Douglas W. Domenech 

Secretary of Natural Resources 

COMMONWEALTH a/VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Street address: 629 East Main Street, Richmond, Virginia 23219 

Mailing address: P.O. Box 1105, Richmond, Virginia 23218 

TDD (804) 6984021 

www.deq.virginia.gov 

MAY 06 Z011 

Ms. Diana Esher, Director 

Air Protection Division (3APOO) 

U.S. Environmental Protection Agency, Region III 

1650 Arch Street 

Philade1phia, Pennsylvania 19103-2029 

David K. Paylor 

Director 

(804) 698-4000 

1-800-592-5482 

Reference: SIP Revision for 

MeadWestvaco Packaging 

Resource Group 

Dear Ms. Esher: 

Pursuant to the requirements of § 110 of the Clean Air Act, we are officially requesting 

approval of a revision to the Commonwealth of Virginia State Implementation Plan (SIP) 

approved on May 4, 2011 under the authority of § 10.1-1185 ofthe Code of Virginia and 

submitted in accordance with the requirements of 40 CFR Part 51 (Requirements for Preparation, 

Adoption, and Submittal ofImplementation Plans). The plan revision is effective upon the date 

of this letter. 

The revision consists of a permit for the control of visibility-impairing emissions from 

MeadWestvaco Packaging Resource Group located in Alleghany County, Virginia for the 

purposes of reasonable progress goals as required by 40 CFR 51.308( d). 

Enclosed are the following: 

1. SIP Revision, including the following: 

A. Federally enforceable state operating pennit. 

B. Statement of basis, including federal land manager comment. 
2. Public participation certification. 

3. Summary of testimony and responses thereto. 

4. An electronic copy of the complete submittal. This electronic copy is an exact 

duplicate of the hard copy. 

If you have any questions or need additional information, please let us know. 

DKP\kgs 

TEM:PLATES\SOURCE-SPECIFIC\PLNOO 

SRCESPEC\MEADWESTV AC02\MW2-SIP.DOC 

Enclosures 
ENCLOSURE 1

COMMONWEALTH OF VIRGINIA

STATE IMPLEMENTATION PLAN REVISION

FOR

IMPLEMENTATION OF

REASONABLE PROGRESS

STATE OPERATING PERMIT

FOR

MeadWestvaco Corporation

Packaging Resources Group

Section 110 of the federal Clean Air Act prescribes the requirements for the contents, 

adoption and submittal of the state implementation plan (SIP). Section 110(a)(2)(D)(i)(II) 

requires that the plan contain adequate provisions prohibiting emissions in amounts which 

will interfere with measures required to be included in the plan to prevent significant 

deterioration of air quality or to protect visibility.

Part C (Prevention of Significant Deterioration of Air Quality) of § 160 establishes the 

purposes of the part as follows:

(1) to protect public health and welfare from any actual or potential adverse effect which in the 

Administrator's judgment may reasonably be anticipated to occur from air pollution or from exposures 

to pollutants in other media, which pollutants originate as emissions to the ambient air, 

notwithstanding attainment and maintenance of all national ambient air quality standards;

(2) to preserve, protect and enhance the air quality in national parks, national wilderness areas, 

national monuments, national seashores, and other areas of special national or regional natural, 

recreational, scenic or historical value;

(3) to insure that economic growth will occur in a manner consistent with the preservation of existing 

clean air resources;

(4) to assure that emissions from any source in any state will not interfere with any portion of the 

applicable implementation plan to prevent significant deterioration of air quality for any other state; 

and

(5) to assure that any decision to permit increased air pollution in any area to which this section 

applies is made only after careful evaluation of all the consequences of such a decision and after 

adequate procedural opportunities for informed public participation in the decision making process.

Section 165 addresses the preconstruction requirements for major sources to be built in 

areas classified as PSD areas (federal class I areas). Section 165(b)(2) addresses the 

responsibility of the federal land manager that has authority over federal class I areas:

The Federal Land Manager and the Federal official charged with direct responsibility for 

management of such lands shall have an affirmative responsibility to protect the air quality related 

values (including visibility) of any such lands within a class I area and to consider, in consultation with 

the Administrator, whether a proposed major emitting facility will have an adverse impact on such 

values. . . . In cases where the Federal Land Manager demonstrates to the satisfaction of the state 
that the emissions from such facility will have an adverse impact on the air quality related values 

(including visibility) . . . a permit shall not be issued.

