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 for a modification to the Part 70 permit for the IP Valliant Paper 

Mill (Valliant). The facility is currently operating as authorized by Permit No. 97-057-TV. 

The proposed modification was submitted to address 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 Administrative Code (OAC). 

Facilities with affected equipment were required 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 permit 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 mandatory 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 review of the impact on Class I areas by the affected sources at 

the Valliant plant. This review indicated that Valliant could control 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 Federal area. Valliant submitted an application to 

include the limits in its Title V permits which assure that the facility qualifies for a waiver of 
PERMIT MEMORANDUM 97-057-TV (M-10) - 2 - 

BART requirements on December 1, 2006; with 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 authorization 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 oil is to be added to liquor 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 

unchanged. 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 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 ensure that emissions from this change will be 

negligible. DEQ agrees with this change since 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 and document the quantity of fuel used and its 

sulfur content to demonstrate that emissions 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 increase of 1.97 tons) for the #2 BSW. The request 

also included adding clarifying language to the power boiler description. These adjustments 

result in no adverse air quality impacts. DEQ 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 requirements. It does not involve significant changes to existing 

monitoring, reporting or recordkeeping requirements in the permit. It does not require or 

change a case-by-case determination of an emission limitation or other standard, or a sourcespecific determination for temporary sources of ambient impacts, or a visibility or increment 

analysis. 

3. A change of the compliance reporting periods and 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 was 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 withdrawn upon issuance of this permit. 
PERMIT MEMORANDUM 97-057-TV (M-10) - 3 - 

The IP Valliant Paper Mill is a Kraft Process 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 Price Companies). The determination made by the Air 

Quality Division (AQD) is that there was no clear indication that the two 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 operation 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. Other than for collocation-related purposes, the 

wood chipping facility is not addressed 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 construction 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 exception of the wastewater pipeline requirements (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 effect, at this time. Applicable requirements will 

be incorporated into this operating 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 digesters, secondary fiber processing, and paper 

machines. The primary raw materials used in the production of paper products 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, washed, and calcinated for reuse. Steam requirements are supplied by 

two large boilers (Bark Boiler and Power Boiler), a small package boiler and by a recovery 

furnace. Steam is also used to drive a turbine electric generator that supplements the mill’s 

electric energy needs. 

SECTION III. PROCESS DESCRIPTIONS 

Operations at the Valliant Mill have been subdivided into six functional areas. The functional 

areas are based on the flow of materials within the Valliant Mill and on the various steps in the 

production process. Emissions units within each functional process area are identified. Any 

particular emissions unit may include more than one significant emission point. 
PERMIT MEMORANDUM 97-057-TV (M-10) - 4 - 

VALLIANT MILL FUNCTIONAL AREAS

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 Functional 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 End) 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); F12 – 

Wood Chipping operation – owned and operated by Valliant Chips, Inc. (The Price Companies). 

Functional Area A - Pulping 

Digester Areas (EUGs A1, A2, A3) 

The Digesters produce pulp by utilizing a chemical pulping process 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 Kraft 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) Noncondensible Gas (NCG) Collection System (EUG F4b). 

From each chip bin, a meter feeds the material into a steaming vessel, which heats the material to 

processing temperature. The steaming vessels are vented to the Turpentine Recovery System (EUG 

E1). 

From the steaming vessels, the fiber 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 fiber source material is steeped in cooking liquor in the impregnation vessel 

before its introduction into the Digester. 

Vapors produced by the cooking process are vented to the Turpentine Recovery System (EUG 

E1). The spent cooking liquor, which contains dissolved 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 tanks. 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 Digesters. The 

brownstock passes through defibrators, which mechanically break apart the mostly-digested fibers. 

The pulp is then sent to a surge tank that is vented to the HVLC NCG Collection System (EUG 

F4b). 

Repulping Operations (OCC Plants) (EUGs A4, A5, A6, A7) 

Repulping operations prepare fiber for the paper 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 container) materials, which include, but are not 

limited to, old corrugated containers (e.g., cardboard boxes), old newspapers, rejected materials 

from paper machines or box manufacturing facilities, and other types 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 light 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 are pressed to remove water, then may be disposed 

on site, transferred off-site, or transferred to a receiving bin before being used as a fuel source. 

The prepared fiber is stored in OCC high density 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. There 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 particulate 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 brownstock 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-through 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 remove spent cooking chemicals. After being 

washed, the pulp is transferred to several high density 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 washing process or is returned to the digester areas. 

Brownstock Washing Area 3 performs a similar function to that described above for Brownstock 

Washing Areas 1 and 2. However, Brownstock Washing Area 3 washes pulp from the No. 3 

Digester, which uses a semi-chemical pulping system. Therefore, Brownstock Washing Area 3 

is not subject to the maximum achievable control technology (MACT) standard for pulp and 

paper mills (40 CFR Part 63, Subpart S). 

Functional Area C - Paper Making

Paper Machine Stock Preparation (EUGs C1, C4, C7) 

Stock preparation is a process of blending the fibers (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 cleaned as it passes from vessel to vessel through the 

stock preparation process. Stock from various sources, 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 addition, fiber recycled from the wet end or the dry end 

(known as broke) may be processed and added to the stock during preparation. 

The various chests (vessels) associated with the stock preparation process are vented either 

directly to the atmosphere or to the interior of the paper machine building. 

Paper Machine Wet End (EUGs C2, C5, C8) 

The paper machine wet end forms a base sheet by means of the primary headbox, which 

distributes the dilute stock evenly over a continuously 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 supported first by the wire screen and then by a moving felt sheet. 
PERMIT MEMORANDUM 97-057-TV (M-10) - 7 - 

Water removed from the stock during processing, called 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 machine 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 machine 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 operates 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 electricity. Steam extracted from the generator and 

steam that by-passes the generator is fed into the steam distribution system for use in various 

processes. Steam from the Package Boiler feeds directly into the steam distribution system. 

The Bark Boiler (EUG D1) burns a variety of fuels in varying combinations and amounts. Fuels 

include but are not limited to wood residues, OCC rejects, wastewater treatment sludge, oil, and 

natural gas. Oils from mill equipment (including small portions of used antifreeze and 

miscellaneous non-hazardous used parts washer fluid) may also be added to the Bark Boiler fuel 

mixture. The Bark Boiler is also capable of burning coal. Particulate emissions 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 and the wet venturi scrubber also results in a 

reduction in SO2 emissions. Its emissions are discharged 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 Tall Oil Scrubber (Main Stack). The Power Boiler 

annual emissions are tracked with the New Recovery Furnace (Phase I). 

The Package Boiler (EUG D3) burns only natural gas. 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 concentration area (EUGs E2a and E2b) or spent liquor obtained from offsite. Prior to being burned, the spent liquor may pass through the Spent Liquor Mix Tanks (EUG 

E3d), where it may be mixed with particulate matter captured in the Recovery Furnace’s 

electrostatic precipitator (ESP). The spent liquor 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 available for the smelt dissolving tank. 

The new Recovery Furnace is the primary control 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 burning other materials that may contain spent cooking chemicals, 

such as soap from the evaporators, brine from the 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 liquor 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 unchanged. 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 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 ensure that emissions from this change will be 

negligible. DEQ agrees with this change since 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 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 turpentine 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 combusted 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 separates the turpentine from the 

remaining water. The water is drawn off and sent to the steam stripper 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 the 
PERMIT 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 pump tank that receives liquid from the cyclone 

separators, and the collection tank 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 from 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 storage, 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 conversion 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 recover process chemicals from the spent liquor 

concentration area or spent liquor obtained from off-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 Furnace’s electrostatic precipitator (ESP). The spent 

liquor mix tanks emit through the new recovery furnace. 

A molten inorganic residue called smelt forms in the 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 causticizing process that regenerates cooking chemicals. The smelt dissolving tank 

also emits through the new recovery furnace. There is an emergency by-pass stack available. 

Smelt Dissolving Tank (EUG E4b) 

Smelt from the Recovery Furnace flows into the Smelt Dissolving Tank, 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 Green Liquor Clarifier (EUG 

E6) for further processing. After particulate emissions have been reduced with aqueous sprays, 

the Smelt Dissolving Tank is vented through the Recovery 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 initiate the causticizing process 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 enters the Slakers from the green liquor clarifier, 
PERMIT MEMORANDUM 97-057-TV (M-10) - 10 - 

from green liquor storage, or from off-site sources. The mixture of green liquor and lime flows 

from the Slakers through classifiers, which remove unreacted lime and other debris, to the 

Causticizers. 

