -- 0.12 -- --

E7 Lime Kiln System (Phase 2 Limits) 14.65 1.80 85.59 6.47 2.06 0.19 0.07

Note: PM speciation for the Bark Boiler is based on AP-42 (9/0 3) Table 1.6-5, wood-bark-fired boilers. Power Boiler speciation is based on
AP-42 (9/98) Table 1.3-1 & 1.3-2, NO.6 oil fuel

ESTIMATED EMISSION RATES (24-HOUR AVERAGE) (REVISED PHASE 3B - FUEL OIL OPERATION)

Point

ID Source Name S0 2 lbs/hr S0 4 lbs/hr NO X lbs/hr PM 10 lbs/hr PM 2.5 lbs/hr EC
lbs/hr SOA
lbs/hr

D1 Bark Boiler 135.00 12.82 270.00 39.38 -- -- 1.61

D2 Power Boiler 168.10 12.82 255.60 39.38 -- -- 1.61 D3 Package Boiler 0.13 -- 21.67 0.47 1.42 -- --

E5 Lime Slakers -- -- -- -- 0.12 -- --

E7 Lime Kiln System (Phase 2 Limits) 14.65 1.80 85.59 6.47 2.06 0.19 0.07

Note: PM speciation for the Power Boiler is based on AP-42 (9/98) Table 1.3-1 & 1.3-2, NO.6 oil fuel

ESTIMATED EMISSION RATES (24-HOUR AVERAGE) (REVISED PHASE 3B - NON-FUEL OIL (IN THEBARK BOILER) OPERATION)

Point

ID Source Name S0 2 lbs/hr S0 4 lbs/hr NO X lbs/hr PM 10 lbs/hr PM 2.5 lbs/hr EC
lbs/hr SOA
lbs/hr

D1 Bark Boiler 135.00 5.51 270.00 1.80 88.20 -- --

D2 Power Boiler 252.15 13.57 255.60 42.66 -- -- 1.61 D3 Package Boiler 0.13 -- 21.67 0.47 1.42 -- --

E5 Lime Slakers -- -- -- -- 0.12 -- --

E7 Lime Kiln System (Phase 2 Limits) 14.65 1.80 85.59 6.47 2.06 0.19 0.07

Note: PM speciation for the Bark Boiler is based on AP-42 (9/0 3) Table 1.6-5, wood-bark-fired boilers. Power Boiler speciation is based on
AP-42 (9/98) Table 1.3-1 & 1.3-2, NO.6 oil fuel

MODELING METHODOLOGY

CALPUFF system parameters and variables used in this analysis remain consistent with the refined modeling protocol submitted on December 1, 2006, as well as with the previous modeling analysis submitted March 30, 2007. The ve rsions of the CALPUFF modeling system programs used for International Paper's modeling are listed in the table below, which also compares the program versions used with the program versions recommended by CENRAP. Note that some of the program versions are not the same as the program versions recommended by CENRAP. Certain programs were utilized in order to avoid data compatibility issues with previous versions of the CALPUFF system. Model selection was based on the previous BART modeling performed for the Mill and was primarily driven by a desire to utilize the most recent release of CALMET at the time of the init ial BART modeling. CALPUFF and CALPOSTPERMIT MEMORANDUM 97-057-TV (M-10) - 35 -

executable versions were then selected as ap propriate for compatibility. All aspects and variables of the updated modeling analysis have remained unchanged and are identical to the previously submitted modeling reports. Only the source emission rates have been modified.

CALPUFF MODELING SYSTEM VERSION NUMBERS

Program CENRAP Suggested Valliant Mill Refined Analysis Reason for Difference Version Level Version Level

TERREL 3.311 030709 3.311 030709

CTGCOMP 2.42 030709 2.22 030528 Version recommended
is not available

CTGPROC 2.42 030709 2.42 030709

MAKEGEO 2.22 030709 2.22 030709

CALMM5 2.4 050413 2.4 050413

CALMET 5.53a 040716 6.211 060414 Most recent release of

CALMET CALPUFF 5.711a 040716 6.112 060412 Use version compatible with

CALMET v6.211

POSTUTIL 1.4 040818 1.4 040818 CALPOST 5.51 030709 6.131 060410 Use version compatible with

CALPUFF 6.112

MODEL RESULTS

The 98 th percentile values indicate that the Valliant Mill’s contributi on to visibility impairment is below the 0.5 ~dv threshold at Caney Creek. The 98 th percentile at Upper Buffalo for the same period was modeled to be less th e 0.119 ~dv. Other Class I areas are further away and have ~dv impacts which are less yet. These results indicate that the Valliant Mill is eligible for a waiver from BART requirements.

Phase 3a Visibility Results 98 th % ~ dv

Cane y Cree k Herc-Glades U pp er Buffalo Wichita Mts.
2001 0.433 0.014 0.182

-- 2002 0.417 0.013 0.174

-- 2003 0.323 0.003 0.095

--

Phase 3b (Non fuel oil) Visibility Results 98 th % ~ dv

Cane y Cree k Herc-Glades U pp er Buffalo Wichita Mts.
2001 0.486 0.008 0.125

-- 2002 0.390 0.010 0.122

-- 2003 0.495 0.007 0.109

--PERMIT MEMORANDUM 97-057-TV (M-10) - 36 -

Phase 3b (fuel oil) Visibility Results 98 th % ~ dv

Cane y Cree k Herc-Glades U pp er Buffalo Wichita Mts.
2001 0.495 0.008 0.142

-- 2002 0.389 0.010 0.116

-- 2003 0.497 0.007 0.107

--

MODIFIED PERMIT LIMITS

International Paper has modeled two operational scenarios for Phase 3B emissions. As such, separate permit limits must be established for each operation scenario. The following tables provide a summary of the revised permit limits for those units with reduced emission rates.

PHASE 3A PERMIT LIMITS (24-HOUR AVERAGE)

Point ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

Dl Bark Boiler -- -- --

D2 Power Boiler 933.91 255.60 132.09

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) - FUEL OIL OPERATION OF BOTH BARK BOI LER AND POWER BOILER

Point ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

Dl Bark Boiler 135.00 270.00 50.09

D2 Power Boiler 168.10 255.60 50.09

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) - NON FUEL OIL OPERATION OF THE BARK BOILER

Point ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

DI Bark Boiler 135.00 270.00 90.00

D2 Power Boiler 252.15 255.60 53.37

The permit has been modified to require complia nce with the proposed limits within five years of the Oklahoma Regional Haze SIP approval by EPA.

SECTION VIII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Prov isions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporati on by Reference) [Applicable] The purpose of this Subchapter is to incorporate by reference applicable provisions of Title 40 of the Code of Federal Regulations. The provisions of Title 40 of the Code of Federal RegulationsPERMIT MEMORANDUM 97-057-TV (M-10) - 37 -

listed in OAC 252:100, Appendix Q are hereby inco rporated by reference as they existed on September 1, 2006.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Primary Standards are in Appendix E and Seconda ry Standards are in Appendix F of the Air Pollution Control Rules. At this time, all of Okla homa is in attainment of these standards.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. VOCs will be tracked on an as-carbon basis for annual emissions inventory

purposes.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requir ements for Part 70 permits. Any planned changes in the operation of the facility which re sult in emissions not authorized in the permit and which exceed the “Insignificant Activities” or “Trivial Activities” thre sholds require prior notification to AQD and may require a permit modification. Insignif icant activities mean
individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:

• 5 TPY of any one criteria pollutant

• 2 TPY of any one hazardous air pollutant (HAP ) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission operating limits have been established based in perm its: 75-011-O, 75-012-O, 86-019- O, 91-093-O, 95-224-O, 96-043-C(PSD), 96-043- C(M-1), 96-043-C(M-2)(PSD), 96-043-C(M3)(PSD), 96-043-C(M-5)(PSD), 96-188-C, 97-0 57-C, 99-134-C, 97-057-C (M-4)(PSD), 97-057- C (M-8)(PSD) and 97-057-C (M-9) (PSD) for Phase I. These limits are incorporated into the Title V permit according to the following table.

EXISTING PERMIT REQUIREMENTS

Permit Number Units Involved Permit Status

75-011-O Chip air separation Removed from mill – permit void

75-012-O Lime Slaker Superseded by Permit No. 96-043-C (M-2)(PSD)

86-019-O Package Boiler Superseded by Permit No. 96-043-C (M-2)(PSD);

91-093-O OCC rejects handling, Bark

Boiler Superseded by Permit No. 96-043-C (M-2)(PSD) 95-224-O Diesel-powered water pump Incorporated into Title V permit 96-043-C (PSD) Bark Boiler, Package Boiler, pulp mill, No. 1 and No. 3

Paper Machines, NCG
Thermal Oxidizer Superseded by Permit No. 96-043-C (M-2)(PSD)

96-043-C (M-1) Wood chip screening/ conditioning unit Incorporated into Title V permitPERMIT MEMORANDUM 97-057-TV (M-10) - 38 -

96-043-C (M-2)(PSD) Alternate opacity limit for the Recovery Furnace Limit retired in 1998 by Air Quality
Council 96-043-C (M-3)(PSD) No. 2 and No. 3 Paper Machines, No. 3 OCC Plant,
No. 2 Power Boiler Incorporated into Title V permit (No. 2 Power Boiler will not be constructed) 96-043-C(M-5)(PSD) Lime Kiln (Petcoke) Incorporated into Title V permit

96-188-C Wood chip screening/ conditioning unit Incorporated into Title V permit

97-057-C WWTS Pipeline permit Inco rporated into Title V permit

99-134-C NCG Thermal Oxidizer, Steam Stripper System Incorporated into Title V permit

97-057-C (M-4)(PSD) Phased constructio n Superseded by 97-057-C (M-9) (PSD) 97-057-C (M-8)(PSD) Phased constructio n Superseded by 97-057-C (M-9) (PSD) except the WWTS Pipeline – incorporated into Title V permit 97-057-C (M-9)(PSD) Phased construction Phase I incorporated into Title V permit

OAC 252:100-9 (Excess Emission Re porting Requirements) [Applicable] Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess emissions shall notify the Director as soon as possible, but no later th an 4:30 p.m. the following working day of the first occurren ce of excess emissions in each exces s emissions event. No later than thirty (30) calendar days after the start of any excess emission event, the owner or operator of an air contaminant source from which excess emissions have occurred shall submit a report for each excess event describing the extent of the event and the actions taken by the owner or operator in response to this ev ent. Request for affirmative defense, as described in OAC 252:100-9-8, shall be included in the excess emissi ons event report. Add itional reporting may be required in the case of ongoing emission events and in the case of excess emissions reporting required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable] Open burning of refuse and other combustible mate rial is prohibited except as authorized in the specific examples and under the cond itions listed in this subchapter.

OAC 252:100-19 (Particulate Matter (PM)) [Applicable] This subchapter is applicable to the Lime Kiln, the several bo ilers, and the Recovery Furnace but not to the NCG Thermal Oxidizer. “Fuel-burning e quipment” is defined as boilers, gas turbines, or other combustion devices and all appurtenances thereto used to convert fuel or waste into useable heat or power. The Thermal Oxidizer do es not provide any usea ble heat or power and, therefore, does not meet the defini tion of fuel-burning equipment.

Subchapter 19 specifies PM emissions limitations based on heat input capacity. The following table lists applicable standards by unit and anticipated PM emissions. For most of the combustion devices, applicable permit limitations are more st ringent than Subchapter 19.PERMIT MEMORANDUM 97-057-TV (M-10) - 39 -

COMPARISON OF PM EMISSIONS TO LIMITATIONS OF OAC 252:100-19 Unit Heat Input Capacity,

MMBTUH PM Emission
Limitation of OAC 252:100-19,
lb/MMBTU PM Emission Rate,
lb/MMBTU

Bark Boiler confidential 0.21 0.10

Power Boiler confidential 0.20 < 0.20 Package Boiler confidential 0.29 0.0150 New Recovery

Furnace confidential 0.19 <0.19

Lime Kiln confidential 0.30 < 0.30

Diesel Stormwater Pump confidential 0.60 < 0.60

Subchapter 19 specifies a limit of PM emission s from wood-waste burning equipment of 0.35 lb/MMBTU. The Bark Boiler is subject to this standard. Emissions from the Bark Boiler are limited to 0.1 lb/MMBTU, which is in compliance with Subchapter 19.

This subchapter limits emissions of particulate matter from processes ot her than fuel-burning equipment based on their process weight rate. The following table compares the emissions rates
of PM with the allowable PM emissions under S ubchapter 19, showing that the facility is in compliance.
COMPLIANCE WITH SUBCHAPTER 19

Operation Process Weight Rate, TPH Allowable PM Emissions per Subchap. 19, lb/hr Permitted PM Emissions, lb/hr
Smelt Dissolving Tank confidential * 46.3**

Lime Slaker No. 1 confidential * 1.8

Lime Slaker No. 2 confidential * 1.8

Lime Kiln confidential * 52.2
No. 1 Line Chip Screening & Conditioning Unit 44.5 * 1.5

No. 3 Line Chip Screening & Conditioning Unit 57.9 * 1.5

* Allowable PM emission rates fo r these units have been verifi ed from confidential information. **SDT covered by Subpart MM. Emissions routed to Recovery Furnace (permit limit)

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except fo r short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any cons ecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. Compliance with this subchapter will be required by the permit.