Section 169(A) addresses visibility protection for federal class I areas:

Congress hereby declares as a national goal the prevention of any future, and the remedying of any 

existing, impairment of visibility in mandatory class I Federal areas which impairment results from 

manmade air pollution.

This section also provides timeframes by which the Secretary of the Interior and the 

Administrator will interact to assess visibility, develop federal regulations including specific 

source exemptions and public participation and the promulgation of those regulations.

Section 169(B) addresses the need for studies and assessment of current sources of 

visibility, impacts of other provisions, establishment of visibility transport regions and 

commissions, duties of the Administrator and the establishment of the Grand Canyon 

Visibility Transport Commission.

40 CFR 51.166, SIPs for new source review and source modifications, requires that the 

plans (in accordance with the policy of §101(b)(1) and the purpose of §160 contain 

emission limitations and such other measures as may be necessary to prevent significant 

deterioration of air quality.

Visibility is specifically addressed in 40 CFR 51.166(o), additional impact analysis:

(1) The owner or operator shall provide an analysis of the impairment to visibility, soils, and 

vegetation that would occur as a result of the source or modification and general commercial, 

residential, industrial, and other growth associated with the source or modification....

40 CFR 51.166(p) addresses sources affecting federal class I areas-additional 

requirements.

(p)(2) The Federal Land Manager and the Federal official charged with direct responsibility for 

management of Class I lands have an affirmative responsibility to protect the air quality related 

values (including visibility) of any such lands and to consider, in consultation with the with the 

Administrator, whether a proposed source or modification would have an adverse impact on such 

values.

On July 1, 1999, EPA published a final rule to address regional haze (64 FR 35714). 

The regional haze rule requires states to submit SIPs to address regional haze visibility 

impairment in federally protected parks and wilderness areas, which are known as 

“mandatory Class I federal areas” or “Class I areas.” The 1999 rule was issued to fulfill 

the requirements of §§169A and 169B. In this rule, EPA included a requirement for 

BART for certain large stationary sources that were put in place between 1962 and 

1977. The regulatory requirements for BART were codified at 40 CFR 51.308(e) and in 

definitions that appear in 40 CFR 51.301.

Sections 169A(b)(2)(A) and 169A(g)(7) use the term “major stationary source” to 
describe those sources that are the focus of the BART requirement. To avoid confusion 

with other requirements which also use the term “major stationary source,” the regional 

haze rule uses the term “BART-eligible source.” BART-eligible sources (i) have the 

potential to emit 250 tons or more of a visibility-impairing air pollutant, (ii) were in place 

between August 7, 1962 and August 7, 1977, and (iii) have operations that fall within 

one or more of 26 listed source categories. BART is required for any BART-eligible 

source which a state determines “emits any air pollutant which may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any such area.” 

Accordingly, for stationary sources meeting these criteria, states must address the 

BART requirement when developing regional haze SIPs.

Section 169A(g)(7) requires that states consider the following factors in making BART 

determinations: (i) the costs of compliance, (ii) the energy and nonair quality 

environmental impacts of compliance, (iii) any existing pollution control technology in 

use at the source, (iv) the remaining useful life of the source, and (v) the degree of 

improvement in visibility which may reasonably be anticipated to result from the use of 

such technology. These statutory factors for BART were codified at 40 CFR 

51.308(e)(1)(ii).

In response to various legal challenges, the D.C. Circuit Court issued a ruling in 2002 

striking down the regional haze rule in part and upholding it in part. On July 6, 2005 (70 

FR 39103), EPA promulgated final regulations to address the court’s decisions (40 CFR 

51.302 and 51.308), and to provide BART determination guidance (Appendix Y to 40 

CFR Part 51). The purpose of the guidelines is to assist states as they identify which of 

their BART-eligible sources should undergo a BART analysis, and select controls in 

light of the statutory factors (the BART determination).

MeadWestvaco Corporation Packaging Resources Group (Meadwestvaco), located in 

Alleghany County, Virginia, has been identified as a source subject to the BART 

requirements. A legally enforceable mechanism (federally enforceable state operating 

permit) was drafted to ensure compliance with the BART requirements. 

MeadWestvaco's BART permit was issued on February 23, 2009 to control the following 

visibility impairing pollutants: nitrogen oxides (NOX), particulate matter (PM10), and sulfur 

dioxide (SO2).