Causticizing Area (EUG E6) 

In the Causticizing area, cooking liquor is regenerated 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 particles, such as undissolved smelt, are allowed to settle out. The 

settled material, known as dregs, goes to the dregs 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 the Slakers, the green liquor goes through a series 

of Causticizers (agitated holding tanks) 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, used in the Digesters, or transferred offsite. The material that settles to the bottom of the cooking liquor clarifiers 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 will be calcined in the Lime Kiln (EUG E7a), 

converting it back to calcium oxide. This Lime Kiln product is transported to the lime bins. If 

the Lime Kiln is not operating, the lime mud is disposed in the on-site Solid 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 and petcoke and is also used as a backup to the 

Recovery Furnace (or as backup to the secondary backup Thermal Oxidizer) if it is not being 

used to oxidize the collected NCGs and/or Stripper Off Gases (SOGs). 

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

collected lime dust to the kiln. 

The regenerated quick lime is transferred to the 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 recovered and sold for various commercial uses. It is produced by 

the Tall Oil Plant from the soap collected during spent liquor evaporation (EUGs E2a and E2b). 

Tall oil is produced by charging the Tall Oil Reactor with soap, water, and 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. The 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 contains lignin and other organic materials. 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 the storage tanks directly to transport vessels or to another storage 

tank. Tall oil can be loaded into 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 (TRS) from the tall oil reactor, 

the wet tall oil tanks, and the brine tank. This scrubber is vented 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 material into receiving 

pits. The received materials can be stored for later retrieval or conveyed directly to the screening 

operation. 

Material to be stored is stockpiled into storage piles by stackers. Material can be removed from 

the storage piles by reclaimers. Reclaimed 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 transferred as needed from the chip silos to the chip 

bins in the Digester areas (EUGs A1, A2, and A3). 

Conveyors and transfer points in the fiber source material handling 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 storage pile. Oversized materials can be sent offsite or diverted from the 

fiber source processing/storage area and pass through a hogger for size reduction before being 

stockpiled. Fuel reclaimed from the storage pile is conveyed directly to the Bark Boiler. 

Conveyors and transfer points in the fuel handling system are partially covered and/or enclosed. 

This serves to reduce the potential for fugitive particulate emissions from material handling 

operations. 

Plant Traffic Road Emissions (EUG F2)

Heavy trucks and other vehicles regularly travel on paved and unpaved roads within the Valliant 

Mill. These vehicles are expected to cause fugitive 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 cleaned 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 materials, the shipping of finished 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 Dewatering Operation, Aerated Stabilization Basins, and 

Emergency Storage Ponds. With the exception of the Sludge Dewatering Operation, the 

Wastewater Treatment System (WWTS) components 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 contained 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. The 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, either to another basin 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 Effluent Clarifier, or 

bypass the clarifier and mix directly with the overflow from the Runoff Pond. Solids from the 

primary clarifier go to the Sludge Dewatering Operation. 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. Liquid from the clarifier combines with water from 

the Runoff Pond. Microbial nutrients may be added to the clarifier effluent to aid biodegradation 
PERMIT MEMORANDUM 97-057-TV (M-10) - 13 - 

of organic materials in the liquid. If necessary, clarifier effluent and runoff pond effluent can be 

sent to emergency holding ponds. Chemicals may be used to control WWTS H2S or foaming. 

From the No. 1 Aerated Stabilization Basin, wastewater is either discharged or enters the No. 2 

Aerated Stabilization Basin for final settling, biodegradation, and clarifying. The effluent from 

the No. 2 Aerated Stabilization Basin is discharged 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 wastewater effluent from the Valliant Mill to the Red River. 

Under normal operating conditions, effluent from the Valliant Mill 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 (H2S) formed in the pipeline. From the collection box, the 

effluent flows to a 200-foot diffuser at the bottom 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-concentration sources of NCGs, whereas the HVLC 

streams produce more total gas flow but much lower concentrations of NCGs. The following 

sources of concentrated NCGs are 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 surge tanks are vented to the HVLC system (EUG F4b). NCGs from 

the No. 1 Digester chip bin are routed directly to the combustion 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 unavailable, the NCG thermal oxidizer 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 used 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 conditions, the NCG streams may be released to the 

atmosphere for a relatively short time for safety reasons. These are recognized technological 

limitations for purposes of excess emissions reporting (OAC 252:100-9-1). 

Solid Waste Disposal Facility Operations (EUG F5) 

A variety of solid wastes are generated as part of the manufacturing processes at the Valliant 

Mill. Wastes generally are transported via trucks from the Valliant Mill to the on-site Solid 

Waste Disposal facility (landfill) located south of the manufacturing complex. The trucks 

regularly travel back and forth between the Solid Waste Disposal Facility and manufacturing 

areas. The majority of the roads in the manufacturing complex are paved, while those in the 

Solid Waste Disposal Facility area are unpaved. 

Vehicle traffic related to Solid Waste Disposal 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 emissions. To limit fugitive emissions, 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 line. In the event that the new Recovery Furnace 

becomes unstable or must be taken off-line, the Lime Kiln (EUG E7a) is used to thermally oxidize 

all the SOGs or the secondary backup is the Thermal 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 conveyance. The silo is equipped with a bin vent that allows for air 

displacement when the silo is being filled with petcoke. The bin vent is equipped 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 here from the permit application, e.g. “E-A4,C.” 

The applicant has requested that heat input capacity for several units be kept 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 Tank 
PERMIT 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 Industry 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 Rejects 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 

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

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 1st

 Stage Brownstock Washer 

E-B2, B 2nd Stage Brownstock Washer 
PERMIT 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 therefore not subject to this MACT. 

EUG C1 – No. 1 Paper Machine (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 cylindrical wire mesh screen used for draining 

water from pulp. 

EUG C4 – No. 2 Paper Machine (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 Section 
PERMIT MEMORANDUM 97-057-TV (M-10) - 18 - 

EUG C7 – No. 3 Paper Machine (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 2006  
PERMIT 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 Tanks – 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-1972 
PERMIT 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 Tanks– 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 stacks be extended or control 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 Causticizer 
PERMIT 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, Subpart S as a back-up air pollution control device. 

Subpart MM was promulgated on January 12, 2001, to regulate lime kilns 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” requiring 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 Storage 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-1972/2003 
PERMIT 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 matches 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 1995 
PERMIT 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) 

ADS-2 Air Density Separator 1998 

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. INSIGNIFICANT 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 considered an “existing” source. Therefore the black 

liquor storage tanks in this EUG are not regulated by Subpart S. 

EUG E10 - Small Volatile Organic 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 Handling System No. 1 

Emission Point EU Name/Model Construction 

Date 

F13 Petcoke Handling System No. 1 2005 

Emissions associated with the Petcoke Handling 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 Insignificant 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 House 
PERMIT MEMORANDUM 97-057-TV (M-10) - 25 - 

exceeding 500 hours per year. The facility 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 category includes the administration building boiler 

with 2.5 MMBTUH heat input and a small boiler in the personnel building. 

* Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles 

if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. 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 handling facilities, equipment, and storage tanks except those subject 

to New Source Performance Standards and standards in OAC 252:100-37-15, 39-30, 39-41, and 

39-48. The facility includes a diesel 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 turpentine 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 aeration pads utilized for soils excavated at the facility only. 

None listed but may be conducted in the future. 

*Non-commercial water washing operations and drum crushing operations (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 includes 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 staging areas. The facility includes a waste 

accumulation area. 

Sanitary sewage collection and treatment facilities other than incinerators and Publicly Owned 

Treatment Works (POTW); Stacks or vents for sanitary sewer plumbing traps are also included 

(i.e., lift station). 

Emissions from landfills and land farms unless otherwise 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. The 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 operations 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 activities. The insignificant activities included 

in this category are denoted as such in the insignificant activities list maintained and updated on 

site. 