OAC 252:100-29 (Fugitive Dust) [Applicable] Subchapter 29 prohibits the handling, transportati on, or disposition of any substance likely to become airborne or wind-borne without taking “reasonable precautions” to minimize emissionsPERMIT MEMORANDUM 97-057-TV (M-10) - 40 -

of fugitive dust. No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the em issions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Most of the materials handled are wood/wood waste, th erefore non-brittle and not ve ry susceptible to becoming fugitive dust. Haul roads and the Solid Waste Disposal Facility are watered to minimize emissions of fugitive dust.

OAC 252:100-31 (Sulfur Compounds ) [Applicable]

Part 2 limits the ambient air impact of sulfur dioxide (SO 2 ) emissions from any existing facility or any new petroleum and natura l gas process facility subjec t to OAC 252:100-31-26(a)(1). The ambient air quality modeling summarized in the following table demonstrates compliance with
the SO 2 standards.

COMPLIANCE WITH SO 2 AMBIENT IMPACTS LIMITATIONS Averaging Period Ambient SO 2 Impacts Limitation, ug/m 3 Modeled SO 2 Impacts, ug/m 3

3-Hours 650 299

24-Hours 130 104

Part 2 also limits H 2 S Impacts to the ambient limitation of 0.2 ppm (24hrs average). The facility has demonstrated compliance with this requirement.

Part 3 specifies limitations on total reduced sulfur compounds emissions. The following table lists the standards of Subchapter 31 for existing Kraft paper mills.

COMPLIANCE WITH TRS EMISSIONS LIMITATIONS

Emission Unit TRS Emission Limitation of OAC 252:100-31 (12-hour average as

H 2 S on a dry basis) TRS Emission Rate Test

Results

Recovery Furnace 40 ppm @ 8% O 2 1.02 ppm @8% O 2 (2007)

Lime Kiln 40 ppm @ 10% O 2 31.3 ppm @10% O 2 (1989)

Smelt Dissolving Tanks 0.016 g TRS per kilogram (0.033 lb/ton) black liquor solids Emits through the new Recovery Furnace (2007) NCG Thermal Oxidizer, when

incinerating NCGs from the

evaporators and digesters 5 ppm by volume 0.9 ppm (4/5-6/02 stack test)

Part 5 limits sulfur dioxide emissions from new e quipment (constructed af ter July 1, 1972). For gaseous fuels, the limit is 0.2 lbs/MMbtu heat i nput; for liquid fuels, the limit is 0.8 lb/MMBTU; and for solid fuels, the limit is 1.2 lb/MMBTU. The permitted SO 2 emission rates are much more stringent than Subchapter 31 limits.

Part 5, Section 27 addresses sulfur oxide emission limits fr om blow pits, washer vents, storage tanks, digester relief, and recovery furnace of any new pulp mill. The Valliant Mill began operation in 1971 however the facility has been modified since 1972 may be subject to this

section. The issue is curre ntly under review by DEQ.PERMIT MEMORANDUM 97-057-TV (M-10) - 41 -

OAC 252:100-33 (Nitrogen Oxides) [Applicable] Subchapter 33 affects new fuel -burning equipment with a rate d heat input of 50 MMBTUH or more. The following table compared anticipated NOx emission rates with applicable limitations of Subchapter 33. The Diesel Stormwater Pump has a rated heat input we ll below the de minimis and is not subject to this subchapter. The Lime Kiln and Power Boiler were constructed prior to 1972 and are not subject to this subchapter.

COMPLIANCE WITH NOx EMISSIONS LIMITATIONS Unit Primary Fuel Type NOx Emission Limitation of OAC 252:100-33,
lb/MMBTU* NOx Emission Rate,
lb/MMBTU

Bark Boiler Solid 0.7 0.3 Package Boiler Gas 0.2 0.1 New Recovery

Furnace Solid (supplemental gas) 0.181 short term

* Three-hour averages calculated as NO 2

OAC 252:100-35 (Carbon Monoxide) [Not Applicable] None of the following affected proc esses are part of this project: gr ay iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic reformi ng unit or petroleum catalytic cracking unit.

OAC 252:100-37 (Volatile Organi c Compounds) [Applicable]

Part 3 requires storage tanks cons tructed after December 28, 1974, w ith a capacity of 400 gallons or more and containing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an orga nic vapor recovery system. This affects the gasoline storage tank, but all othe r tanks have vapor pressures below the 1.5 psia threshold.

Part 5 limits the VOC content of coating or othe r operations. This faci lity does not normally conduct coating or painting operations except fo r routine maintenance of the facility and equipment which is exempt.

Part 7 affects effluent water separa tors. This requirement affects only processing of organic materials with a vapor pressure above 1.5 psia. Th erefore, this requireme nt is not applicable.

Part 7 also requires all reciprocating pumps and comp ressors to be equipped with packing glands that are properly installed and maintained in go od working order. The equi pment at this location is subject to this requirement.

Part 7 also requires fuel-bur ning equipment to be operated and maintained so as to minimize emissions. Temperature and available air must be sufficient to provide essentially complete combustion. The equipment at this locati on is subject to this requirement.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable] This Subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in areas of concern (AOC). Any wo rk practice, material substituti on, or control equipment required by the Department prior to June 11, 2004, to c ontrol a TAC, shall be retained, unless a modification is approved by the Director. Since no AOC has been designated there are no specific requirements for this facility at this time.PERMIT MEMORANDUM 97-057-TV (M-10) - 42 -

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirement s for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Okla homa to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing mu st be conducted by methods appr oved by the Air Quality Director and under the direction of qualified personnel. A no tice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any fede ral or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conduc ted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information re levant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-07 Permits for Minor Fa cilities not in source category

OAC 252:100-11 Alternative Emi ssions Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevator s not in source category

OAC 252:100-39 Nonattainment Ar eas not in source category

OAC 252:100-47 Landfills not in source category

SECTION IX. FEDERAL REGULATIONS

Protection of Visibility, 40 CFR 51 S ubpart P [Applicable] The primary purposes of this subpart are to re quire States to develop programs to assure reasonable progress toward meeting the national goal of preventing any future, and remedying any existing, impairment of visibility in ma ndatory Class I Federal areas which impairment results from manmade air pollution; and to establish necessary additional procedures for new source permit applican ts, States and Federal Land Managers to use in conducting the visibility impact analysis required for new sources unde r §51.166. This subpart sets forth requirements addressing visibility impairment in its two principal forms: “reasonably attributable” impairment (i.e., impairment attributable to a single source/small group of sources) and regional haze (i.e., widespread haze from a multitude of sources whic h impairs visibility in every direction over a large area). Regional haze visibility impairment is partially addressed through the Best Available Retrofit Technology (BART) process. The facility has been determined to be subject to a BART
review.

Best Available Retrofit Technology requireme nts for regional haze visibility impairment. Valiant
must either submit a BART review or a demons tration that the BART-e ligible sources do notPERMIT MEMORANDUM 97-057-TV (M-10) - 43 -

cause or contribute to any impairment of visi bility in any mandatory Class I Federal area. As indicated in Section VI., Valiant proposed to ta ke enforceable limits, such that, they would not cause or contribute to any impa irment of visibility in any mandatory Class I Federal area. Requirements to comply within 5 years of SI P approval have been added to the permit.

PSD, 40 CFR Part 52 [Not Applicable] The facility has been issued several PSD permits. These permits were issued following demonstrations that insure that the facility w ill not cause or contribute to a violation of a NAAQS, PSD increment, or adversely affect visib ility or other air quality related value (AQRV). Emissions limitations of five of these PSD permits have been incorporated into this permit. The facility is a major source for NOx, CO, SO 2 , PM 10 , and VOC. Any future increases must be evaluated in the context of PSD signifi cance levels: 40 TPY NOx, 100 TPY CO, 40 TPY SO 2 , 15

TPY PM 10 , 40 TPY VOC, 10 TPY TRS, or 0.6 TPY lead.

NSPS, 40 CFR Part 60 [Subparts A, D, Db, BB are Applicable] Subpart A (General Provisions) requires the submittal of several notifications for NSPS-affected sources. These provisions apply and a ppropriate notifications are required. Subpart D (Steam Generating Units) affects boilers w ith a rated heat input greater than 250 MMBTUH which commenced construction, reconstr uction, or modification after August 17, 1971. This subpart affects the Bark Boiler, sp ecifying emissions limitations of 0.8 lb/MMBTU

SO 2 , 0.10 lb/MMBTU PM, and 0.3 lb/MMBTU NO x. CEMS systems measuring opacity, NOx,

SO 2 , and a diluent gas (CO 2 or O 2 ) are required. Subpart Db (Steam Generating Units) affects boilers with a rated heat input of greater than 100 mmBtu per hour heat input. The Recovery Furnace is subject to Subpart D b, but the facility has requested an enforceable condition limiting natura l gas firing to a 10% annual capacity factor Subpart Kb (Volatile Organic Materials Storage Vesse ls) affects tanks w ith a capacity above 19,813 gallons which commenced construction, rec onstruction, or modification after July 23, 1984. The facility records of ta nk dimensions, capacity, and maximu m true vapor pressure show that vessels storing organic liq uids have true vapor pressure s below 0.5. Here, the storage temperature of black liquor is relatively constant since the process genera ting the black liquor is kept at a relatively constant temperature. Bo th distillate and residual fuel oils have vapor pressures below 0.01 psia at 60 o F. The tanks are not subject to subpart Kb. Subpart Y (Coal Preparation Plant) affects thermal dryers, pneumatic coal cleaning equipment (air tables), coal processing and conveying e quipment (including breaker s and crushers), coal storage systems, and coal transfer and loadin g systems at any coal preparation plant that

commences construction or modification af ter October 24, 1974. The Valliant Mill is not considered a coal preparation plant, as it does not operate any of the pr ocesses identified in 40 CFR 60.251(a) breaking, crushing, screening, wet or dry cleaning, and thermal drying of coal. Therefore, this subpart is not applicable. Subpart BB (Kraft Paper Mills) affects each digest er system, brown stock washer system, multiple-effect evaporator, recovery furnace, sm elt dissolving tank, lime kiln, and condensate stripper system (i.e., steam stripping system) in kraft pulp mills, for which construction, modification, or reconstruction is commenced after September 24, 1976. The No. 2 brownstock washer and spent liquor concentrat or were modified after the effe ctive date, therefore they are subject to NSPS Subpart BB. No add-on cont rols were required for the No. 2 brownstock
washer direct emissions. The Lime Kiln and the NCG Thermal Oxidizer are pollution controlPERMIT MEMORANDUM 97-057-TV (M-10) - 44 -

devices for equipment subject to Subpart BB. Subpart BB prohibits discharge into the atmosphere of gases which contain total reduc ed sulfur (TRS) in excess of 5 ppm by volume unless the gases are combusted in an incinerator or other device not subject to the provisions of this subpart and are subjected to a minimum temperature of 1,200 o F for at least 0.5 seconds. Subpart BB requires a continuous monitoring system and describes excess emissions as periods
in excess of 5 minutes in duration in which the combustion temperature at the point of

incineration is less than 1,200 o F. The applicant will maintain compliance with NSPS Subpart BB by continuously monitoring the control device combustion temp erature and using engineering calculations to determ ine residence time. The Lime Kiln is subject to 40 CFR 60, Subpart BB when combusting exhaust gases as a back up to the NCG Collection System and Thermal Oxidizer. The new Recovery Fu rnace is the primary combustion source for NCGs/SOGs. The new Smelt Dissolving Tank and Mix Tanks emit through the Recovery

Furnace. Subpart IIII , Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. This subpart affects st ationary compression ignition (CI) internal combustion engines (ICE) based on power and di splacement ratings, depending on date of construction, beginning with those constructe d after July 11, 2005. For the purposes of this subpart, the date that construction commences is the date the engine is ordered by the owner or operator. The fac ility is not currently subject to this subpart, but shall comply with the provisions of Subpart IIII if they in stall any subject equipment later. Subpart JJJJ , Stationary Spark Ignition (SI) Internal Combustion Engines (ICE). This subpart was proposed on June 12, 2006. For the purposes of this subpart, the date of construction is the date the engine is ordered by the owner or operato r. All owners or operators of SI ICE will be required to keep records of all maintenance conducted on an engine per 40 CFR 60.4245(a)(2). The facility is not currently subject to this subpart, but shall comply with the provisions of Subpart JJJJ if they install any subject equipment later. Subpart WWW (Municipal Solid Waste Landfills) is not applicable. The mill Solid Waste Disposal Facility does not receive municipal solid waste as defined by the regulation.