In addition to requiring implementation of BART, EPA's regional haze requirements at 

40 CFR 51.308(d)(1) require that state plans for the control of regional haze address 

"reasonable progress goals." As a part of the reasonable progress process, DEQ 

determined the potential for the MeadWestvaco facility's SO2 emissions to have an 

impact on reasonable progress goals, and requested further evaluation of certain

emission units. In response, the company determined that an additional 15% SO2

reduction could be achieved from the current BART SO2 limit. In order to implement the 

new reduction requirement, DEQ issued MeadWestvaco a state operating permit, which

is included as Attachment A. Attachment B presents the engineering analysis to 

support the terms and conditions of the permit, including the determination and analysis 

to support the reasonable progress determination for the control of the specific visibility-
impairing pollutant (SO2) from the facility. The permit is being issued pursuant to Article 

52 (9VAC5-40-7550 et seq.) of 9VAC5-40 (Existing Stationary Sources) and Article 5 

(9VAC5-80-800 et seq.) of 9VAC5-80 (Permits for Stationary Sources) of state 

regulations and is federally enforceable upon issuance.

TEMPLATES\SOURCE-SPECIFIC\PLN01

SRCESPEC\MEADWESTVACO 2\MW2-SIP-1.DOC
ATTACHMENT A

LEGALLY ENFORCEABLE MECHANISM (PERMIT)

TO ENSURE COMPLIANCE WITH REASONABLE PROGRESS REQUIREMENTS

FOR

MeadWestvaco Corporation

Packaging Resources Group

Alleghany County, Virginia

Registration No. 20328

Under the authority provided in 9VAC5-170-180 and Section II of Agency Policy 

Statement No. 3-2006 (dated October 20, 2006), the Director of the Blue Ridge

Regional Office approved and issued the permit on May 4, 2011, to be effective that 

same day. The permit was approved and issued following the procedural requirements 

of Virginia's federally enforceable state operating permit program, Article 5 (9VAC5-80-

800 et seq.) of Part II of 9 VAC 5-80 (Permits for Stationary Sources). 
Douglas W. Domenech 

Secretary of Natural Resources 

Lynchburg Office 

7705 Timberlake Road 

Lynchburg, Virginia 24502 

(434) 582-5120 

Fax (434) 582-5125 

COMMONWEALTH of VIRGINIA 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Blue Ridge Regional Office 

www.deq.virginia.gov 

STATE OPERATING PERMIT 

STATIONARY SOURCE PERMIT TO OPERATE 

David K. Paylor 

Director 

Robert J. Weld 

Regional Director 

Roanoke Office 

3019 Peters Creek Road 

Roanoke, Virginia 24019 

(540) 562-6700 

Fax (540) 562-6725 

This permit implements the requirements for Reasonable Progress Goals. 

This pennit (i) is for the purpose of implementing the reasonable progress requirements of 40 

CFR51.308(d), and (ii) establishes control technology and other requirements for the control of 

visibility-impairing pollutants from the MeadWestvaco Corporation Packaging Resources Group 

in the Blue Ridge Air Quality Control Region. These requirements shall be the legal and 

regulatory basis for control of visibility-impairing pollutants from this facility that ar~ needed in 

order for the Commonwealth to demonstrate reasonable further progress. 

fu compliance with the Federal Clean Air Act and the Commonwealth of Virginia Regulations 

for the Control and Abatement of Air Pollution, 

MeadWestvaco Corporation Packaging Resources Group 

104 East Riverside Street 

Covington, Virginia 24426 

Registration No.: 20328 

is authorized to operate equipment subject to reasonable progress requirements under 

40 CFR 51.308(d), located at 

104 East Riverside Street, Covington, Virginia 

in accordance with the Conditions of this pennit. 

Ap]JIovcd on May 4, 20~I!I~ 

j} . Robert J. Weld 

Regional Director 

Pennit consists of 5 pages. 

Pennit Conditions 1 to 16. 
INTRODUCTION 

MeadWestvaco Corporation Packaging Resources Group 

Registration Number: 20328 

May 4, 2011 

Page 2 of5 

This permit approval is based on the documents concerning Regional Haze reasonable progress 

goals - Tall Stack S02 Evaluation Response dated June 12,.2008 and supplemental information 

dated January 13, 2010. Any changes in the permit application specifications or any existing 

facilities which alter the impact of the facility on air quality may require a permit. Failure to 

obtain such a permit prior to construction may result in enforcement action. 