SECTION VI. EMISSIONS 

Valliant Mill has examined aspects of all major production areas at the plant to determine the 

maximum material process rates in order to calculate 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 and 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 (greater than daily) average emissions are based on the maximum 

sustainable process rates. 

The Valliant Mill has examined various sources to determine appropriate emission factors, 

including stack tests, mass balances, U.S. EPA AP-42, NCASI technical 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 account 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 emission factors incorporate a safety factor. 

The application has requested that all emission factors be kept confidential since they were the 

product of a lengthy and expensive research project. 

Additional rates for Baseline Emissions, Baseline Accommodated, and Projected 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 Furnace2 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 Washer1 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 and 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 Operation PM10 CO SO2 NOx VOC***

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr 

A7 No 3 OCC Plant Fugitives -- -- -- -- -- -- -- -- 25.06 A8 OCC Lightweight Rejects Handling System 0.46 1.9 -- -- -- -- -- -- -- 

B1 No. 1 Brownstock Washing -- -- -- -- -- -- -- -- 26.57 1B2 No. 2 Brownstock Washing -- -- -- -- -- -- -- -- 19.19 B3 No. 3 Brownstock Washing -- -- -- -- -- -- -- -- 14.76 

C1, C2 & C3 No. 1 Paper Machine 3.6 13.14 -- -- -- -- -- -- 310.64 1C4, C5 & C6 No. 2 Paper Machine 1.70 6.35 -- -- -- -- -- -- 146.69 5C7, C8 & C9 No. 3 Paper Machine 1.95 6.57 -- -- -- -- -- -- 168.26 5

D1 Bark Boiler 90.0 306.6 6,626.7 11399.39 720.0 254.48 270.0 840.08 51.1 1D2 Power Boiler 171.0 92.99 1,486.8 1022.40 7.49 D3 Package Boiler 1.89 6.50 16.23 55.86 0.13 0.43 21.67 74.58 17.2 D6 New Recovery Furnace 49.07 482.56 1155.39 657.39 41.25 

D2/D6 Comb. Annual Emissions 668.3 533.9 7139.4 3956.0 

E2b Evaporator Sump -- -- -- -- -- -- -- -- 52.63 2

E5,A &B Slaker Vent No. 1 & 2 0.12 0.39 -- -- -- -- -- -- 66.74 2

E6 Causticizer Vents Combined -- -- -- -- -- -- -- -- 61.88 2

E7a Lime Kiln 1.93 5.37 36.30 101.07 14.64 40.72 50.40 140.18 12.00 

E8 Tall Oil Plant -- -- -- -- -- -- -- -- 84.56 

 Unloading at Dumps 1.6 1.5 -- -- -- -- -- -- -- 

Pulping Material Pile 2.1 1.9 -- -- -- -- -- -- 0.3 

Hog Fuel Storage Piles 0.5 0.4 -- -- -- -- -- -- 0.1 

F2 Facility Traffic 4.5 19.8 -- -- -- -- -- -- -- 
PERMIT MEMORANDUM 97-057-TV (M-10) - 29 - 

EUG Operation 

PM10 CO SO2 NOx VOC**** 

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TP

aste DF* Road Emissions 6.6 5.8 -- -- -- -- -- -- -- -

F3a Wastewater Treatment System -- -- -- -- -- -- -- -- 312.57 1264

F3b Wastewater Pipeline** -- -- -- -- -- -- -- -- -- -

F4a 

&F4b NCG Collection 7.6 0.4 41.5 91.1 0.7 

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.

F7 & 

F9 

No 3 Chip & No 1 Chip 

Screening/Conditioning 1.26 5.16 -- -- -- -- -- -- 4.73 19.

 Plant-Wide Fugitives -- -- -- -- -- -- -- -- 23.77 528

F11 Misc. Insignificant Activities 0.7 0.2 2.1 0.5 0.6 0.2 9.7 2.4 0.8 0.

TOTALS 656 2,546 9,445 14,591 2,652 8,712 1,278 5,353 1,135 4,4

*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 
PERMIT MEMORANDUM 97-057-TV (M-10) - 30 - 

Thermal Oxidizer TPY emissions are accounted for 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 reacting with oxygen in the 

instrument. If the organic molecules had single bonds, double bonds, or even triple bonds, the 

signal was the same. So since the measurement method 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 carbon. By 1996, EPA reversed their position and said VOC should 

be shown as it actually is emitted. Remembering the limitations of Method 25A, you have to 

convert the measured results to an as-emitted molecular weight. More recent guidance from EPA 

(June 2006) indicated no data is readily available for pulp and paper 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 brownstock washers have been converted to a 

combined alpha-pinene/methanol factor. VOCs have been evaluated with alpha-pinene for the 

chip handling, chip and bark stacks, etc. and methanol 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 National 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 appropriate, 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 major source of HAP emissions.
PERMIT MEMORANDUM 97-057-TV (M-10) - 32 - 

SECTION VI. BART. REVIEW 

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

*the source must fall within the 26 source category list, 

*have units which were put in place during the 1962 to 1977 time frame, 

*and have potential emissions of air pollutants (NOx, SO2, PM10, PM2.5) which may reasonably 

cause or contribute to visibility impairment above 250 TPY from affected units. 

In support of BART applicability and permitting activities 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 percentile impact at any of the four nearest Class 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 historical operations and noted that 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 construction 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 modified existing permit limits to accommodate the 

potential changes to the Mill. A Title V operating 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 emission rates contained in 

Title V permit No. 97-057-TV, did not correspond with the emission rates in the BART 

submittal. International Paper has revised modeling 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 emission are rates being incorporated into the Title 

V operating permit as emission limits which will become effective five years after the date of 

EPA’s approval of the DEQ's BART State Implementation Plan. Emissions in this modified 

permit have been revised to reflect the most current 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 BART analysis process, International Paper has 

discovered that in order to not exceed the BART threshold of 0.5 deciview (~dv) for the 98th 

percentile impact while operating the Bark Boiler using fuel oil, operations would have to be 

limited significantly. As part of the PSD permit application, the Mill requested permitting of 

multiple operating scenarios (described in the application as Phases 3A and 3B). Since the Mill 

is permitted to operate under either 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 modeled 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) - emissions 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 S02lbs/hr 

S04

lbs/hr 

NOX 

lbs/hr

PM10

lbs/hr 

PM2.5 

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-HOUR AVERAGE) (REVISED PHASE 3A) 

Point 

ID Source Name S02lbs/hr 

S04

lbs/hr 

NOX 

lbs/hr

PM10

lbs/hr 

PM2.5 

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 fuel
PERMIT MEMORANDUM 97-057-TV (M-10) - 34 - 

EMISSION RATES (PREVIOUSLY PERMITTED PHASE 3B) 

Point 

ID Source Name S02

lbs/hr 

S04

lbs/hr 

NOX 

lbs/hr

PM10

lbs/hr 

PM2.5 

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 (9/03) 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 S02lbs/hr 

S04

lbs/hr 

NOX 

lbs/hr

PM10

lbs/hr 

PM2.5 

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 S02lbs/hr 

S04

lbs/hr 

NOX 

lbs/hr

PM10

lbs/hr 

PM2.5 

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 (9/03) 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 versions 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 initial BART modeling. CALPUFF and CALPOST 
PERMIT MEMORANDUM 97-057-TV (M-10) - 35 - 

executable versions were then selected as appropriate 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 98th percentile values indicate that the Valliant Mill’s contribution to visibility impairment is 

below the 0.5 ~dv threshold at Caney Creek. The 98th percentile at Upper Buffalo for the same 

period was modeled to be less the 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 98th % ~ dv 

 Caney Creek Herc-Glades Upper 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 98th % ~ dv 

 Caney Creek Herc-Glades Upper 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 98th % ~ dv 

 Caney Creek Herc-Glades Upper 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 SO2 NOX PM\PMIO

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 BOILER AND POWER BOILER 

Point ID Source Name SO2 NOX PM\PMIO

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 SO2 NOX PM\PMIO

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 compliance 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 Provisions) [Applicable] 

Subchapter 1 includes definitions but there are no regulatory requirements. 