NESHAP, 40 CFR Part 61 [Subpart E Applicable] Subpart E (Mercury Emissions) affects wastewat er treatment sludge incineration, limiting mercury emissions to 3,200 grams per 24-hour peri od. This standard affects the Bark Boiler which is used to dispose of water treatment sludge. The permit requires compliance with all applicable requirements.

NESHAP, 40 CFR Part 63 [Subparts S and MM, are Applicable] There are three subparts which affect the Pulp and Paper Industry. Th e provisions of these subparts apply to a major source that uses the following processes and materials:

1. Kraft, soda, sulfuric, or semi-chemi cal pulping processes using wood; or

2. Mechanical pulping proc esses using wood; or

3. Any process using secondary or non-wood fibers.

Subpart S (Pulp & Paper Industry) establishes MACT standards for control of HAPs pulp and paper production which were finalized and publ ished in the Federal Register on April 15, 1998. These standards will affect knotter systems (w ood knot removal systems), pulp screens, pulp washing systems, decker systems, digester vents, evaporator system vent s, turpentine recovery systems, weak liquor evaporators, and other high-volume-low-concentration (HVLC) and low-PERMIT MEMORANDUM 97-057-TV (M-10) - 45 -

volume-high-concentration (LVHC) systems. Th ese units are currently vented to the NCG collection system and combusted. The pulp wa shing systems are using the Clean Condensate
Alternative 40 CFR 63.447.

There are several units not affected by Subpart S but which do have significant HAP emissions.
In addition to the No. 3 Brownsto ck washer (semi-chemical proces s), Subpart S does not affect the paper machines; applicability ends at the last pulp washing step. The OCC plants are “secondary fiber” processes, but the only standards of Subpart S which affect secondary fiber processes are for bleaching units; there is no bleaching unit at this facility. Subpart MM establishes MACT standards for cont rol of HAPs from chemical recovery
combustion sources which were finalized a nd published in the Fe deral Register on January 12, 2001. These standards affect recove ry furnaces, smelt dissolving tanks, and lime

kilns. Subpart DDDDD , Industrial Boilers and Process H eaters. Subpart DDDDD regulated HAP emissions from industrial boilers and process he aters. In March, 2007, the EPA filed a motion to vacate and remand this rule back to the agency. The rule was vacated by court order, subject to appeal, on June 8, 2007. No appeals were made and the rule was v acated on July 30, 2007. Existing and new small gaseous fuel boilers a nd process heaters (less than 10 MMBtu/hr heat rating) were not subject to any standards, recordkeeping, or notifications under Subpart

DDDDD.

EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting authorities should take regarding MACT determin ations under either S ection112(g) or Section 112(j) for sources that were affected sources under Subpart DDDDD and ot her vacated MACTs. It is expected that the guidance (or rule) will establish a new timeline for submission of section 112(j) applications for vacated MACT standards. At this time, AQD has determined that a 112(j) determination is not needed for sources po tentially subject to a vacated MACT, including Subpart DDDDD. This permit may be reopened to address Section 112(j) when necessary.

Compliance Assurance Monitoring, 40 CFR 64 [Not Applicable] Compliance Assurance Monitoring, as publishe d in the Federal Register on October 22, 1997, applies to any pollutant specific emission unit at a major source, which is required to obtain a Title V permit, if it meets all the following criteria:

• It is subject to an emission limit or standard for an applicable re gulated air pollutant.

• It uses a control device to achieve compliance wi th the applicable emission limit or standard.

• It has potential emissions, prior to the control device, of the applicable regulated air pollutant
of 100 TPY.

The lime kiln, recovery furnace and bark boiler have potential PM emissions, prior to the control device, of more than 100 TPY. However, the lime kiln and recovery furnace are subject to an emission limit for PM under 40 CFR 63 Subpart MM. The bark boiler is subject to NSPS Subpart D. Emissions of PM from the bark boiler are controlled by a wet scrubber and specific conditions are in the permit for monitoring of control parameters for the wet scrubberPERMIT MEMORANDUM 97-057-TV (M-10) - 46 -

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility does not store any regulated substance above the ap plicable thresh old limits. More information on this federal program is avai lable at the web site: http://www.epa.gov/ceppo/

.

Acid Rain, 40 CFR Part 72, 73, 75 and 76 (Permit Requirements) [Not Applicable] Currently the Valliant Mill does no t sell electricity back to the gr id. If the mill elects in the future to sell more than 25 MW of electricity ba ck to the grid, potential applicable requirements
will be reviewed.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F Applicable] These standards require phase out of Class I & II substances, reduc tions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-deple ting substances (Subparts A & C) ; control servic ing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximi ze the substitution of safe alternatives to Class I and Class II substances (Subpart D); requi re warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozon e-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of Halons (Subpart H). Subpart A identifies ozone-depleting substances and divides them into two classes. Class I
controlled substances are divided into seve n groups; the chemicals typically used by the manufacturing industry include ca rbon tetrachloride (Class I, Gr oup IV) and methyl chloroform (Class I, Group V). A complete phase-out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chlo roform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. A complete phase- out of Class II substances, scheduled in phases starting by 2002, is required by January 1, 2030.

To the extent that the facility has air-conditioning units/fir e systems that apply, the permit requires compliance with Part 82.

SECTION X. COMPLIANCE

Inspection/Testing

On June 25, 2009 a full compliance evaluation was conducted at the Valliant Paper Mill. Brandie Czerwinski, Environmen tal Programs Specialist for the Department of Environmental Quality (DEQ), Air Quality Division, of the Regional O ffice at Tulsa conducted the unannounced onsite evaluation. Ms. Kathryn Crenwe lge, EH&S Manager and Mr. Brad Burris, Senior Environmental Engineer w ith International Paper (IP) re presented the company during the evaluation. The Valliant Paper Mill was evaluated to determin e compliance with federal and state air quality regulations as well as the active operating and construction permits. No violations were noted during the evaluation; however, information was requested from the facility determine compliance with specified regulations. Details of the inspec tion can be found in thePERMIT MEMORANDUM 97-057-TV (M-10) - 47 -

Full Compliance Evaluation document “FCE – 4381.” No additional inspection is required for issuance of this permit.

The following table summarizes stack testing results.

Emission Unit Applicable Requirements Stack Test Results Test

Date

D1: Bark Boiler PM: 0.10 lb/MMBTU PM: 0.091 lb/MMBTU 6/7/96

CO: 3.01 lb/MMBTU CO: 0.53 lb/MMBTU 6/7/96

SO 2 : 0.8 lb/MMBTU SO 2 : 0.24 lb/MMBTU 6/5/96

NOx: 0.3 lb/MMBTU NOx: 0.21 lb/MMBTU 6/7/96

VOC: 91.9 lb/hr VOC: 4.62 lb/hr 6/7/96

Lead: 0.3 lb/hr 0.035 lb/hr 6/7/96 D3: Package Boiler CO: 16.2 lb/hr CO: 8.10 lb/hr 4/19/95

NOx: 21.7 lb/hr NOx: 13.11 lb/hr 4/19/95

VOC: 14.1 lb/MMBTU VOC: 4.77 lb/hr 4/19/95
E3: New Recovery

Furnace TRS: 40 ppm @ 8% O 2 TRS: 1.02 ppm @ 8% O 2 2007

E4: Smelt Dissolving

Tank TRS: 0.016 gram TRS per kg black liquor solids Emits through the Rec.

Furnace 2007

E7: Lime Kiln PM: 52.2 lb/hr PM: 3.2 lb/hr 11/4/91 TRS: 40 ppm @ 10% O 2 TRS: 31.3 ppm @ 10% O 2 7/24/89

F4: NCG Thermal
Oxidizer PM: 4.5 lb/hr PM: 4.40 lb/hr 11/2/00

CO: 0.2 lb/hr CO: 0.01 lb/hr 5/11/99

SO 2 : 41.5 lb/hr SO 2 : 0.02 lb/hr 5/11/99

NOx: 91.1 lb/hr NOx: 5.96 lb/hr 5/11/99

VOC: 0.6 lb/hr VOC: Not detectable 5/11/99 TRS: 5 ppm TRS: 0.9 ppm 4/6/02 TRS: 5 ppm @10% O 2 TRS: 0.70 ppm at 10% O 2 11/2/00

Compliance Plans

The mill is in compliance, none required.

Tier Classification and Public Review

This application has been determined to be a Tier II based on the request for a significant modification to a major source operating permit. The applicant published the “Notice of Filing a Tier II Application” and a notice of “Draft Permit” in The McCurtain Gazette , a daily newspaper printed the city of Idabel, McCurtain County, Okla homa. The notice stated that the application and permit are available for review by the public fo r 30-days at the Idabel Public Library at Two SE Ave “D”, Idabel, Oklahoma 74745. The facility is located within 50 miles of the borders of Oklahoma and the states of Texas and Arkansas; bot h states were notified of the draft permit. No comments were received from the public the st ate of Arkansas or the state of Texas. The proposed permit was also submitted to EPA for a 45-day review. No comments were received

from EPA.PERMIT MEMORANDUM 97-057-TV (M-10) - 48 -

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without thei r knowledge. The affida vit certifies that the applicant has notified the property owner.

Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page: http://www.deq.state.ok.us/

.

Fees Paid

Major source operating permit, significant modification fee of $1,000 and $500 for a minor modification to a Title V operating permit whic h has been included in this permit action.

SECTION XI. SUMMARY

The facility is constructed and operated as pr esented in the permit application and follow up submittals. Ambient air quality standards are not th reatened at this site. There is no active Air Quality compliance or enforcement issues concerni ng this facility. Issuance of the permit is

recommended.PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS

International Paper IP Valliant Paper Mill Permit No. 97-057-TV (M-10)

The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 2, 1997, and April 1, 2000, with supplemental information received April 21, 2000, October 13, 2000, January 23, 2001, Janu ary 24, 2001, May 22, 2001, March 21, 2003, January 18, 2006, March 6, 2006, December 1, 2006, March 30, 2007, June 25, 2007, July 7, 2008 August 25, 2008, and September 15, 2009. The Evaluation Memorandum dated March 24, 2010, explains the derivation of applicable permit re quirements and estimates of emissions; however, it does not contain limitations or perm it requirements. Continuing operations under this permit constitutes acceptance of, and cons ent to the conditions contained herein:

I. Equipment and Applicable Requirements

A. EUG FW – Facility-Wide

1. The permittee is authorized to operate th e sources under this permit continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)]

2. This permit supersedes Permit Numb ers 91-093-O, 95-224-O, 96-043-C(M-1), 96- 043-C(M-2)(PSD), 96-043-C(M-3)(PSD), 96-043-C(M-5)(PSD), 96-188-C, 97-057- C, 99-134-C, 97-057-C (M-4)(PSD), 97-057- C (M-8)(PSD) and Phase I of 97-057-C (M-9)(PSD). Permit retirements include: 75-011-O because the equipment was removed from the facility in 1985, 75-012- O and 86-019-O because conditions were superseded by 96-043-C(M-2)(PSD). Permit No. 96-043-C(PSD) became null and void on July 2, 1998. Any information relied upon in the issuance of PSD Construction permits for the sources listed in this permit remain effective for this operating permit. [OAC 252:100-8-6(a)]

3. Unless otherwise necessitated by an applicable requirement, the permittee is authorized to implement changes that quali fy as Insignificant Activities and as limited
under OAC 252:100-8-4 and OAC 252:100-8-7-2. Such changes shall not require a construction permit. [OAC 252:100-8-4(a)(1)]

4. Except for the Bark Boiler and Recovery Furnace, which are subject to the opacity limits specified in Specific Conditions I-N -2.a and I-Q-6b, all other sources of PM emissions shall comply with the opacity limitation specified in Standard Condition A(4) of Section XIX.

5. Compliance with the Clean Condensate Al ternative Compliance Plan Submitted on January 18, 2006, as approved by ODE Q on March 27, 2006, satisfies the requirements of 40 CFR 63.447.SPECIFIC CONDITIONS 97-057-TV (M-10) - 2 -

6. All monthly averages identified in these specific conditions are based on Valliant Mill

fiscal months.

7. The facility is subject to OAC 252: 100-31 and shall maintain appropriate documentation to show compliance.

8. Emission factors used to determine compliance shall be developed using best available data from the acceptable me thods described in OAC 252:100-5-2.1(d).

9. During certain start-up operations and upset conditions, the NCG stre ams are released to the atmosphere for a relatively short time for safety reasons. [OAC 252:100-9-1]

10. The plant wide fugitive emissions will comply with the following emission limits (Phase I) [OAC 252-100-8-6(a)(1)]

i. All excess NCG emissions will comply with these emission limits and be reported with a point even though the poi nt is not normally an emission point.