Words or terms used in this permit shall have meanings as provided in 9 VAC 5-10-20 of the 

State Air Pollution Control Board Regulations for the Control and Abatement of Air Pollution. 

The regulatory reference or authority for each condition is listed in parentheses ( ) after each 

condition. 

-

Annual requirements to fulfill legal obligations to maintain current stationary source emissions 

data will necessitate a prompt response by the permittee to requests by the DEQ or the Board for 

information to include, as appropriate: process and production data.; changes in. control 

equipment; and operating schedules. Such requests for information from the DEQ will either be 

in writing or by personal contact. 

The availability of information submitted to the DEQ or the Board will be governed by 

applicable provisions ofthe Freedom of Information Act, §§ 2.2-3700 through 2.2-3714 ofthe 

Code of Virginia, § 10.1-1314 (addressing information provided to the Board) of the Code of 

Virginia, and 9 V AC 5-170-60 of the Regulations for Control and Abatement of Air Pollution. 

Information provided to federal officials is subject to appropriate federal law and regulations 

governing confidentiality of such information. 

PROCESS AND EMISSION CONTROL REQUIREMENTS 

1. Conditions of this permit are effective as of January 1, 2015. 

2. Equipment List - Equipment to be operated under requirements for reasonable progress at 

this facility consists of the following: 

Equipment to be operated under Reasonable Further Progress 

Ref No. Equipment Description Rated Capacity Approved Fuel(s) 1 

Installation 

Date 

PWR006 No.6 Power Boiler 550 MMBtu/hr (P) coal pre-1963 

(s) Nos. 2, 4 & 6 fuel oil 

PWR007 No. 7 Power Boiler 440 MMBtu/br (P) coal, bark, sawdust, woodchips pre-1963 

(s) Nos. 2, 4 & 6 fuel oil 

--PWROO8- -No~8-Power-Boiler 580-MMBtu/hr~ -(P)-coal,bark,sawdust,woodchips . - --pre-l 963 -_. 

(s) Nos. 2, 4 & 6 fuel oil 

PWR009 No.9 Power Boiler 807 MMBtu/br (P) coal 1963 

(s) Nos. 2, 4 & 6 fuel oil 

1 (P) = primary fuel (s) = standby 
MeadWestvaco COtporation Packaging Resources Group 

Registration Number: 20328 

May 4, 2011 

Page 3 of5 

Specifications included in the pennit under this Condition are for infonnational purposes 

only and do not fonn enforceable tenns or conditions of the pennit. 

(9 V AC 5-80-850) 

3. Emission Controls - S02 emissions from the Nos. 6, 7, 8 and 9 Power Boilers shall be 

controlled by wet scrubbers or an alternative control device as approved by DEQ to provide 

equal or greater control. The wet scrubbers shall be provided with adequate access for 

inspection and shall be in operation when the boilers are operating except during periods of 

preventative maintenance as provided in a plan approved by DEQ. 

(9 VAC 5-80-850 and 40 CFR 51.308(d» 

4. Monitoring Devices- The wet scrubbers shall be equipped with devices to continuously 

monitor water flow and pH. Each monitoring device shall be installed, maintained, 

calibrated and operated in accordance with approved procedures which shall include, as a 

minimum, the manufacturer's written requirements or recommendations. Each monitoring 

device -shall be provided-with adequate access for inspection and. shall be in operation when 

the scrubbers are operating except during times of monitoring device malfunctions, 

associated repairs, and required quality assurance or control activities (including, as 

applicable, calibration checks and required zero and span adjustments). . 

(9 VAC 5-80-850 and 40 CFR 51.308(d» 

5. CEMS - A Continuous Emission Monitoring System (CEMS) shall be installed to measure 

and record the emissions of sulfur dioxide from the combined stack for Power Boilers Nos. 6 

through 9 (Tall Stack). The CEMS shall be installed, calibrated, maintained, audited and 

operated in accordance with DEQ approved procedures which are equivalent to the 

requirements of 40 CFR 60.13 and 40 CFR Part 60, Appendix B, and 40 CFR Part 60, 

AppendixF. 