OAC 252:100-2 (Incorporation 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 Regulations 
PERMIT MEMORANDUM 97-057-TV (M-10) - 37 - 

listed in OAC 252:100, Appendix Q are hereby incorporated 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 Secondary Standards are in Appendix F of the Air 

Pollution Control Rules. At this time, all of Oklahoma 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 requirements for Part 70 permits. Any planned 

changes in the operation of the facility which result in emissions not authorized in the permit and 

which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior 

notification to AQD and may require a permit modification. Insignificant 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 permits: 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, 97-057-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 permit 
PERMIT 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 Incorporated 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 construction Superseded by 97-057-C (M-9) (PSD) 

97-057-C (M-8)(PSD) Phased construction 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 Reporting 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 than 4:30 p.m. the following 

working day of the first occurrence of excess emissions in each excess 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 event. Request for affirmative defense, as described in OAC 

252:100-9-8, shall be included in the excess emissions event report. Additional 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 material is prohibited except as authorized in the 

specific examples and under the conditions listed in this subchapter. 

OAC 252:100-19 (Particulate Matter (PM)) [Applicable] 

This subchapter is applicable to the Lime Kiln, the several boilers, and the Recovery Furnace but 

not to the NCG Thermal Oxidizer. “Fuel-burning equipment” 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 does not provide any useable heat or power and, 

therefore, does not meet the definition 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 stringent 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 emissions 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 other 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 Subchapter 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 for these units have been verified 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 for 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 consecutive 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, transportation, or disposition of any substance likely to 

become airborne or wind-borne without taking “reasonable precautions” to minimize emissions 
PERMIT 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 emissions 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, therefore non-brittle and not very 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 (SO2) emissions from any existing facility 

or any new petroleum and natural gas process facility subject to OAC 252:100-31-26(a)(1). The 

ambient air quality modeling summarized in the following table demonstrates compliance with 

the SO2 standards. 

COMPLIANCE WITH SO2 AMBIENT IMPACTS LIMITATIONS 

Averaging Period Ambient SO2 Impacts 

Limitation, ug/m3

Modeled SO2 Impacts, ug/m3

3-Hours 650 299 

24-Hours 130 104 

Part 2 also limits H2S 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 

H2S on a dry basis) 

TRS Emission Rate Test 

Results 

Recovery Furnace 40 ppm @ 8% O2 1.02 ppm @8% O2 (2007) 

Lime Kiln 40 ppm @ 10% O2 31.3 ppm @10% O2 (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 equipment (constructed after July 1, 1972). For 

gaseous fuels, the limit is 0.2 lbs/MMbtu heat input; for liquid fuels, the limit is 0.8 lb/MMBTU; 

and for solid fuels, the limit is 1.2 lb/MMBTU. The permitted SO2 emission rates are much 

more stringent than Subchapter 31 limits. 

Part 5, Section 27 addresses sulfur oxide emission limits from 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 currently 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 rated 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 well 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 NO2

OAC 252:100-35 (Carbon Monoxide) [Not Applicable] 

None of the following affected processes are part of this project: gray iron cupola, blast furnace, 

basic oxygen furnace, petroleum catalytic reforming unit or petroleum catalytic cracking unit. 

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

Part 3 requires storage tanks constructed after December 28, 1974, with 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 organic vapor recovery system. This affects the 

gasoline storage tank, but all other tanks have vapor pressures below the 1.5 psia threshold. 

Part 5 limits the VOC content of coating or other operations. This facility does not normally 

conduct coating or painting operations except for routine maintenance of the facility and 

equipment which is exempt. 

Part 7 affects effluent water separators. This requirement affects only processing of organic 

materials with a vapor pressure above 1.5 psia. Therefore, this requirement is not applicable. 

Part 7 also requires all reciprocating pumps and compressors to be equipped with packing glands 

that are properly installed and maintained in good working order. The equipment at this location 

is subject to this requirement. 

Part 7 also requires fuel-burning 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 location 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 work practice, material substitution, or control equipment required 

by the Department prior to June 11, 2004, to control 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 requirements 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 Oklahoma to install, maintain and 

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant 

source. All required testing must be conducted by methods approved by the Air Quality Director 

and under the direction of qualified personnel. A notice-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 federal 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 conducted 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 relevant 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 Facilities not in source category 

OAC 252:100-11 Alternative Emissions 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 Elevators not in source category 

OAC 252:100-39 Nonattainment Areas not in source category 

OAC 252:100-47 Landfills not in source category 

SECTION IX. FEDERAL REGULATIONS 

Protection of Visibility, 40 CFR 51 Subpart P [Applicable] 

The primary purposes of this subpart are to require 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 mandatory Class I Federal areas which impairment 

results from manmade air pollution; and to establish necessary additional procedures for new 

source permit applicants, States and Federal Land Managers to use in conducting the visibility 

impact analysis required for new sources under §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 which 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 requirements for regional haze visibility impairment. Valiant 

must either submit a BART review or a demonstration that the BART-eligible sources do not 
PERMIT MEMORANDUM 97-057-TV (M-10) - 43 - 

cause or contribute to any impairment of visibility in any mandatory Class I Federal area. As 

indicated in Section VI., Valiant proposed to take enforceable limits, such that, they would not 

cause or contribute to any impairment of visibility in any mandatory Class I Federal area. 

Requirements to comply within 5 years of SIP 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 will not cause or contribute to a violation of a 

NAAQS, PSD increment, or adversely affect visibility 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, SO2, PM10, and VOC. Any future increases must be 

evaluated in the context of PSD significance levels: 40 TPY NOx, 100 TPY CO, 40 TPY SO2, 15 

TPY PM10, 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 appropriate notifications are required. 

Subpart D (Steam Generating Units) affects boilers with a rated heat input greater than 250 

MMBTUH which commenced construction, reconstruction, or modification after August 17, 

1971. This subpart affects the Bark Boiler, specifying emissions limitations of 0.8 lb/MMBTU 

SO2, 0.10 lb/MMBTU PM, and 0.3 lb/MMBTU NOx. CEMS systems measuring opacity, NOx, 

SO2, and a diluent gas (CO2 or O2) 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 Db, but the facility has 

requested an enforceable condition limiting natural gas firing to a 10% annual capacity factor 

Subpart Kb (Volatile Organic Materials Storage Vessels) affects tanks with a capacity above 

19,813 gallons which commenced construction, reconstruction, or modification after July 23, 

1984. The facility records of tank dimensions, capacity, and maximum true vapor pressure show 

that vessels storing organic liquids have true vapor pressures below 0.5. Here, the storage 

temperature of black liquor is relatively constant since the process generating the black liquor is 

kept at a relatively constant temperature. Both distillate and residual fuel oils have vapor 

pressures below 0.01 psia at 60o

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 equipment (including breakers and crushers), coal 

storage systems, and coal transfer and loading systems at any coal preparation plant that 

commences construction or modification after October 24, 1974. The Valliant Mill is not 

considered a coal preparation plant, as it does not operate any of the processes 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 digester system, brown stock washer system, 

multiple-effect evaporator, recovery furnace, smelt 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 concentrator were modified after the effective date, therefore they are 

subject to NSPS Subpart BB. No add-on controls were required for the No. 2 brownstock 

washer direct emissions. The Lime Kiln and the NCG Thermal Oxidizer are pollution control 
PERMIT 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 reduced 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 1,200o

F. The applicant will maintain compliance with NSPS Subpart 

BB by continuously monitoring the control device combustion temperature and using 

engineering calculations to determine 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 Furnace 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 stationary compression ignition (CI) internal 

combustion engines (ICE) based on power and displacement ratings, depending on date of 

construction, beginning with those constructed 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 facility is not currently subject to this subpart, but shall comply with the 

provisions of Subpart IIII if they install 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 operator. 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 wastewater treatment sludge incineration, limiting 

mercury emissions to 3,200 grams per 24-hour period. 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. The provisions of these 

subparts apply to a major source that uses the following processes and materials: 

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

2. Mechanical pulping processes 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 published in the Federal Register on April 15, 1998. 

These standards will affect knotter systems (wood knot removal systems), pulp screens, pulp 

washing systems, decker systems, digester vents, evaporator system vents, 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. These units are currently vented to the NCG 

collection system and combusted. The pulp washing 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 Brownstock washer (semi-chemical process), 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 control of HAPs from chemical recovery 

combustion sources which were finalized and published in the Federal Register on 

January 12, 2001. These standards affect recovery furnaces, smelt dissolving tanks, and lime 

kilns. 