Emission Point Plant wide Fugitives Fugitive TRS Fugitive VOC

TPY C TPY C

Phase I 23.77 528.89

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

Table X provides specific Federal Regul atory emission limitations citations.

B. EUG A1 – No. 1 Digester System

1. Non-condensable gases (NCGs) from the No. 1 Digester System shall be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combustion. At times when

the combustion source becomes unstable or is not operating, air em issions from these
units shall be vented to one of the other combustion sources or otherwise treated to reduce TRS emissions to 5 ppm or less, dry-basis. [OAC 252:100-31-15(a)(2)]

2. The No. 1 Digester System shall co mply with the following regulations:

a. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.

C. EUG A2 – No. 2 Digester System

1. NCGs from the No. 2 Digester System shall be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combusti on. At times when the combustion source becomes unstable or is not operating, air emi ssions from these units shall be vented to

one of the other combustion sources or othe rwise treated to reduce TRS emissions to 5 ppm or less, dry-basis. [OAC 252:100-31-15(a)(2)]

2. The No. 2 Digester System shall co mply with the following regulations:

a. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.SPECIFIC CONDITIONS 97-057-TV (M-10) - 3 -

D. EUG A3 – No. 3 Digester System

1. NCGs from the No. 3 Digester System shall be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combusti on. At times when the combustion source becomes unstable or is not operating, air emi ssions from these units shall be vented to

one of the other combustion sources or othe rwise treated to reduce TRS emissions to 5 ppm or less, dry-basis. [OAC 252:100-31-15(a)(2)]

2. The No. 3 Digester System shall co mply with the following regulations:

a. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.

E. EUG A4, A5, & A7 – OCC Plants

1. The OCC Plants shall comply with the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission Point EU Name/Model VOC A

lb/hr B TPY C

E-A4, C No. 1 OCC Plant

25.06 99.6 A5 No. 2 OCC Plant

A7 No. 3 OCC Plant

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fis cal month basis, and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I-E-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

F. EUG A6 – Makedown Pulper

1. This emission unit is considered “grandfathered” and is limited to the existing equipment as it is.

Emission Point EU Name/Model Construction Date

A6 Makedown Pulper Pre-1972SPECIFIC CONDITIONS 97-057-TV (M-10) - 4 -

G. EUG A8 – OCC Lightweight Rejects Handling System

1. The OCC Lightweight Rejects Handling System is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model PM 10 lb/hr B TPY C

A8 OCC Lightweight Rejects Baghouse 0.46 1.9

B Valliant Mill fis cal month basis, and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I-G-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

3. Air exhausts from the Bark Boiler Surg e Bin shall be processed by a baghouse or equivalent PM 10 emissions control device which achieves discharge concentrations of 0.00437 gr/dscf or less PM 10 emissions

. Pressure differential shall be recorded once daily. [OAC 252:100-25]

H. EUG B1 – No. 1 Brownstock Washing Area

1. The No. 1 Brownstock Washing System is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C

B1,B B1,C Brownstock Washer 1A 26.57 108.60 0.83 3.37 Brownstock Washer 1B

A

VOC emissions limitati ons expressed as 80% a- pinene/20% methanol.

B Valliant Mill fis cal month basis, and hours of operation.

C 12-month rolling total based on Va lliant Mill fiscal calendar month.

2. Compliance with Specific Condition I-H-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

3. The No. 1 Brownstock Washing Area shall comply with the following regulations:

a. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.SPECIFIC CONDITIONS 97-057-TV (M-10) - 5 -

I. EUG B2 – No. 2 Brownstock Washing Area

1. The No. 2 Brownstock Washing System is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C

B2,A B2,B 1 s t Stage Brownstock Washer 19.19 77.58 1.08 4.38 2 n d Stage Brownstock Washer

A

VOC emissions limitati ons expressed as 80% a- pinene/20% methanol.

B Valliant Mill fis cal month basis, and hours of operation.

C 12-month rolling total based on Va lliant Mill fiscal calendar month.

2. Compliance with Specific Condition I-I-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

3. The No. 2 Brownstock Washing area shal l comply with the following regulations:

a. Federal New Source Performance St andard, 40 CFR 60, Subpart BB; and

b. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.

J. EUG B3 – No. 3 Brownstock Washing Area

1. The No. 3 Brownstock Washing System is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C

B3,A B3, B B3, C B3, D Brownstock Washer – A Line

14.76 58.18 0.46 1.81 Brownstock Washer – A Line

Brownstock Washer – B Line

Brownstock Washer – B Line

A

VOC emissions limitati ons expressed as 80% a- pinene/20% methanol.

B Valliant Mill fis cal month basis, and hours of operation.

C 12-month rolling total based on Va lliant Mill fiscal calendar month.

.

2. Compliance with Specific Condition I.-J.-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

K. EUG C1 – No. 1 Paper Machine (Stock Prep) EUG C2 – No. 1 Paper Machine (Wet End) EUG C3 – No. 1 Paper Machine (Dry End)SPECIFIC CONDITIONS 97-057-TV (M-10) - 6 -

1. The permittee has requested the follow ing emission limits be established.

[OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model PM/PM 10 VOC A

lb/hr B TPY C lb/hr B TPY C

E-C1 E-C2,A E-C2,B E-C2,D E-C3,A Stock Preparation

Fourdrinier
3.6 13.14 310.64 1,133.81 Vacuum Pumps/ Vacuum Flume

Press Section Dryer Section

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fis cal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-K.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

L. EUG C4 – No. 2 Paper Machine (Stock Prep) EUG C5 – No. 2 Paper Machine (Wet End) EUG C6 – No. 2 Paper Machine (Dry End)

1. The No. 2 Paper Machine shall comply with the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission Point EU Name/Model PM/PM 10 VOC A

lb/hr B TPY C lb/hr B TPY C
C4 / E-C5,A Stock Preparation / Fourdrinier

1.70 6.35 146.69 548.02 E-C5,B Press Section E-C5,D Vacuum Pumps/ Vacuum Flume E-C6,A Dryer Section

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fis cal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-L.-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

M. EUG C7 – No. 3 Paper Machine (Stock Prep) EUG C8 – No. 3 Paper Machine (Wet End) EUG C9 – No. 3 Paper Machine (Dry End)SPECIFIC CONDITIONS 97-057-TV (M-10) - 7 -

1. The No. 3 Paper Machine shall comply with the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission Point EU Name/Model PM/PM 10 VOC A

lb/hr B TPY C lb/hr B TPY C
C7 E-C8,A Stock Prep aration Fourdrinier

1.95 6.57 168.26 566.92

E-C8,B Press Section E-C8,D Vacuum Pumps/ Vacuum Flume E-C9,A Dryer Section

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fis cal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-M.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

N. EUG D1 – Bark Boiler

1. The Bark Boiler is subject to the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

D1 Bark Boiler 90.00 306.6 6,626.70 11,399.39 720.00 254.48 270.00 840.08

Emission

Point EU Name/

Model VOC A Lead H 2 SO 4 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

D1 Bark Boiler 51.17 174.31 0.08 0.29 22.35 76.13

A

VOC emissions limitation s expressed as propane.

B Valliant Mill fiscal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

a. The permittee shall demonstrate compliance wi th the emission limi ts listed above as
follows.

i. Compliance with Specific Condition I.-N.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors for PM 10 , CO, VOC, and Lead.

ii. The permittee shall utilize Continuous Em issions Monitoring System (CEMS)

data records to demonstrat e compliance with th e emission limits listed above for

SO 2 and NO

x .

b. The permittee shall not fire gr eater than 3.8 TPH, dry basi s, of OCC rejects, based on a fiscal monthly average.

c. The permittee shall not fire greater than 6.0 TPH fiscal monthly average, dry basis, of wastewater treatment plant sludge.

2. The Bark Boiler is subject to federal NSPS, 40 CFR 60, Subpart D, and shall comply with all applicable requir ements. [40 CFR Part 60.40]SPECIFIC CONDITIONS 97-057-TV (M-10) - 8 -

a. The permittee shall not emit in excess of 0.10 lb PM 10 /MMBtu heat input from the Bark Boiler or exhibit greater than 20% opacity except for one six-minute period per hour of not more than 27% opacity. [40 CFR 60.42 and OAC 252:100-8 Part 7]

i. All stack exhausts from the Bark Boiler shall be processed by a wet scrubber or equivalent air pollution c ontrol device. [OAC 252:100-8 Part 7]

ii. A minimum pressure differential of at least 0.5 inches water column (3-hour block average) maintained across the wet scrubber demonstrates compliance
with the 0.10 lb PM 10 /MMBtu limit. Operation of the wet scrubber on exhaust shall not be required when natural ga s is the only fuel being burned. [OAC 252:100-8 Part 7]

iii. Continuous monitoring of opacity from th e Bark Boiler shall not be required. [40 CFR 60.13(i) and OAC 252:100-8 Part 7]

b. The permittee shall not em it in excess of 0.80 lb SO 2 /MMBtu heat input from the

Bark Boiler. [40 CFR 60. 43 and OAC 252:100-8 Part 7]

c. The permittee shall not em it in excess of 0.30 lb NO

x (expressed as NO 2 )/MMBtu heat input from the Bark Boiler. [40 CFR 60.44 and OAC 252:100-8 Part 7]

d. Determinations of heat input (for determination of co mpliance with standards on a lb/MMBtu basis) may be determined by ASME Method PTC-4.1 or an equivalent method approved by DEQ. [Permit No. 96-043-C (M-2)(PSD)]

e. The permittee shall operate and maintain continuous monitoring systems for the
Bark Boiler for SO 2 and NOx emissions using the applicable methods and procedures set forth and shall record the output of the systems. [40 CFR 60.45(a)]

3. During firing of wastewater treatment plant sludge, the Bark Boiler is subject to federal NESHAP, 40 CFR 61, Subpart E, a nd shall comply with all applicable requirements. [40 CFR 61 Subpart E]

a. Mercury emissions shall not exceed 3.2 kg of mercury per 24-hour period. If emissions exceed 1.6 kg mercury per 24-hour period, the permittee shall conduct testing of the sludge in accordance w ith 40 CFR 61.55 at leas t once per year.

4. The Bark Boiler may be used as a back-up control device for the control of emissions as specified in federal NESHAP for Sour ce Categories, 40 CFR 63, Subpart S. When used in this capacity, the Bark Boiler shal l comply with all applicable requirements, including but not limited to the requireme nts of Subpart BB. [40 CFR 63, Subpart S]

5. Fuels include but are not limited to wood resi dues, OCC rejects, wastewater treatment sludge, fuel oil, coal and natural gas. Oil from mill equipment (including smallSPECIFIC CONDITIONS 97-057-TV (M-10) - 9 -

portions of used antifreeze and miscellaneous non-hazardous used parts washer fluids) may also be added to the Bark Boiler fuel mixture. [40 CFR 61 Subpart E]

6. The Bark Boiler excess emissions of NOx or SO2 that are startup, shutdown, malfunction or maintenance issues are covered by the permitted limits in 1.N.1. [Permit No. 97-057-C (M-9)(PSD)]

7. This specific condition includes additional requirements/limits for the Bark Boiler. Valliant shall be in compliance with the list ed emission limits and conditions within 5 years of EPA approval of the Regional Haze State Implementation Plan. Valiant shall submit any permit modification request as determ ined to be applicable as a result of proposed changes.

PHASE 3A PERMIT LIMITS (24-HOUR AVERAGE)

Point

ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr Dl Bark Boiler (Removed) N.A. N.A. N.A.

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) - FUEL OIL OPERATION BARK BOILER

Point

ID Source Name SO 2 NO X PM\PM IO
lbs/hr lbs/hr lbs/hr

Dl Bark Boiler 135.00 270.00 39.38

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) – NON FUEL OIL OPERATION BARK BOILER

Point

ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

DI Bark Boiler 135.00 270.00 90.00

a. The listed limits apply while the units are com busting any fuel type as described in I.-N.-5.
Sulfur content of fuel oil combusted in the Bark Boiler shall be limited to 15,000 ppm. b. International Paper shall s ubmit any permit modification reque st as determined to be applicable as a result of proposed changes. c. For determining compliance with the emissi on average, a “boiler op erating day” is as defined in 40 CFR Part 60, Subpart Da.SPECIFIC CONDITIONS 97-057-TV (M-10) - 10

-

O. EUG D2 –Power Boiler

1. The Power Boiler shall comply with the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission
Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B TPY lb/hr B TPY lb/hr B TPY lb/hr B TPY

Main

Stack Power Boiler 171.00 92.99 1,486.80 1,022.40

Emission
Point EU Name/

Model VOC A Lead H 2 SO 4 lb/hr B TPY lb/hr B TPY lb/hr B TPY

Main

Stack Power Boiler 7.49 0.02 22.35

A

VOC emissions limitation s expressed as propane.

B Valliant Mill fis cal month basis, and hours of operation.