Subpart DDDDD, Industrial Boilers and Process Heaters. Subpart DDDDD regulated HAP 

emissions from industrial boilers and process heaters. 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 vacated on July 30, 2007. 

Existing and new small gaseous fuel boilers and 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 determinations under either Section112(g) or Section 

112(j) for sources that were affected sources under Subpart DDDDD and other 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 potentially 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 published 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 regulated air pollutant. 

• It uses a control device to achieve compliance with 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 scrubber 
PERMIT 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 applicable threshold limits. More 

information on this federal program is available 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 not sell electricity back to the grid. If the mill elects in the 

future to sell more than 25 MW of electricity back 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, reductions of emissions of Class I 

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential 

products containing ozone-depleting substances (Subparts A & C); control servicing of motor 

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations 

which meet phase out requirements and which maximize the substitution of safe alternatives to 

Class I and Class II substances (Subpart D); require 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 ozone-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 seven groups; the chemicals typically used by the 

manufacturing industry include carbon tetrachloride (Class I, Group 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 chloroform). 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/fire 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, Environmental Programs Specialist for the Department of Environmental 

Quality (DEQ), Air Quality Division, of the Regional Office at Tulsa conducted the 

unannounced onsite evaluation. Ms. Kathryn Crenwelge, EH&S Manager and Mr. Brad Burris, 

Senior Environmental Engineer with International Paper (IP) represented the company during the 

evaluation. The Valliant Paper Mill was evaluated to determine 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 inspection can be found in the 
PERMIT 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 

SO2: 0.8 lb/MMBTU SO2: 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% O2 TRS: 1.02 ppm @ 8% O2 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% O2 TRS: 31.3 ppm @ 10% O2 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 

SO2: 41.5 lb/hr SO2: 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% O2 TRS: 0.70 ppm at 10% O2 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, Oklahoma. The notice stated that the application 

and permit are available for review by the public for 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; both states were notified of the draft permit. 

No comments were received from the public the state 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 their knowledge. The affidavit 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 which has been included in this permit action. 

SECTION XI. SUMMARY 

The facility is constructed and operated as presented in the permit application and follow up 

submittals. Ambient air quality standards are not threatened at this site. There is no active Air 

Quality compliance or enforcement issues concerning 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, January 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 requirements and estimates of emissions; 

however, it does not contain limitations or permit requirements. Continuing operations under 

this permit constitutes acceptance of, and consent to the conditions contained herein: 

I. Equipment and Applicable Requirements 

A. EUG FW – Facility-Wide 

1. The permittee is authorized to operate the 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 Numbers 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 qualify 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 Alternative Compliance Plan Submitted on 

January 18, 2006, as approved by ODEQ 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 methods described in OAC 252:100-5-2.1(d). 

9. During certain start-up operations and upset conditions, the NCG streams 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 point 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 Valliant Mill fiscal calendar month. 

Table X provides specific Federal Regulatory 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 emissions 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 comply with the following regulations: 

a. Federal NESHAP for Source Categories, 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 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 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. 2 Digester System shall comply with the following regulations: 

a. Federal NESHAP for Source Categories, 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 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 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. 3 Digester System shall comply with the following regulations: 

a. Federal NESHAP for Source Categories, 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 VOCA

lb/hr B TPY C

E-A4, C No. 1 OCC Plant 

A5 No. 2 OCC Plant 25.06 99.6 

A7 No. 3 OCC Plant A VOC emissions limitations expressed as methanol. B

 Valliant Mill fiscal month basis, and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

 

2. Compliance with Specific Condition I-E-1 shall 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-1972 
SPECIFIC 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 PM10

lb/hrB TPYC

A8 OCC Lightweight Rejects Baghouse 0.46 1.9 B

 Valliant Mill fiscal month basis, and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

 

2. Compliance with Specific Condition I-G-1 shall be demonstrated monthly based on 

 operating rates and Valliant Mill specific emission factors. [OAC 252-100-43] 

3. Air exhausts from the Bark Boiler Surge Bin shall be processed by a baghouse or 

equivalent PM10 emissions control device which achieves discharge concentrations of 

0.00437 gr/dscf or less PM10 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 limitations expressed as 80% a-pinene/20% methanol. B

 Valliant Mill fiscal month basis, and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month.

2. Compliance with Specific Condition I-H-1 shall 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 Categories, 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 VOCA TRS

lb/hrB TPYC lb/hrB TPYC

B2,A 

B2,B 

1st Stage Brownstock Washer 19.19 77.58 1.08 4.38 2nd

 Stage Brownstock Washer A VOC emissions limitations expressed as 80% a-pinene/20% methanol. B

 Valliant Mill fiscal month basis, and hours of operation. C 12-month rolling total based on Valliant 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 shall comply with the following regulations: 

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

b. Federal NESHAP for Source Categories, 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 VOCA TRS

lb/hrB TPYC lb/hrB TPYC

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 limitations expressed as 80% a-pinene/20% methanol. B

 Valliant Mill fiscal month basis, and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month.

. 

2. Compliance with Specific Condition I.-J.-1 shall 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 following emission limits be established. 

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

Emission Point EU Name/Model PM/PM10 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 

Vacuum Pumps/ Vacuum Flume 3.6 13.14 310.64 1,133.81 

Press Section 

Dryer Section 

A VOC emissions limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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/PM10 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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

2. Compliance with Specific Condition I.-L.-1 shall 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/PM10 VOC A

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

C7 E-C8,A Stock Preparation 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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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 / PM10 CO SO2 NOx

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 H2SO4

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 limitations expressed as propane. B

 Valliant Mill fiscal month basis and hours of operation. 

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

a. The permittee shall demonstrate compliance with the emission limits 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 PM10, 

CO, VOC, and Lead. 

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

data records to demonstrate compliance with the emission limits listed above for 

SO2 and NOx. 

b. The permittee shall not fire greater than 3.8 TPH, dry basis, 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 requirements. [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 PM10/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 control 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 PM10/MMBtu limit. Operation of the wet scrubber on exhaust 

shall not be required when natural gas is the only fuel being burned. 

 [OAC 252:100-8 Part 7] 

iii. Continuous monitoring of opacity from the Bark Boiler shall not be required. 

[40 CFR 60.13(i) and OAC 252:100-8 Part 7] 

b. The permittee shall not emit in excess of 0.80 lb SO2/MMBtu heat input from the 

Bark Boiler. [40 CFR 60.43 and OAC 252:100-8 Part 7] 

c. The permittee shall not emit in excess of 0.30 lb NOx (expressed as NO2)/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 compliance 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 SO2 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, and 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 with 40 CFR 61.55 at least 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 Source Categories, 40 CFR 63, Subpart S. When 

used in this capacity, the Bark Boiler shall comply with all applicable requirements, 

including but not limited to the requirements of Subpart BB. [40 CFR 63, Subpart 

S] 

5. Fuels include but are not limited to wood residues, OCC rejects, wastewater treatment 

sludge, fuel oil, coal and natural gas. Oil from mill equipment (including small 
SPECIFIC 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 listed 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 SO2 NOX PM\PMIO

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 SO2 NOX PM\PMIO

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 SO2 NOX PM\PMIO

lbs/hr lbs/hr lbs/hr 

 DI Bark Boiler 135.00 270.00 90.00 

a. The listed limits apply while the units are combusting 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 submit any permit modification request as determined to be 

applicable as a result of proposed changes. 

c. For determining compliance with the emission average, a “boiler operating 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 / PM10 CO SO2 NOx

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 H2SO4

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 limitations expressed as propane. B

 Valliant Mill fiscal 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 SO2 emission rate shall be calculated from the recorded sulfur weight 

percent and density of each 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 twice a month (for a 

period of up to 30 minutes each) during soot blowing activities, allowing the boiler to 

operate more efficiently. All excess emissions 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 listed 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 SO2 NOX PM\PMIO

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 SO2 NOX PM\PMIO

lbs/hr lbs/hr lbs/hr 

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

- 

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

Point 

ID Source Name SO2 NOX PM\PMIO

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 submit any permit modification request as determined to be 

applicable as a result of proposed changes. 

c. For determining compliance with the emission average, a “boiler operating 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 

PM10 CO SO2 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 limitations expressed as propane. B

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

 12-month rolling total based on Valliant 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 pipeline grade natural gas or other gaseous fuel 

with sulfur content less than 343 ppmv. Compliance can be shown by the following 

methods: for pipeline grade natural gas, a current gas company bill; for other gaseous 

fuel, a current lab analysis, stain-tube analysis, 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 / PM10 CO SO2 NOx

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 H2SO4

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 limitations expressed as propane. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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 emission 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 from 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 comply 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 MM 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 13 

- 

EUG D2& D6 Summary 

1. The Power Boiler and Recovery Furnace shall 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 H2SO4

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 average 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 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 sources or otherwise 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 Categories, 40 CFR 63, Subpart S. 