2. Compliance with Specific Condition I.-O.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

3. The average SO 2 emission rate shall be calculated from the recorded sulfur weight percent and density of ea ch fuel. [OAC 252-100-43]

4. Stack testing: NOx was stack tested on 2/16/05. Stack testing for PM shall be performed once during the life of the permit.

5. The power boiler could have excess opacity emissions occurring tw ice a month (for a period of up to 30 minutes each) during soot blowing activities, allowing the boiler to operate more efficiently. All excess em issions shall be reported. [OAC 252-100-43]

6. Effective with the date of five years after EPA approval of DEQ’s BART SIP, the emission limits from BART will apply.

7. This specific condition includes additional requirements/limits for the Power Boiler. Valliant shall be in compliance with the lis ted emission limits and conditions within 5 years of EPA approval of the Regional Haze State Implementation Plan. Valiant shall submit any permit modification request as determined to be applicable as a result of proposed changes.

PHASE 3A PERMIT LIMITS (24-HOUR AVERAGE)

Point

ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

D2 Power Boiler 933.91 255.60 121.38

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) - FUEL OIL OPERATIONOF BARK BOILER

Point

ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

D2 Power Boiler 168.10 255.60 39.38SPECIFIC CONDITIONS 97-057-TV (M-10) - 11

-

PHASE 3B PERMIT LIMITS (24-HOUR AVERAGE) – NON-FUEL OIL OPERAT IONOF BARK BOILER

Point

ID Source Name SO 2 NO X PM\PM IO lbs/hr lbs/hr lbs/hr

D2 Power Boiler 252.15 255.60 42.66

a. The listed unit is permitted to combust fuel oil. Sulfur content of fuel oil combusted in the Power Boiler shall be limited to 10,000 ppm. b. International Paper shall s ubmit any permit modification reque st as determined to be applicable as a result of proposed changes. c. For determining compliance with the emissi on average, a “boiler op erating day” is as defined in 40 CFR Part 60, Subpart Da.

EUG D3 –Package Boiler

4. The Package Boiler is subject to the following emission limits. [OAC 252:100-8 Part 7]

Emission

Point EU Name/

Model PM 10 CO SO 2 NOx VOC A

lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

D3 Package

Boiler 1.89 6.50 16.23 55.86 0.13 0.43 21.67 74.58 17.2 59.1

A

VOC emissions limitation s expressed as propane.

B Valliant Mill fiscal month basis, and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

5. Compliance with Specific Condition I.-P.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

6. The Package Boiler shall be fired with pipelin e grade natural gas or other gaseous fuel
with sulfur content less th an 343 ppmv. Compliance can be shown by the following methods: for pipeline grade na tural gas, a curren t gas company bill; for other gaseous fuel, a current lab analysis, stain-tube an alysis, gas contract, tariff sheet, etc. Compliance shall be demonstrated at least once annually. [OAC 252-100-43]SPECIFIC CONDITIONS 97-057-TV (M-10) - 12

-

P. EUG D6 – Recovery Furnace (New)

1. The Recovery Furnace is subject to the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B TPY lb/hr B TPY lb/hr B TPY lb/hr B TPY

D6 Recovery

Furnace 49.07 482.56 1,155.39 657.39

Emission

Point EU Name/

Model VOC A TRS Lead H 2 SO 4 lb/hr B TPY lb/hr B TPY C lb/hr B TPY lb/hr B TPY

D6 Recovery

Furnace 41.25 6.22 20.25 .003 3.06

A

VOC emissions limitation s expressed as propane.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. The Recovery Furnace shall comply with the following BACT requirements:

Pollutant Emission Limit Control Technology

H2SO4 0.5 ppm @ 8% O2 GCP/High Solids Firing VOC (as propane) 40 ppm @ 8% O2 Staged Combustion /

NDCE

3. Compliance with Specific Conditions I.-Q.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific em ission factors except TRS and SO2 limits shall be demonstrated utilizing CMS as required in I-U-7. [Permit No. 97-057-C (M-9)(PSD)]

4. Compliance with Specific Conditions I.-Q.- 2 shall be demonstrated by the initial performance test. [Permit No. 97-057-C (M-9)(PSD)]

5. Natural gas and ultra low sulfur distillate fuel oil firing fr om the new recovery furnace shall be limited to a maximum annual capacity factor of ten percent (10%) of the unit’s heat input capacity utilizing the Annual Capacity Factor of NSPS Subpart Db until the permittee elects to lift the limit and co mply with all requirements of Db. [40CFR§60.41b, 40 CFR §60.46b(d)]

6. Gases from the Smelt Dissolving Tanks shall be routed to the New Recovery Furnace as combustion air or vented through the emergency bypass. All excess emissions associated with the emergency bypass are covered by the emission limits for the New Recovery Furnace. [Permit No. 97-057-C (M-9)(PSD)]

7. The Recovery Furnace shall comply with the following regulations:

a. OAC 252:100, Subchapters 19,31, and 33;

b. Federal NSPS, 40 CFR 60, Subpart BB

c. Federal NESHAP for Source, 40 CFR 63, Subpart MMSPECIFIC CONDITIONS 97-057-TV (M-10) - 13

-
EUG D2& D6 Summary

1. The Power Boiler and Recovery Furnace sha ll comply with the following combined Sum 12 month rolling total ton per year emission limits. [OAC 252:100-8-6(a)(1)]

EU Name / Emission

Pt. Phase I TPY

PM/
PM10 CO SO2 NOx VOC A Lead H 2 SO 4

Power Boiler / Main
Stack 508.47 263.34 6,512.20 3,040.14 21.22 0.07 66.45

New Recovery / Recovery Furn Stack 159.80 270.52 627.17 915.85 115.69 .009 9.97

Sum TPY B : 668.3 533.9 7,139.4 3,956.0 136.9 0.079 76.4

A VOC emissions limitations expressed as propane

B January 2008 starts the beginning of the 12 month rolling aver age with the first annual total in December of 2008. The 12 month rolling average shall be calculated based upon Valliant Mill’s fiscal calendar.

Q. EUG E1 – Turpentine Recovery System

1. NCG’s from the Turpentine System shall be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combusti on. At times when the combustion source becomes unstable or is not operating, air emi ssions from these units shall be vented to

one of the other combustion sources or othe rwise treated to reduce TRS emissions to 5 ppm or less, dry-basis. [OAC 252:100-31-15(a)(2)]

2. The Turpentine Recovery System shall comply with the following regulations:

a. Federal NSPS, 40 CFR 60, Subpart BB; and

b. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.

R. EUG E2a – Spent Liquor Concentration

1. NCG’s from the Spent Liquor Concentration sh all be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combustion. At times when the combustion source becomes unstable or is not operating, air emissions from these units shall be
vented to one of the other combustion s ources or otherwise tr eated to reduce TRS emissions to 5 ppm or less, dry-basi s. [OAC 252:100-31-15(a)(2)]

2. The Spent Liquor Concentration is a multiple effect evaporator system and shall comply with the following regulations: [OAC 252:100-8-6(a)(1)]

a. Federal NSPS, 40 CFR 60, Subpart BB; and

b. Federal NESHAP for Source Ca tegories, 40 CFR 63, Subpart SSPECIFIC CONDITIONS 97-057-TV (M-10) - 14

-

S. EUG E2b – Evaporator Sump

1. The Evaporator Sump is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C
E2b Evaporator Sump 52.63 213.01 16.07 65.05

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

X. Compliance with Specific Condition I.-T.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

O. EUG E3d – Spent Liquor Mix Tanks

1. The Spent Liquor Mix Tanks includes the followi ng units [OAC 252:100-8-6(a)(1)]

The Spent Liquor Mix Tanks vent th rough the New Recovery Furnace.

P. EUG E4b – Smelt Dissolving Tank (New)

1. The Smelt Dissolving Tank includes the fo llowing units. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model Construction Date E3c New Recovery Furnace Stack Smelt Dissolving Tank 2006

2. Gases from the Smelt Dissolving Tanks shall be routed to the Recovery Furnace as combustion air or vented through the emergency bypass. All excess emissions associated with the emergency bypass are covered by the emission limits for the New Recovery Furnace.

3. The Smelt Dissolving Tank shall comply with the following regulations:

a. OAC 252:100, Subchapter 31; and

b. Federal NSPS, 40 CFR 60, Subpart BB; and

c. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart MM.SPECIFIC CONDITIONS 97-057-TV (M-10) - 15

-

Q. EUG E5 – Lime Slakers

1. The following emission limits apply to th e lime shakers. [OAC 252:100-8-6(a)(1)]

Emission

Point EU Name/Model PM / PM 10 TRS VOC A

lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

E-E5,A Lime Slaker Vent #1 0.12 0.39 0.17 0.55 66.74 219.27 E-E5,B Lime Slaker Vent #2

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condi tions I.-W.-1 shall be demonstrated monthly based on Valliant Mill fiscal calendar month opera ting rate records and emission factors. [OAC 252-100-43]

R. EUG E6 – Causticizing System

1. The following emission limits apply to the causticizing system. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C

E6 (2 stacks) No. 1a Causticizer

61.88 203.29 0.17 0.55 No. 2 Causticizer

No. 1b Causticizer

No. 3 Causticizer

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fis cal month basis and hours of operation..

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-X.-1 sh all be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43].SPECIFIC CONDITIONS 97-057-TV (M-10) - 16

-

S. UG E7a – Lime Kiln

1. The Lime Kiln shall comply w ith the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

E7a No. 1 Lime

Kiln 1.93 5.37 36.30 101.07 14.64 40.72 50.40 140.18

Emission

Point EU Name/

Model VOC A TRS Lead H 2 SO 4 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

E7a No. 1 Lime

Kiln 12.00 33.39 2.40 6.68 0.11 0.32 0.50 1.39

A

VOC emissions limitation s expressed as propane.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Conditions I.-Y.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

3. The Lime Kiln shall comply with the following regulations:

a. OAC 252:100, Subchapter 31; and

b. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart MM.

c. Federal NSPS, 40 CFR 60, Subpart BBand

d. Federal NESHAP for Source Ca tegories, 40 CFR 60, Subpart S

4. Compliance with OAC 252:100, S ubchapter 31 to be demonstrated by stack testing once during the life of the permit for TRS.

5. Federal NSPS, 40 CFR 60, Subpart BB is app licable to the Lime Kiln as a lime producing unit, but the Lime Kiln has not triggered those requirements. The only requirements of Subpart BB currently applicable to the Lime Kiln apply when used as a back-up control device for the destruc tion of non-condensable gases (NCGs) and stripper off-gases (SOGs). [40 CFR 60, Subpart BB]

6. When used as a back-up control device for the control of emissions as specified in federal NESHAP for Source Categories, 40 CFR 63, Subpart S, the Lime Kiln shall comply with all applic able requirements. [ 40 CFR 63, Subpart S]

7. The SO 2 , TRS, and NO

x emission limitations in Speci fic Condition I.-Y.-1. for the Lime Kiln do not apply when the Lime Kiln is used as a backup control device for the destruction of non-condensable gases (N CGs) and stripper off-gases (SOGs).

8. The Lime Kiln shall be fired with natural gas and/or petroleum coke.SPECIFIC CONDITIONS 97-057-TV (M-10) - 17

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T. EUG E8 – Tall Oil Plant

1. The following emission limits apply to the ta ll oil plant. [O AC 252:100-8-6(a)(1)]

Emission Point EU Name/Model VOC A TRS

lb/hr B TPY C lb/hr B TPY C

Main Stack Tall Oil Plant 84.56 370.39 0.36 1.56

A

VOC emissions limitation s expressed as methanol

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Conditions I.-Z.-1 shall be demonstrated monthly based on operating rates and Valliant Mill specific emission factors. [OAC 252-100-43]

U. EUG F1 – Woodyard

1 The Woodyard shall comply with the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission

Point EU Name/Model PM PM 10 VOC A

lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C
F1 Woodyard 5.44 4.70 2.70 2.28 0.33 1.44

A

VOC emissions limitations expressed as alpha-pinene.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2 Compliance with Specific Conditions I.-AA. -1 shall be demonstrated monthly based on Valliant Mill fiscal calendar month opera ting rate records and emission factors submitted with the application for this permit.

V. EUG F3a – Wastewater Treatment System and F3b – Wastewater Pipeline

1. The Wastewater Treatment System shall co mply with the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission

Point EU Name/Model VOC A TRS (as H 2 S) H 2 S

lb/hr B TPY C lb/hr B TPY C lb/hr D TPY C
F3a Wastewater Treatment System 312.57 1264.98 27.30 126.80

F3b Wastewater Pipeline 1.98 8.67

A

VOC emissions limitation s expressed as methanol.