R. EUG E2a – Spent Liquor Concentration 

1. NCG’s from the Spent Liquor Concentration 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 emissions 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 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 Categories, 40 CFR 63, Subpart S 
SPECIFIC 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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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 following units [OAC 252:100-8-6(a)(1)] 

The Spent Liquor Mix Tanks vent through the New Recovery Furnace. 

P. EUG E4b – Smelt Dissolving Tank (New) 

1. The Smelt Dissolving Tank includes the following 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 Categories, 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 the lime shakers. [OAC 252:100-8-6(a)(1)] 

Emission 

Point EU Name/Model PM / PM10 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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

2. Compliance with Specific Conditions I.-W.-1 shall be demonstrated monthly based on 

Valliant Mill fiscal calendar month operating 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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation.. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

2. Compliance with Specific Condition I.-X.-1 shall 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 with the following emission limits. 

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

Emission 

Point 

EU Name/ 

Model 

PM / PM10 CO SO2 NOx

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 H2SO4

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 limitations expressed as propane. B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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 Categories, 40 CFR 63, Subpart MM. 

c. Federal NSPS, 40 CFR 60, Subpart BBand 

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

4. Compliance with OAC 252:100, Subchapter 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 applicable 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 destruction 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 applicable requirements. [40 CFR 63, Subpart S] 

7. The SO2, TRS, and NOx emission limitations in Specific 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 (NCGs) 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 

- 

T. EUG E8 – Tall Oil Plant 

1. The following emission limits apply to the tall oil plant. [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

Main Stack Tall Oil Plant 84.56 370.39 0.36 1.56 

A VOC emissions limitations expressed as methanol B

 Valliant Mill fiscal month basis and hours of operation. C 12-month rolling total based on Valliant 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 PM10 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 fiscal month basis and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

2 Compliance with Specific Conditions I.-AA.-1 shall be demonstrated monthly based 

on Valliant Mill fiscal calendar month operating 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 comply with the following emission limits. 

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

Emission 

Point 

EU Name/Model VOC A TRS (as H2S) H2S 

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 limitations expressed as methanol. B

 Valliant Mill fiscal month basis and hours of operation. C

 12-month rolling total based on Valliant Mill fiscal calendar month 

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

based on Valliant Mill fiscal calendar month operating rate records and emission 

factors. [OAC 252-100-43]
SPECIFIC CONDITIONS 97-057-TV (M-10) - 18 

- 

3. At least three times per week, the dissolved oxygen content shall be measured at the 

discharge end of the pipeline 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 consecutive 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 Thermal Oxidation System – LVHC 

 EUG F4b – NCG Collection and Thermal Oxidation System – HVLC 

1. NCG’s from the NCG LVHC and HVLC Collection 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 annual emissions from 

the NCG Thermal Oxidizer and Recovery Furnace shall not exceed the annual 

emission limits specified in Specific Conditions I.Q.1. The Thermal Oxidizer 

lb/hr emissions shall not exceed previously 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 Oxidation System are subject to the following 

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

Emission 

Point 

EU Name/ 

Model 

PM / PM10 CO SO2 NOx

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 limitations expressed as propane. B

 Valliant Mill fiscal month basis and hours of operation.

4. The permittee shall demonstrate compliance with the emission limits listed in I.-

CC.-3 as follows: [OAC 252-100-43] 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 19 

- 

a. Limits shall be demonstrated monthly based on Valliant Mill fiscal calendar 

month operating rate records and emission factors. 

b. The permittee, at its option, may determine compliance with the SO2

emission rates by installing and operating 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 SO2

CEMS for the NCG Thermal Oxidizer, CEMS data records shall be used to 

demonstrate compliance with the emission limits listed above for SO2. 

5. Emissions from the NCG Thermal Oxidizer shall be processed by a caustic wet 

scrubber or equivalent system (90% control of SO2 emissions). The system shall 

maintain a minimum liquor pH of 8.0 and a minimum scrubber recirculation 

flow of 300 gpm, daily average. The 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 specified 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 the control of emissions as specified in 

federal NSPS, 40 CFR 60, Subpart BB, the NCG Thermal Oxidizer shall 

combust the gases at a minimum temperature 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 available to regulatory personnel upon request. 

9. When used as the control device for the control of emissions as specified in 

federal NESHAP for Source Categories, 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 

- 

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 PM10

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 month basis and hours of operation. B

 12-month rolling total based on Valliant Mill fiscal calendar month. 

2. Compliance with Specific Condition I.-DD.-1 shall be demonstrated monthly based 

on Valliant Mill fiscal calendar month operating 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 

PM10 CO SO2

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 fiscal month basis and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month. 

2. Compliance with specific condition I.-EE.-1 shall be demonstrated monthly based on 

Valliant Mill fiscal calendar month operating rate records 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 sulfur demonstrated 

annually (vendor analysis, Material Safety Data Sheets, etc). 

 [OAC 252:100-8-6(a)(1)] 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 21 

- 

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 PM10

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 fiscal month basis and hours of operation. C 12-month rolling total based on Valliant Mill fiscal calendar month.

2. Compliance with Specific Condition I.-FF.-1 shall be demonstrated monthly based on 

Valliant Mill fiscal calendar month operating rate records and emission factors. 

 [OAC 252-100-43] 

AA. EUG F10 - Steam Stripper System 

1. SOG’s from the Steam Stripper System shall be routed to the Recovery Furnace, 

Lime Kiln, or Thermal Oxidizer for combustion.

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

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

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

II. Insignificant Activities 

BB. EUG E9 – Organic Liquid Storage Vessels 

1. The Organic Liquid Storage Vessels 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 1997 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 22 

- 

CC. EUG E10 – Small Volatile Organic 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 with a permanent submerged fill pipe or 

equipped with an organic material vapor-recovery system. [OAC 252:100-37-5(a)] 

DD. EUG F11- Miscellaneous Insignificant Activities 

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

be recorded. 

2. Units F11-3 and F11-4 are limited to 500 hours 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 recording and shall be provided 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 System, operating rate as a monthly basis 

(Condition I.-G.-2). 

3. The No. 1 Brownstock Washing Area, operating 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 House 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 23 

- 

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

I.-2). 

5. The No. 3 Brownstock Washing Area, operating 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 fuels fired in the Bark Boiler. The recorded amount of OCC 

rejects fired shall be on a dry basis (Condition I.-N.-1ai. & I.-N.-1b). 

10. CEMS readings of SO2 and NOx 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 pressure 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 Power Boiler (daily when done and cumulative 

annual total) (Condition I.-O.-1). 

15. Monthly average sulfur weight 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 the Package Boiler. (Condition I.-P.-2) and 

(Condition I.-P.-4). Annual sulfur content 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 operating) (Condition I.-Y). 

22. Lime Kiln combustion temperature continuously 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 (Condition I.-BB.-2 and Condition I.-BB-6) and 

weekly average ( Condition I.-BB-5). 

25. The pipeline discharge dissolved oxygen content 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 SO2 emissions from the NCG Thermal Oxidizer (continuous if the 

permittee chooses to install an SO2 CEMS). 

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

29. NCG Thermal Oxidizer operating temperature (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 Conditioning, operating rate as a monthly basis 

(Condition I.-FF.-2). 

32. Monthly and cumulative annual process throughput of the Wood Chip Screening and 

Conditioning Unit – No. 3 Line. 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 24 

- 

33. Monthly and cumulative annual process throughput of the Wood Chip Screening and 

Conditioning Unit – No. 1 Line. 