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Va lliant Mill fiscal calendar month

2. Compliance with Specific Condition I.-BB.-1 for F3a shall be demonstrated monthly

based on Valliant Mill fiscal calendar m onth operating rate records and emission factors. [OAC 252-100-43]SPECIFIC CONDITIONS 97-057-TV (M-10) - 18

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3. At least three times per week, the dissolved oxygen content shall be measured at the discharge end of the pipe line and recorded [OAC 252:100-8-6]

4. The wastewater shall have oxygen injected as needed such that the dissolved oxygen content does not remain below 0.5 mg/l for more than two consecutiv e readings at the discharge end of the pipeline. [OAC 252:100-8-6]

5. Throughput of wastewater shall not exceed 27.10 million gallons per day (12-month rolling average) or 80 million gallons per day (weekly average). [OAC 252:100-8-6]

6. Compliance with Specific Condition I – BB.-1 for F3b shall use the 12-month rolling average flow and emission factor shall be used to calculate a monthly average lb/hr and 12-month rolling total emission rate for comparison with the lb/hr and TPY

emission limits. [OAC 252:100-8-6]

W. EUG F4a – NCG Collection and Therm al Oxidation System – LVHC
EUG F4b – NCG Collection and Th ermal Oxidation System – HVLC

1. NCG’s from the NCG LVHC and HVLC Coll ection System shall be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combustion.

2. The NCG Thermal Oxidizer shall be used as a back-up unit for the control and combustion of NCGs and SOGs for periods when the Recovery Furnace and/or Lime Kiln are in process upsets or not in operation. During these periods of backup operation of the NCG Thermal Oxidizer, the sum of the annua l emissions from
the NCG Thermal Oxidizer and Recove ry Furnace shall not exceed the annual emission limits specified in Specific Conditions I.Q.1. The Thermal Oxidizer lb/hr emissions shall not exceed previ ously permitted (No. 99-134-C) emission limits specified for the Thermal Oxidizer which are listed in the table below.

3. The NCG Collection and Thermal Oxidati on System are subject to the following

emission limits. [OAC 252:100-8-6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B lb/hr B lb/hr B lb/hr B

F4 Thermal

Oxidizer 7.6 0.4 41.5 91.1

Emission

Point EU Name/

Model VOC A TRS

lb/hr B lb/hr B

F4 Thermal
Oxidizer 0.7 0.5

A VOC emissions limitation s expressed as propane.

B Valliant Mill fi scal month basis and hours of operation.

4. The permittee shall demonstrat e compliance with the emissi on limits listed in I.- CC.-3 as follows: [OAC 252-100-43]SPECIFIC CONDITIONS 97-057-TV (M-10) - 19

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a. Limits shall be demonstrated monthly based on Valliant Mill fiscal calendar month operating rate record s and emission factors.

b. The permittee, at its option, may determine compliance with the SO 2 emission rates by installing and operati ng a CEMS, which has been certified and quality-assured using the methods and procedures of federal NSPS, 40 CFR 60, Appendices B and F. If the permittee chooses to install an SO 2 CEMS for the NCG Thermal Oxidizer, CE MS data records sh all be used to demonstrate compliance with the emission limits listed above for SO 2

.

5. Emissions from the NCG Thermal Oxidizer shall be processed by a caustic wet scrubber or equivalent sy stem (90% control of SO 2 emissions). The system shall maintain a minimum liquor pH of 8.0 and a minimum scrubber recirculation flow of 300 gpm, daily average. Th e permittee shall demonstrate compliance with this condition by recording the liquor pH and scrubber recirculation flow averaged daily. [OAC 252-100-43]

6. TRS emissions from the NCG Thermal Oxidizer shall not exceed 5 ppm dry basis. [OAC 252:100-31-15(a)(2)]

7. The NCG Thermal Oxidizer shall be used as the one of the backup control device for the control of emissions as specif ied in federal NSPS, 40 CFR 60, Subpart BB, and federal NESHAP for Source Categories, 40 CFR 63, Subpart S. [OAC 252:100-8-6(a)(1)]

8. When used as the control device for th e control of emissions as specified in federal NSPS, 40 CFR 60, Subpart BB, the NCG Thermal Oxidizer shall combust the gases at a minimum temper ature of 650 degrees C (1200 degrees F)
for at least 0.5 second. [40 CFR 60.283(a)(1)(iii)]

a. A continuous monitoring system to measure and record the combustion temperature of the effluent gases has been installed as specified in 40 CFR 60.284(b)(i).

b. Engineering equations shall be used to calculate residence time. These
calculations shall be made availabl e to regulatory personnel upon request.

9. When used as the control device for th e control of emissions as specified in federal NESHAP for Source Categorie s, 40 CFR 63, Subpart S, the NCG Thermal Oxidizer shall comply with all applicable requirements. [40 CFR 63, Subpart S]SPECIFIC CONDITIONS 97-057-TV (M-10) - 20

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X. EUG F5 – Solid Waste Disposal Facility Operations

1. Solid Waste Disposal Facility Operations shall comply with the following

emission limits. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model PM PM 10 lb/hr A TPY B lb/hr A TPY B
F5 SWDF Operations 15.84 4.11 7.58 1.95

A Valliant Mill fiscal mont h basis and hours of operation.

B 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-DD.-1 shall be demonstrated monthly based on Valliant Mill fiscal calendar month opera ting rate records and emission factors submitted with the application for this permit.

Y. EUG F6 – Diesel Stormwater Pump

2. The Diesel Stormwater Pump is subject to the following emission limits. [OAC 252:100-8-6(a)(1)]

Emission

Point EU Name/

Model PM 10 CO SO 2 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

F6 166 HP Diesel engine 0.4 1.5 1.4 5.9 0.1 0.3

Emission

Point EU Name/

Model NOx VOC (NMHC)
lb/hr B TPY C lb/hr B TPY C

F6 166 HP Diesel engine 3.9 17.1 0.1 0.6

B Valliant Mill fi scal month basis and hours of operation.

C 12-month rolling total based on Vall iant Mill fiscal calendar month.

2. Compliance with specific cond ition I.-EE.-1 shall be demo nstrated monthly based on

Valliant Mill fiscal calenda r month operating rate record s and emission factors. [OAC 252-100-43]

3. The engine of the Diesel Stormwater Pump shall only be fueled with diesel, LPG, or natural gas. Liquid fuels shall not exceed 0.05% by weight su lfur demonstrated annually (vendor analysis, Material Safety Data Sheets, etc). [OAC 252:100-8-6(a)(1)]SPECIFIC CONDITIONS 97-057-TV (M-10) - 21

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Z. EUG F7 & F9 – Chip Thickness Screening and Conditioning Systems

1. The Chip Thickness Screening and Conditioning Systems shall comply with the following emission limits. [OAC 252-100-8-6(a)(1)]

Emission

Point EU Name/Model VOC A PM PM 10 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

F7/F9 Bar Screen

4.73 19.11 2.10 8.60 1.26 5.16 Chip Conditioner
Air Density Separator #1
Air Density Separator #2
Air Density Separator #3

A

VOC emissions limitations expressed as alpha-pinene.

B Valliant Mill fis cal month basis and hours of operation.

C 12-month rolling total based on Va lliant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-FF.-1 shall be demonstrated monthly based on Valliant Mill fiscal calendar month opera ting rate records and emission factors. [OAC 252-100-43]

AA. EUG F10 - Steam Stripper System

1. SOG’s from the Steam Stripper System sha ll be routed to the Recovery Furnace, Lime Kiln, or Thermal Oxidizer for combustion.

2. The Steam Stripper System shall co mply with the following regulations:

a. Federal NSPS, 40 CFR 60, Subpart BB; and

b. Federal NESHAP for Source Cate gories, 40 CFR 63, Subpart S.

II. Insignificant Activities

BB. EUG E9 – Organic Liquid Storage Vessels

1. The Organic Liquid Storage Vesse ls include the following units. [OAC 252:100-8-6(a)(1)]

Emission Point

Tank No. EU Name/Model Capacity, gallons Construction

Date

164100010 No. 1 Weak Black Liquor Tank 793,090 1995

164100110 No. 2 Weak Black Liquor Tank 793,090 1995

164100210 Boilout Tank 426,263 1991

164101310 51% Black Liquor Tank 793,090 1994

164101710 No. 2 Fuel Oil Storage Tank 1,523,381 1990

164101810 “NSSC” Weak Liquor Tank 842,428 1990 164102511 68% Black Liquor Storage Tank 603,400 1995

E-E2,L “Super Bowl” Temporary Storage Area 10,000,000 1990 164110110 Foul Condensate Storage (Steam Stripper Feed) Tank 350,000 2000

174102010 No. 2 Green Liquor Storage Tank >20,000 1997SPECIFIC CONDITIONS 97-057-TV (M-10) - 22

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CC. EUG E10 – Small Volatile Or ganic Liquid Storage Tanks

1. The following emission units are considered insignificant because emissions are less than 5 TPY. The permittee shall keep records to verify insignificance. [OAC 252:100-8-6(a)(1)]

Emission Point EU Name/Model Capacity,
Gallons Construction

Date

GAS-01 Gasoline Fuel Tank 1,950 1987 034120511 Turpentine Storage Tank 28,000 1971

ULS Fuel Oil-01 Ultra Low Sulfur Distillate Fuel Oil 10,000 gals 2008

2. The gasoline fuel tank shall be equipped w ith a permanent submerged fill pipe or equipped with an organic material va por-recovery system. [OAC 252:100-37-5(a)]

DD. EUG F11- Miscellaneous In significant Activities

1. Miscellaneous insignificant activities that requ ire records to document this status shall

be recorded.

2. Units F11-3 and F11-4 are limited to 500 hour s of operation per year and shall be
fitted with non-resettable run hour meters. [OAC 252-100-8-6(a)(1)]

3. The number of empty barrels disposed in the on-site Solid Waste Disposal Facility
will be recorded.

III. Record Keeping Requirements

EE. The permittee shall maintain records of operations (based on Valliant Mill fiscal calendar) as listed below. These records shall be maintained on-site for at least five years after the date of r ecording and shall be provide d to regulatory personnel upon request. [OAC 252:100-8-6 (a)(3)(B)]

1. The OCC Plants, operating rate as a monthly basis (Condition I.-E.-2).

2. The OCC Lightweight Rejects Handling Syst em, operating rate as a monthly basis (Condition I.-G.-2).

3. The No. 1 Brownstock Washing Area, operatin g rate as a monthly basis (Condition I.- H.-2). Emission Point EU Name/Model Construction Date

F11-1 100 KW Caterpillar D100PI Emergency

Generator 1971

F11-2 150 KW Caterpillar D336 Emergency Generator 1990 F11-3 700 KW Pipeline Basin Emergency Generator 2003

F11-4 25 KW Pipeline Valve HouseSPECIFIC CONDITIONS 97-057-TV (M-10) - 23

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4. The No. 2 Brownstock Washing Area, operatin g rate as a monthly basis (Condition I.- I.-2).

5. The No. 3 Brownstock Washing Area, operatin g rate as a monthly basis (Condition I.- J.-2).

6. The No. 1 Paper Machine operating rate as a monthly basis (Condition I.-K.-2).

7. The No. 2 Paper Machine operating rate as a monthly basis (Condition I.-L.-2).

8. The No. 3 Paper Machine operating rate as a monthly basis (Condition I.-M.-2).

9. Monthly quantities of all fuel s fired in the Bark Boiler. The reco rded amount of OCC rejects fired shall be on a dry basi s (Condition I.-N.-1ai. & I.-N.-1b).

10. CEMS readings of SO 2 and NO

x emissions from the Bark Boiler (Condition I.-N.- 1aii).

11. Weekly measurements of dry-basis sludge weight (Condition I.-N.-1c).

12. Daily Bark Boiler wet scrubber pressu re differential (Condition I.-N.-2aii).

13. The Power Boiler, operating rate as a monthly basis (Condition I.-O.-2).

14. Amount of liquid fuels fired in the Powe r Boiler (daily when done and cumulative annual total) (Condition I.-O.-1).

15. Monthly average sulfur wei ght percent of each liquid fuel fired in the Power Boiler(Condition I.-O.-3).

16. The Package Boiler, operating rate as a monthly basis (Condition I.-P.-2) and (Condition I.-P.-5).

17. Monthly amount of natural gas fired in th e Package Boiler. (Condition I.-P.-2) and (Condition I.-P.-4). Annual sulfur conten t of natural gas (Condition I.-P.-3).

18. The Lime Slakers, operating rate as a monthly basis (Condition I.-W.-2).

19. The Causticizing System, operating rate as a monthly basis (Condition I.-X.-2).

20. The Lime Kiln, operating rate as a monthly basis (Condition I.-Y.-2).

21. Lime Kiln COMS data (continuous when operat ing) (Condition I.-Y).

22. Lime Kiln combustion temperature conti nuously when used as a back-up control device (Condition I.-Y).

23. The Tall Oil, operating rate as a monthly basis (Condition I.-Z.-2).

24. The Wastewater Treatment System and Wastewater Pipeline, operating rate in million gallons per day, as a monthly basis (Condi tion I.-BB.-2 and Condition I.-BB-6) and weekly average ( Condition I.-BB-5).

25. The pipeline discharge dissolved oxygen co ntent recorded (three times per week when operated). (Condition I.-BB-3).

26. The NCG Thermal Oxidizer, operating rate as a monthly basis (Condition I.-CC.-2).

27. CEMS readings of SO 2 emissions from the NCG Therma l Oxidizer (continuous if the permittee chooses to install an SO 2 CEMS).

28. Daily average NCG Thermal Oxidizer wet sc rubber liquor pH and recirculation flow.

29. NCG Thermal Oxidizer operating temper ature (continuous when operated).

30. Monthly amount of diesel fuel fired in the Diesel Stormwater Pump (Condition I.- EE.-2). Annual sulfur content of fuel (Condition I.-EE.-3).

31. The Chip Thickness Screening and Conditi oning, operating rate as a monthly basis (Condition I.-FF.-2).

32. Monthly and cumulative annua l process throughput of th e Wood Chip Screening and Conditioning Unit – No. 3 Line.SPECIFIC CONDITIONS 97-057-TV (M-10) - 24

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33. Monthly and cumulative annua l process throughput of th e Wood Chip Screening and Conditioning Unit – No. 1 Line.

34. Sufficient records shall be maintained to demonstrate emissi ons that qualify as insignificant activities.

35. Hours of operation of each stationary e ngine (monthly and 12-m onth rolling totals based on Valliant Mill fiscal month) (Condition I.-JJ.-2).

36. Sulfur content of liquid fuels used in st ationary diesel engines F11-3 and F11-4.

37. Empty barrels disposed in the on-site Solid Waste Disposal Facility tracked on a Valliant Mill fiscal monthly basis.

38. The permittee shall prepare and maintain a site-specific inspection plan including a drawing or schematic of the components of applicable equipment subject to federal NESHAP for Source Categories, 40 CFR 63, Su bpart S, and record the information listed in 40 CFR 63.454(b) for each insp ection. [40 CFR 63.454(b)]

39. The permittee shall keep all applicable records as required by the following regulations:

a. 40 CFR Part 60 Subparts D and BB; and

b. 40 CFR Part 61 Subpart E; and

c. 40 CFR Part 63 Subparts S and MM.

d. For specific recordkeeping citations by EUG see Table X

IV. Reporting Requirements

A. The permittee shall meet all recordkeeping and reporting requireme nts as required by the following regulations:
1. 40 CFR Part 60 Subparts D and BB
2. 40 CFR Part 61 Subpart E
3. 40 CFR Part 63 Subparts S and MM
4. For specific reporting citations by EUG see Table X

V. Testing and Monitoring

A. The permittee shall meet all testing and monitoring requirements as required, including but not limited to the following regulations:
1. 40 CFR Part 60 Subparts D and BB
2. 40 CFR Part 61 Subpart E
3. 40 CFR Part 63 Subparts S and MM
4. For specific testing and monitori ng citations by EUG see Table X

B. No later than 30 days after each anniversary date of the issuance of the original Title V permit for this facility (October 17, 2008), the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certifi cation of compliance
with the terms and conditions of th is permit until January 1, 2011.

No later than 30 days after each (6) month period after the date of the issuance of the original Title V permit for this facility, th e permittee shall submit to AQD a report of all required monitoring not reported since the last semi-annual monitoring report until January 1, 2011.SPECIFIC CONDITIONS 97-057-TV (M-10) - 25

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No later than 30 days after January 1, 2011, the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certifi cation of compliance
with the terms and conditions of the Part 70 operating permit for the permit period of October 17, 2010 to January 1, 2011. The certif ication of compliance shall also contain a report of all required mon itoring not reported since the last semi-annual monitoring report (October 17, 2010 to January 1, 2011).

After January 1, 2011, no later th an 30 days after each annive rsary of the date January 1, 2011, the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certificati on of compliance with the terms and conditions of this permit.

After January 1, 2011, no later than 30 days af ter each (6) month period after the date January 1, 2011, the permittee shall submit to AQD a report of all required monitoring not reported since the last se mi-annual monitoring report. [OAC 252:100-8-6 (c)(5)(A) & (D)]

VI. Covered Permits

A. This permit supersedes all previous Air Quality operating permits which are now null and void. The actions requested in permit application No. 97-057-TV (M-7) have been incorporated into this permit. It will therefore be withdrawn upon issuance of this permit.Table X. Federal Regulatory Requirement Citations25EUG: Applicable Regs UnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicableParts of theGeneralProvisions:FW Part 82, Subpart B, F& HFacility-WideA1Subpart SNo. 1 DigesterSystem - ExistingKraft Digester63.443 and63.446 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart STable 1A1 Subpart BB,Applicable but nottriggered.No. 1 DigesterSystem - ExistingKraft DigesterNoneA2Subpart SNo. 2 DigesterSystem - ExistingKraft Digester63.443 and63.446 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart STable 1A2 Subpart BB,Applicable but nottriggered.No. 2 DigesterSystem - ExistingKraft DigesterNoneA3Subpart SNo. 3 DigesterSystem - ExistingSemi-ChemicalDigester63.443 and63.45063.453 63.454 Unit has no Subpart S limits, however with CCAutilization at the mill, need to monitor what’shappening with system.A3Subpart BB,Applicable but nottriggered.No. 3 DigesterSystem - ExistingSemi-ChemicalDigesterNoneA4,A5, &A7OCC Plants NoneA6Makedown Pulper NoneA8OCC LightweightRejects HandlingSystemNoneB1Subpart SNo. 1 BrownstockWashing Area63.447 63.453 63.454 63.447 &63.45563.457 40 CFR 63Subpart STable 1SPECIFIC CONDITIONS 97-057-TV (M-10)- 27 -Table X ContinuedEUG: Applicable Regs UnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicable Partsof the GeneralProvisions:B1 Subpart BB,Applicable but nottriggered.No. 1 BrownstockWashing AreaNoneB2 Subpart BB, No. 2 BrownstockWashing Area60.283 60.284B2 Subpart SNo. 2 BrownstockWashing Area63.447 63.453 63.454 63.447 &63.45563.457 40 CFR 63Subpart S Table 1B3 Subpart BB,Applicable but nottriggered.No. 3 BrownstockWashing AreaNoneB3 Subpart SNo. 3 BrownstockWashing AreaNone – CleanCondensateAlternative63.453 63.454C1No. 1 PaperMachine (StockPrep)NoneC2No. 1 PaperMachine (WetEnd)NoneC3No. 1 PaperMachine (WetEnd)NoneC4No. 2 PaperMachine (StockPrep)NoneC5No. 2 PaperMachine (WetEnd)NoneC6No. 2 PaperMachine (DryEnd)NoneC7No. 3 PaperMachine (StockPrep)NoneSPECIFIC CONDITIONS 97-057-TV (M-10)- 28 -Table X ContinuedEUG: Applicable Regs UnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicable Partsof the GeneralProvisions:C8No. 3 PaperMachine (WetEnd)NoneC9No. 3 PaperMachine (DryEnd)NoneD1 Subpart S(Applicable whenused as back-upcontrol device, butnot triggered)Bark BoilerNoneD1 Subpart DBark Boiler 60.43 & 60.44 60.4560.45 60.46D1 Subpart EBark Boiler61.52 61.54 & 61.55 61.53461.54D2Power Boiler NoneD3210 MMBtu/hrPackage BoilerNoneD6Subpart MMNew RecoveryFurnace63.862 &63.86463.864 63.866 63.867 63.865 40 CFR 63 MMTable 1D6Subpart SNew RecoveryFurnace63.443 63.453(m, n, & o)40 CFR 63S40 CFR 63S40 CFR 63S40 CFR 63SD6Subpart BBNew RecoveryFurnace60.282 &60.28360.284 60.284 60.284 60.284 &60.28540 CFR 60BBD6Subpart DbNew RecoveryFurnace60.44 (e) 40 CFR 60Db60.49(d,o,p)60.49(q)40 CFR 60Db40 CFR 60DbE1Subpart STurpentineRecovery System63.443 &63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart S Table 1E1Subpart BBTurpentineRecovery System60.283 see lime kiln &NCG thermaloxidizerE2aSubpart SSpent LiquorConcentration63.443 &63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart S Table 1E2aSubpart BBSpent LiquorConcentration60.283 see lime kiln &NCG thermaloxidizerSPECIFIC CONDITIONS 97-057-TV (M-10)- 29 -Table X ContinuedEUG: Applicable Regs UnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicable Partsof the GeneralProvisions:E2bEvaporator SewerSumpNoneE3dNew Spent LiquorMix TanksNone – Emissions routed to Recovery FurnaceE4bSubpart MMNew SmeltDissolving TankApplicable. However, no direct emissions from the SDT (except SSM/excessemissions). The SDT is vented to the recovery furnace.63.866 (a,b,c)E4bSubpart BB,New SmeltDissolving TankApplicable. However, no direct emissions from the SDT (except SSM/excessemissions). The SDT is vented to the recovery furnace.40 CFR 60BBE5Lime Slakers NoneE6CausticizingSystemNoneE7aSubpart MMLime Kiln 63.862 &63.86463.864 63.866 63.867 63.865 40 CFR 63 MMTable 1E7a Subpart S (whenused as a back-upcontrol device)Lime Kiln 63.443 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart S Table 1E7a Subpart BB (whenused as a back-upcontrol device) –applicable – but notbecause ofmodificationLime Kiln60.283 60.28460.284 60.285E8Tall Oil Plant NoneE9Organic LiquidStorage VesselsNoneSPECIFIC CONDITIONS 97-057-TV (M-10)- 30 -Table X ContinuedEUG: Applicable RegsUnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicableParts of theGeneralProvisions:E10Small Volatile OrganicLiquid Storage TanksNoneF1WoodyardNoneF2FacilityTrafficNoneF3Wastewater TreatmentSystemNoneF4a Subpart SNCG Collection andThermal OxidationSystem – LVHC63.443 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart STable 1F4a Subpart BB NCG Collection andThermal OxidationSystem – LVHC60.283 60.284 60.284 60.285F4b Subpart SNCG Collection andThermal OxidationSystem – HVLC63.443 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart STable 1F4b Subpart BB NCG Collection andThermal OxidationSystem – HVLC60.283 60.284 60.284 60.285F5Solid Waste DisposalFacility OperationsNoneF6Diesel StormwaterPumpNoneF7 &F9ChipThicknessScreening/ConditioningSystemNoneF10 Subpart SSteam Stripper System 63.443,63.446 and63.45063.453 63.454 63.455 63.457 40 CFR 63Subpart STable 1SPECIFIC CONDITIONS 97-057-TV (M-10)- 31 -Table X ContinuedEUG: Applicable Regs UnitEmissionlimitations: Monitoring:RecordkeepingRequirements:ReportingRequirements:TestMethods &ProceduresApplicableParts of theGeneralProvisions:F10 Subpart BB (applic–steam stripper prjt)Steam StripperSystem60.283 see lime kiln &NCG thermaloxidizerFllMisc.InsignificantActivitiesNoneF13Petcoke Silo BinVent No. 1NoneInternational Paper Attn: Kathryn Crenwelge

890 IP Lane Valliant, Oklahoma 74764

SUBJECT: Permit Number: 97-057-TV (M-10) Facility: IP Va lliant Paper Mill Location: Secs. 26, 27, 28, 33 a nd 34-T6S-R21E, McCurtain County

Permit Writer: Dale Becker

Dear Ms. Crenwelge:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit is issued subject to standard and specifi c conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections.