34. Sufficient records shall be maintained to demonstrate emissions that qualify as 

insignificant activities. 

35. Hours of operation of each stationary engine (monthly and 12-month rolling totals 

based on Valliant Mill fiscal month) (Condition I.-JJ.-2). 

36. Sulfur content of liquid fuels used in stationary 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, Subpart S, and record the information 

listed in 40 CFR 63.454(b) for each inspection. [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 requirements 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 monitoring 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 certification of compliance 

with the terms and conditions of this 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, the 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 

- 

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 certification 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 certification of compliance shall also contain 

a report of all required monitoring not reported since the last semi-annual monitoring 

report (October 17, 2010 to January 1, 2011). 

After January 1, 2011, no later than 30 days after each anniversary 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 certification of compliance with the terms and conditions of this 

permit. 

After January 1, 2011, no later than 30 days after 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 semi-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 Citations 25

EUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Met

Pro

FW Part 82, Subpart B, F 

& H 

Facility-Wide 

A1 

Subpart S 

No. 1 Digester System - Existing Kraft Digester 

63.443 and 63.446 and 

63.450 

63.453 63.454 63.455 6

A1 Subpart BB, 

Applicable but not triggered. 

No. 1 Digester System - Existing Kraft Digester 

None 

A2 

Subpart S 

No. 2 Digester System - Existing Kraft Digester 

63.443 and 63.446 and 

63.450 

63.453 63.454 63.455 6

A2 Subpart BB, 

Applicable but not triggered. 

No. 2 Digester System - Existing Kraft Digester 

None 

A3 

Subpart S 

No. 3 Digester System - Existing Semi-Chemical Digester 

63.443 and 

63.450 

63.453 63.454 Unit has no Subpart S li

utilization at the mill, nehappening with system. 

A3 Subpart BB, 

Applicable but not triggered. 

No. 3 Digester System - Existing Semi-Chemical Digester 

None 

A4, 

A5, & 

A7 

OCC Plants None 

 A6 Makedown Pulper None 

A8 OCC Lightweight 

Rejects Handling System 

None 

B1 

Subpart S 

No. 1 Brownstock Washing Area 

63.447 63.453 63.454 63.447 & 

63.455 

6
SPECIFIC CONDITIONS 97-057-TV (M-10) - 27 - 

Table X Continued

EUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Te

Meth

Proce

B1 Subpart BB, 

Applicable but not triggered. 

No. 1 Brownstock Washing Area 

None 

 B2 Subpart BB, No. 2 Brownstock 

Washing Area 

60.283 60.284 

B2 Subpart S No. 2 Brownstock 

Washing Area 

63.447 63.453 63.454 63.447 & 

63.455 

63.

B3 Subpart BB, 

Applicable but not triggered. 

No. 3 Brownstock Washing Area 

None 

B3 Subpart S No. 3 Brownstock 

Washing Area 

None – Clean 

Condensate 

Alternative 

63.453 63.454 

C1 No. 1 Paper 

Machine (Stock Prep) 

None 

C2 No. 1 Paper 

Machine (Wet End) 

None 

C3 No. 1 Paper 

Machine (Wet End) 

None 

C4 No. 2 Paper 

Machine (Stock Prep) 

None 

C5 No. 2 Paper 

Machine (Wet End) 

None 

C6 No. 2 Paper 

Machine (Dry End) 

None 

C7 No. 3 Paper 

Machine (Stock Prep) 

None 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 28 - 

Table X Continued

EUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Te

Meth

Proce

C8 No. 3 Paper 

Machine (Wet End) 

None 

C9 No. 3 Paper 

Machine (Dry End) 

None 

D1 Subpart S 

(Applicable when used as back-up control device, but not triggered) 

Bark Boiler None 

D1 Subpart D Bark Boiler 60.43 & 60.44 60.45 60.45 60D1 Subpart E Bark Boiler 61.52 61.54 & 61.55 61.534 61.54 D2 Power Boiler None D3 210 MMBtu/hr 

Package Boiler 

None 

D6 Subpart MM New Recovery Furnace 63.862 & 63.864 63.864 63.866 63.867 63.D6 Subpart S New Recovery Furnace 63.443 63.453 (m, n, & o) 40 CFR 63 S 40 CFR 63 S 40 CF

S 

D6 Subpart BB New Recovery Furnace 60.282 & 60.283 60.284 60.284 60.284 60.2

60.

D6 Subpart Db New Recovery Furnace 60.44 (e) 40 CFR 60 Db 60.49 (d,o,p) 60.49 (q) 40 CF

D

E1 Subpart S Turpentine Recovery System 63.443 & 63.450 63.453 63.454 63.455 63.E1 

Subpart BB 

Turpentine Recovery System 

60.283 see lime kiln & 

NCG thermal 

oxidizer 

E2a Subpart S Spent Liquor Concentration 63.443 & 63.450 63.453 63.454 63.455 63.E2a 

Subpart BB 

Spent Liquor Concentration 

60.283 see lime kiln & 

NCG thermal 

oxidizer 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 29 - 

Table X Continued

EUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Te

Meth

Proce

 E2b Evaporator Sewer 

Sump 

None 

E3d New Spent Liquor 

Mix Tanks 

None – Emissions routed to Recovery Furnace 

E4b Subpart MM New Smelt Dissolving Tank Applicable. However, no direct emissions from the SDT (except SSM/excess emissions). The SDT is vented to the recovery furnace. E4b Subpart BB, New Smelt Dissolving Tank Applicable. However, no direct emissions from the SDT (except SSM/excess emissions). The SDT is vented to the recovery furnace. 

E5 Lime Slakers None E6 Causticizing 

System 

None 

E7a Subpart MM Lime Kiln 63.862 & 63.864 63.864 63.866 63.867 63.E7a Subpart S (when 

used as a back-up control device) 

Lime Kiln 63.443 and 

63.450 

63.453 63.454 63.455 63.

E7a Subpart BB (when 

used as a back-up control device) – applicable – but not because of modification 

Lime Kiln 60.283 60.284 60.284 60.

E8 Tall Oil Plant None E9 Organic Liquid 

Storage Vessels 

None 
SPECIFIC CONDITIONS 97-057-TV (M-10) - 30 - 

Table X ContinuedEUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Me

Pro

E10 Small Volatile Organic 

Liquid Storage Tanks 

None 

 F1 Woodyard None  F2 FacilityTraffic None  F3 Wastewater Treatment 

System 

None 

 F4a Subpart S NCG Collection and 

Thermal Oxidation System – LVHC 

63.443 and 

63.450 

63.453 63.454 63.455 6

 F4a Subpart BB NCG Collection and 

Thermal Oxidation System – LVHC 

60.283 60.284 60.284 6

 F4b Subpart S NCG Collection and 

Thermal Oxidation System – HVLC 

63.443 and 

63.450 

63.453 63.454 63.455 6

 F4b Subpart BB NCG Collection and 

Thermal Oxidation System – HVLC 

60.283 60.284 60.284 6

 F5 Solid Waste Disposal 

Facility Operations 

None 

 F6 Diesel Stormwater 

Pump 

None 

F7 & 

F9 

 Chip Thickness 

Screening/Conditioning System 

None 

F10 Subpart S Steam Stripper System 63.443, 

63.446 and 

63.450 

63.453 63.454 63.455 6
SPECIFIC CONDITIONS 97-057-TV (M-10) - 31 - 

Table X Continued

EUG: Applicable Regs Unit 

Emission 

limitations: Monitoring: 

Recordkeeping 

Requirements: 

Reporting 

Requirements: 

Met

Pro

F10 Subpart BB (applic–

steam stripper prjt) 

Steam Stripper System 

60.283 see lime kiln & 

NCG thermal 

oxidizer 

Fll Misc. 