Also note that you are required to annually submit an emissions inve ntory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by April 1 st of every year. Any questions concerning the form or submittal process should be referred to the Emi ssions Inventory Sta ff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact

me at dale.becker@deq.ok.gov (405)702-4213 or (405)702-4100

Sincerely,

L. Dale Becker, P.E. AIR QUALITY DIVISION

EnclosureMAJOR SOURCE AIR QUALITY PERMIT
STANDARD CONDITIONS (July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Okl ahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is th e Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Ai r Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditi ons of this permit. Any permit noncompliance
shall constitute a violation of the Oklahoma Cl ean Air Act and shall be grounds for enforcement action, permit termination, revocation and reissuance, or modifi cation, or for denial of a permit renewal application. All terms and cond itions are enforceable by the DEQ, by the Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act (excluding state-only requirements). Th is permit is valid for operations only at the specific location listed. [40 C.F.R. §70.6(b), OAC 252:100-8-1.3 a nd OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. However, nothing in this paragraph shall be construed as precluding consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for noncompliance if the health, safety, or environm ental impacts of haltin g or reducing operations would be more serious than the impacts of continuing operations. [O AC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial danger to public health, safety, or the environm ent shall be reported in accordance with Section XIV (Emergencies). [OAC 252:100- 8-6(a)(3)(C)(i ii)(I) & (II)]

B. Deviations that result in emissions exceedin g those allowed in this permit shall be reported consistent with the requirem ents of OAC 252:100-9, Excess Em ission Reporting Requirements. [OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this sectio n shall be certified as required by Section III (Monitoring, Testing, Re cordkeeping & Reporting), Paragraph F. [OAC 252:100-8-6(a)(3)(C)(iv)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2

SECTION III. MONITORING, TES TING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including monitoring data and necessary support information, shall be retained on-sit e or at a nearby field office for a period of at least five years from th e date of the monitoring sample, measurement, report, or application, and shall be made av ailable for inspection by regulatory personnel upon request. Support information includes all orig inal strip-chart recordings for continuous monitoring instrumentation, and copies of all repo rts required by this perm it. Where appropriate, the permit may specify that records may be maintained in computerized form. [OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8- 6(c)(1), and OAC 252: 100-8-6(c)(2)(B)]

B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techni ques or methods used; (5) the results of such analyses; and (6) the operating conditions existing at th e time of sampling or measurement. [OAC 252:100-8- 6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit or alternative date as specifically identified in a subsequent Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requireme nts since the prev ious report shall be clearly identified in the report. Submission of these periodic reports will satisfy any reporting requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of S ection II (Reporting Of Deviations From Permit Terms) of these standard conditi ons. [OAC 252:100-8-6( a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be re quired under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeep ing, or as required by any pr ovision of the Federal Clean
Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report, Excess Emission Report, and Annual Emission I nventory submitted in accordance with this permit shall be certified by a responsible offici al. This certificatio n shall be signed by a responsible official, and shall contain the follow ing language: “I certif y, based on information and belief formed after reasonable inquiry, the st atements and information in the document are true, accurate, and complete.” [OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC 252:100-9-7(e), and OAC 252:100-5-2.1(f)] G. Any owner or operator subj ect to the provisions of Ne w Source Performance Standards (“NSPS”) under 40 CFR Part 60 or National Emi ssion Standards for Hazardous Air PollutantsMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 3

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall main tain a file of all measurements and other information required by the applicable general provi sions and subpart(s). These records shall be maintained in a permanent file suitable for insp ection, shall be retained for a period of at least five years as required by Paragraph A of this Section, and sh all include records of the occurrence and duration of any start-up, shutdo wn, or malfunction in the operati on of an affected facility, any malfunction of the air pollution control equipment; and any periods during which a continuous monitoring system or monitoring device is inoperative. [40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annuall y. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or comp liance was achieved. Th e progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods approved by the Division Director. All tests sh all be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the ma nufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. [OAC 252:100-8-6(a)(3)(A )(iv), and OAC 252:100-43]

J. The reporting of total particulate matter em issions as required in Part 7 of OAC 252:100-8 (Permits for Part 70 Sources), OAC 252:100-19 (Control of Emissi on of Particulate Matter), and OAC 252:100-5 (Emission Inventory), shall be conduc ted in accordance with applicable testing or calculation procedures, modified to include b ack-half condensables, for the concentration of particulate matter less than 10 microns in diameter (PM 10 ). NSPS may allow reporting of only particulate matter emissions caught in the f ilter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252: 100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMP LIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit or alternative date as specificall y identified in a subsequent Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become ef fective since the issuance of this permit. [OAC 252:100-8-6(c)(5)(A), and (D)] B. The compliance certification sha ll describe the operating permit term or condition that is the basis of the certification; the current compliance status; whethe r compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reportingMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 4

period. The compliance certification shall also include such other facts as the permitting authority may require to determine th e compliance status of the source. [OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification sh all contain a certifica tion by a responsible official as to the results of the required monitoring. This certification shall be si gned by a responsible official, and shall contain the following language: “I certify, based on information and belief formed after reasonable inquiry, the statements and in formation in the document are true, accurate, and complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions units or stationary sources that are not in comp liance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance w ith any applicable requirements for which the emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or
administrative order to which the emissions unit or stationary source is subject. Any such schedule of compliance shall be supplemental to , and shall not sanction noncompliance with, the applicable requirements on which it is based, excep t that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the permit term and that are applicable to the fac ility. Compliance with all new requirements shall

be certified in the next annual cer tification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC 252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are li sted in the Standard Conditions and the Specific Conditions of this permit. Thos e requirements that the applicant requested be determined as not applicable are summarized in the Specific Condi tions of this permit. [OAC 252:100-8-6(d)(2)]

SECTION VII. ANNUAL EMISSI ONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees
based on emissions inventories. The methods used to calculate emissions for inventory purposes
shall be based on the best availa ble information accepted by AQD. [OAC 252:100-5-2.1, OAC 252:100-5- 2.2, and OAC 252:100-8-6(a)(8)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 5

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, th e term of an operating permit sha ll be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expirati on of its permit unless a timely and complete renewal application has been su bmitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provi ded in OAC 252:100-8-1.4(b) ) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit sha ll apply for a permit to operate (or modified operating permit) within 180 days following the fi rst day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this perm it, or the application of any provision of this permit to any circumstance, is held in valid, the application of such provision to other circumstances, a nd the remainder of this permit, shall not be affected thereby. [OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any proper ty rights of any sort, or any exclusive privilege. [OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in a ny manner affecting the titl e of the premises upon which the equipment is located and does not rel ease the permittee from any liability for damage
to persons or property caused by or resulting from the mainte nance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon r eceipt of a written requ est and within sixty (60) days of the request unless the DEQ specifi es another time period, any information that the DEQ may request to determine whether cause exists for modifying, reopening, revoking, reissuing, terminating th e permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. § 2-5-105(18). Confidential information shal l be clearly la beled as such and shall be separable from the main body of the document such as in an attachment.MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 6

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this f acility is required and shall be made in writing within thirty (30) days after such sale or transfer. [Oklahoma Clean Air Ac t, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopene d and reissued, or terminated for cause. Except as provided for minor permit modifications , the filing of a request by the permittee for a permit modification, revocation and reissuance, te rmination, notification of planned changes, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6(a)(7)( C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the following circumstances: [OAC 252:100- 8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Ac t become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the eff ective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements. (3) The DEQ or the EPA determines that inaccura te information was used in establishing the emission standards, limitations, or other condi tions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ. (4) DEQ determines that the permit should be amended under the discretionary reopening provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8- 7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making ch anges other than those described in Section XVIII (Operational Flexibility), those qualifying fo r administrative permit amendments, or those defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The notification should include any changes which may alter the status of a “grandfathered source,” as defined under AQD rules. Such cha nges may require a permit modification. [OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]

E. Activities that will result in air emissions th at exceed the trivial/insignificant levels and that are not specifically approved by this perm it are prohibited. [O AC 252:100-8-6(c)(6)]

SECTION XIII. IN SPECTION & ENTRY

A. Upon presentation of credentials and othe r documents as may be required by law, the permittee shall allow authorized regulatory offi cials to perform the following (subject to theMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 7

permittee's right to seek conf idential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)
for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions -related activity is conducted, or where records must be kept under the conditions of the permit; (2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including monitoring and air po llution control equipment), practices, or operations regulated or required under the permit; and (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring complian ce with the permit. [OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later than 4:30 p.m. on the next working day afte r the permittee first becomes aware of the exceedance. This notice shall contain a descript ion of the emergency, the probable cause of the exceedance, any steps taken to mitigate emi ssions, and corrective actions taken. [OAC 252:100-8-6 (a)(3 )(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and subs tantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100- 8-6(a)(3)(C )(iii)(II)]

C. An "emergency" means any situation arisi ng from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal ope ration, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An em ergency shall not include noncompliance to the extent caused by improperly designed equipment, lack of preventive maintenance, careless or improper operation, or operator error. [OAC 252:100-8-2] D. The affirmative defense of emergency sh all be demonstrated through properly signed, contemporaneous operating logs or other rele vant evidence that: [O AC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee ca n identify the cause or causes of the

emergency; (2) the permitted facility was at the time being properly operated; (3) during the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emissi on standards or other requirements in this permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 8

F. Every written report or document submitted unde r this section shall be certified as required by Section III (Mon itoring, Testing, Recordkeeping & Reporting), Paragraph F. [OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Se ction 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date . [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are eith er on the list in Appendix I to OAC Title 252, Chapter 100, or whose actual calendar year emissi ons do not exceed any of the limits below. Any activity to which a State or Federal applicab le requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant. (2) 2 tons per year for any one hazardous air pol lutant (HAP) or 5 tons per year for an aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule. [OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emi ssions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or Federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OP ERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in the permit). When an operating scenario is changed, th e permittee shall record in a log at the facility the scenario under which it is operati ng. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted em ission rate of any existing emissions unit to be exceeded;MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 9

provided that the f acility provides the EPA and the DEQ with written notification as required below in advance of the proposed changes, whic h shall be a minimum of seven (7) days, or twenty four (24) hours for emergencies as defi ned in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification re quired above shall include a br ief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longe r applicable as a result of the change. The permit shield provided by this permit does not a pply to any change made pursuant to this paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless elsewhere covered by a mo re restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditi ons listed in the Open Burning Subchapter. [OAC 252:100-13] (2) No particulate emissions from any fuel-burni ng equipment with a ra ted heat input of 10
MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an op acity limit promulgated under 40 C.F.R., Part 60, NSPS, no discharge of greater than 20% opacity is allowed except for: [OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three su ch periods in any consecutive 24 hours. In no case shall the average of any si x-minute period exceed 60% opacity; (b) Smoke resulting from fires covered by th e exceptions outlined in OAC 252:100-13-7; (c) An emission, where the presence of uncombi ned water is the only reason for failure to meet the requirements of OAC 252:100-25-3(a); or (d) Smoke generated due to a malfunction in a facility, when the source of the fuel producing the smoke is not under the direct a nd immediate control of the facility and

the immediate constriction of the fuel flow at the fac ility would produce a hazard to life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standa rds to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fi red fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed th e listed ambient air standards for sulfur dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storag e tanks built after December 28, 1974, and with a capacity of 400 gallons or more stori ng a liquid with a vapor pressure of 1.5 psiaMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 10

or greater under actual conditions shall be e quipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the followi ng standards for production and consumption of ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an or der for production or im portation of certain class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the requirements of §82.4; (2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping requirements at §82.13; and (3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon tetrachloride, tr ichloroethane (methyl chloroform), and bromomethane (Methyl Bromide). Class II substances (lis ted at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance re frigerant (or regulated substitute s ubstance) in the motor vehicle air conditioner (MVAC), the permittee is subject to a ll applicable requirements. Note: The term
“motor vehicle” as used in S ubpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC ” as used in Subpart B does not include the air-tight sealed refrigeration system used as re frigerated cargo, or the system used on passenger buses using HCFC-22 refrigeran t. [40 CFR 82, Subpart B] C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, se rvice, repair, or disposal must comply with the required pract ices pursuant to § 82.156; (2) Equipment used during the mainte nance, service, repair, or di sposal of appliances must comply with the standards for recycling and recovery equipment pursuant to § 82.158; (3) Persons performing maintenance, service, repa ir, or disposal of appliances must be certified by an approved technician cert ification program pursuant to § 82.161; (4) Persons disposing of small appliances, MVAC s, and MVAC-like appliances must comply with record-keeping requirements pursuant to § 82.166; (5) Persons owning commercial or industrial pro cess refrigeration equipment must comply with leak repair requireme nts pursuant to § 82.158; and (6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 11

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work asso ciated with permit revi ew and, wherever it is not inconsistent with Federal requirements, to provide for incorporation of requirements established through construction permitting into the Source’s Title V permit without causing redundant review. Requirements from construction permits may be incorporated into the Title V permit through the administrative amendment pro cess set forth in OAC 252:100-8-7.2(a) only if the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to the public that this permit is subject to EPA review, EPA objection, and petition to EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit. (2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected Stat e, as provided by 40 C.F.R. § 70.8(b). (4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as provided by 40 C.F.R.§ 70.8(a) and (c). (5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 C.F.R. § 70.8(d). (7) A copy of the final construction permit is sent to EPA as provide d by 40 CFR § 70.8(a). (8) The DEQ shall not issue the proposed construction permit until any affected State and EPA have had an opportunity to review the proposed permit, as provided by these permit conditions. (9) Any requirements of the construction permit may be reopened for cause after incorporation into the Title V permit by th e administrative amendment process, by DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40 C.F.R. § 70.7(f) and (g). (10) The DEQ shall not issue the administrativ e permit amendment if performance tests fail to demonstrate that the source is operati ng in substantial compliance with all permit requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifica tions or establishing whether or not a person
has violated or is in violat ion of any provision of the Okla homa implementation plan, nothingMAJOR SOURCE STANDARD CONDITIONS July 21, 2009 12

shall preclude the use, including the exclusive use, of any credible evidence or information,
relevant to whether a source woul d have been in compliance with applicable requirements if the appropriate performance or compliance te st or procedure had been performed. [OAC 252:100-43-6]