Insignificant Activities 

None 

 F13 Petcoke Silo Bin 

Vent No. 1 

None 
International Paper 

Attn: Kathryn Crenwelge 

890 IP Lane 

Valliant, Oklahoma 74764 

SUBJECT: Permit Number: 97-057-TV (M-10)

Facility: IP Valliant Paper Mill 

 Location: Secs. 26, 27, 28, 33 and 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 specific 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 inventory for this facility. An 

emissions inventory must be completed on approved AQD forms and submitted (hardcopy or 

electronically) by April 1st of every year. Any questions concerning the form or submittal 

process should be referred to the Emissions Inventory Staff 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 

Enclosure 

MAJOR 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. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112] 

B. The issuing Authority for the permit is the 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 Air Act, 27A O.S. § 2-5-112] 

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance 

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement 

action, permit termination, revocation and reissuance, or modification, or for denial of a permit 

renewal application. All terms and conditions 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). This permit is valid for operations only at the 

specific location listed. 

 [40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and 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 environmental impacts of halting or reducing operations 

would be more serious than the impacts of continuing operations. [OAC 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 environment shall be reported in accordance with Section 

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)] 

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported 

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. 

 [OAC 252:100-8-6(a)(3)(C)(iv)] 

C. Every written report submitted under this section shall be certified as required by Section III 

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F. 

 [OAC 252:100-8-6(a)(3)(C)(iv)] 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2 

SECTION III. MONITORING, TESTING, 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-site or at a nearby field 

office for a period of at least five years from the date of the monitoring sample, measurement, 

report, or application, and shall be made available for inspection by regulatory personnel upon 

request. Support information includes all original strip-chart recordings for continuous 

monitoring instrumentation, and copies of all reports required by this permit. 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 techniques or methods used; 

(5) the results of such analyses; and 

(6) the operating conditions existing at the 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 requirements since the previous 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 Section II (Reporting Of Deviations From Permit 

Terms) of these standard conditions. [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 required under the provisions of OAC 252:100-43, 

Testing, Monitoring, and Recordkeeping, or as required by any provision 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 Inventory submitted in accordance with this 

permit shall be certified by a responsible official. This certification shall be signed by a 

responsible official, and shall contain the following language: “I certify, based on information 

and belief formed after reasonable inquiry, the statements 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 subject to the provisions of New Source Performance Standards 

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 3 

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other 

information required by the applicable general provisions and subpart(s). These records shall be 

maintained in a permanent file suitable for inspection, shall be retained for a period of at least 

five years as required by Paragraph A of this Section, and shall include records of the occurrence 

and duration of any start-up, shutdown, or malfunction in the operation 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-annually. 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 compliance was achieved. The 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 shall 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 manufacturer’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 emissions as required in Part 7 of OAC 252:100-8 

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and 

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing 

or calculation procedures, modified to include back-half condensables, for the concentration of 

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only 

particulate matter emissions caught in the filter (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. COMPLIANCE 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 specifically 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 effective since the issuance of this permit. 

 [OAC 252:100-8-6(c)(5)(A), and (D)] 

B. The compliance certification shall describe the operating permit term or condition that is the 

basis of the certification; the current compliance status; whether compliance was continuous or 

intermittent; the methods used for determining compliance, currently and over the reporting 
MAJOR 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 the compliance status of the source. 

 [OAC 252:100-8-6(c)(5)(C)(i)-(v)] 

C. The compliance certification shall contain a certification by a responsible official as to the 

results of the required monitoring. This certification shall be signed by a responsible official, 

and shall contain the following language: “I certify, based on information and belief formed 

after reasonable inquiry, the statements and information 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 compliance with all applicable requirements. This 

schedule shall include a schedule of remedial measures, including an enforceable sequence of 

actions with milestones, leading to compliance with 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, except 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 facility. Compliance with all new requirements shall 

be certified in the next annual certification. [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 listed in the Standard Conditions and the Specific 

Conditions of this permit. Those requirements that the applicant requested be determined as not 

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)] 

SECTION VII. ANNUAL EMISSIONS 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 available 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, the term of an operating permit shall 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 expiration of its permit unless a timely 

and complete renewal application has been submitted 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 provided 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 shall apply for a permit to operate (or modified 

operating permit) within 180 days following the first 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 permit, or the application 

of any provision of this permit to any circumstance, is held invalid, the application of such 

provision to other circumstances, and 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 property rights of any sort, or any exclusive privilege. 

 [OAC 252:100-8-6(a)(7)(D)] 

B. This permit shall not be considered in any manner affecting the title of the premises upon 

which the equipment is located and does not release the permittee from any liability for damage 

to persons or property caused by or resulting from the maintenance 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 receipt of a written request and within sixty 

(60) days of the request unless the DEQ specifies another time period, any information that the 

DEQ may request to determine whether cause exists for modifying, reopening, revoking, 

reissuing, terminating the 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 shall be clearly labeled 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 facility is required and 

shall be made in writing within thirty (30) days after such sale or transfer. 

 [Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)] 

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened 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, termination, 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 Act 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 effective 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 inaccurate information was used in establishing the 

emission standards, limitations, or other conditions 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 changes other than those described in Section 

XVIII (Operational Flexibility), those qualifying for 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 changes 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 that exceed the trivial/insignificant levels and that 

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)] 

SECTION XIII. INSPECTION & ENTRY 

A. Upon presentation of credentials and other documents as may be required by law, the 

permittee shall allow authorized regulatory officials to perform the following (subject to the 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 7 

permittee's right to seek confidential 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 pollution 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 compliance 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 after the permittee first becomes aware of the 

exceedance. This notice shall contain a description of the emergency, the probable cause of the 

exceedance, any steps taken to mitigate emissions, and corrective actions taken. 

 [OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)] 

B. Any exceedance that poses an imminent and substantial 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 arising 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 operation, 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 emergency 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 shall be demonstrated through properly signed, 

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)] 

(1) an emergency occurred and the permittee can 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 emission 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 under this section shall be certified as required 

by Section III (Monitoring, 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 Section 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 either on the list in Appendix I to OAC Title 252, 

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. 

Any activity to which a State or Federal applicable 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 pollutant (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 emissions 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. OPERATIONAL 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, the permittee shall record in a log at the facility 

the scenario under which it is operating. [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 emission rate of any existing emissions unit 

to be exceeded; 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 9 

provided that the facility provides the EPA and the DEQ with written notification as required 

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or 

twenty four (24) hours for emergencies as defined 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 required above shall include a brief 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 longer applicable as a result of the change. The 

permit shield provided by this permit does not apply 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 more restrictive requirement: 

(1) Open burning of refuse and other combustible material is prohibited except as authorized 

in the specific examples and under the conditions listed in the Open Burning Subchapter. 

 [OAC 252:100-13] 

(2) No particulate emissions from any fuel-burning equipment with a rated 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 opacity 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 such periods in any consecutive 24 hours. 

In no case shall the average of any six-minute period exceed 60% opacity; 

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7; 

(c) An emission, where the presence of uncombined 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 and immediate control of the facility and 

the immediate constriction of the fuel flow at the facility 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 standards to be exceeded, or interfere with the 

maintenance of air quality standards. [OAC 252:100-29] 

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur 

dioxide. [OAC 252:100-31] 

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and 

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia 
MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 10 

or greater under actual conditions shall be equipped 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 following standards for production and consumption of 

ozone-depleting substances: [40 CFR 82, Subpart A] 

(1) Persons producing, importing, or placing an order for production or importation 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, trichloroethane (methyl chloroform), and bromomethane 

(Methyl Bromide). Class II substances (listed 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 refrigerant (or regulated substitute substance) in the motor vehicle air 

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term 

“motor vehicle” as used in Subpart 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 refrigerated cargo, or the system used on passenger 

buses using HCFC-22 refrigerant. [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, service, repair, or disposal must comply 

with the required practices pursuant to § 82.156; 

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must 

comply with the standards for recycling and recovery equipment pursuant to § 82.158; 

(3) Persons performing maintenance, service, repair, or disposal of appliances must be 

certified by an approved technician certification program pursuant to § 82.161; 

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply 

with record-keeping requirements pursuant to § 82.166; 

(5) Persons owning commercial or industrial process refrigeration equipment must comply 

with leak repair requirements 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 associated with permit review 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 process 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 State, 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 provided 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 the 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 administrative permit amendment if performance tests fail 

to demonstrate that the source is operating 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 certifications or establishing whether or not a person 

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing 
MAJOR 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 would have been in compliance with applicable requirements if the 

appropriate performance or compliance test or procedure had been performed. 

 [OAC 252:100-43-6]