(9 VAC 5-80-850, 9 VAC 5-50-40 and 40 CFR 51.308(d» 

6. FLOW MONITOR - A flow monitoring system shall be installed to measure and record 

volumetric gas flow from the combined stack for Power Boilers Nos. 6 through 9 (Tall 

Stack). The flow monitoring system shall be installed, calibrated, maintained, audited and 

operated in accordance with DEQapproved procedures which are equivalent to the 

requirements of 40 CFR Part 75. 

(9 V AC 5-80-850, 9 V AC 5-50-40 and 40 CFR 51.308( d» 

7. Emission Testing - The Tall Stack shall allow for emissions testing upon reasonable notice 

at any time, using appropriate methods. Sampling ports shall be provided when requested and 

~~~~ _~_ ~_~_ ~_~ __ ~_ ~safe~sampling_platfQnns~and~a_Qc~e~s~s_£hall h~provide....,.,d,,-. ____ _ 

(9 VAC 5-80-880, 9 VAC 5-80-850 and40 CFR 51.308(d» 
EMISSION LIMITATIONS 

MeadWestvaco Corporation Packaging Resources Group 

Registration Number: 20328 

May 4, 2011 

Page 4 of5 

8. Emission Limits (Tall Stack) - Combined emissions from the operation of Power Boilers 

Nos. 6 through 9 shall not exceed the limits specified below: 

Sulfur Dioxide 1,556.35 lb/hr (annual avg.) demonstrated daily 

6,817 tons/yr (12-month rolling total) 

Compliance with these emission limits shall be demonstrated no later than January 1, 2016. 

(9 VAC 5-80-850 and 40 CFR 51.308(d» 

RECORDKEEPING 

9. On Site Records - The permittee shall maintain records of emission data and operating -

parameters as necessary to demonstrate compliance with this permit. The content and format 

of such records shall be arranged with the Blue Ridge Regional Office. These records shall 

include, but are not limited to: 

a. _ Hourly and annual emissions for S02 from the Tall Stack using averaging methods 

approved by the Blue Ridge Regional Office to verify compliance with the lb/hr and 

tonlyr emissions limitations in Condition 8. 

b. Operation and control device monitoring records for the S02 scrubbers as required in 

Condition 4. 

c. Operation and monitoring records for the S02 CEMS and stack flow monitor required in 

Conditions 5 and 6. 

d. Preventive Maintenance plan as approved by DEQ and records as required by the plan. 

These records shall be available for inspection by the DEQ and shall be current for the most 

recent five years. 

(9 VAC 5-50-50, 9 VAC 5-80-900 and 40 CFR51.308(d» 

GENERAL CONDITIONS 

10. Relationshipto Other Requirements - Except to the extent that conditions in this permit 

may be more stringent, this permit does not supersede or replace any other valid permit, 

regulatory or statutory requirement. Furthermore, this approval to operate shall not relieve 

Meadwestvaco Packaging Resource Group of the responsibility to comply with all other ---------------locar;State and-federal regulations-:-including permit regufafions:------------------ -------------

(9 V AC 5-80-800 D and 9 V AC 5-80-820 F) ( 

11. Federal EnforceabiIity- Once the permit is approved by the U.S. Environmental Protection 

Agency into the Commonwealth of Virginia State Implementation Plan, the permit is 

enforceable by EP A and citizens under the federal Clean Air Act. 

(9 V AC 5-80-800 D and 9 V AC 5-80-820 F) 
MeadWestvaco Corporation Packaging Resources Group 

Registration Number: 20328 

May 4, 2011 

Page 5 of5 

12. Permit Modification - The Board may revise (modify, rewrite, change or amend) or repeal 

this permit with the consent ofMeadwestvaco Packaging Resource Group, for good cause 

shown by Meadwestvaco Packaging Resource Group, or on its own motion provided 

approval of the revision or repeal is accomplished in accordance with Regulations of the 

Board and the Administrative Process Act (§ 2.2-4000 et seq.). Such revision or repeal shall 

not be effective until the reviSIon or repeal is approved by the U. S. Environmental Protection 

Agency following the requirements of 40 CFR Part 51 (Requirements for Preparation, 

Adoption, and Submittal of Implementation Plans). 

(9 V AC 5-80-960 and 9 V AC 5-80-1000) 

13. Failure to Comply - Failure by Meadwestvaco Packaging Resource Group to comply with 

any of the conditions of this permit shall constitute a violation of a Permit of the Board. 

Failure to comply may result in a Notice of Violation and civil penalty. Nothing herein shall 

waive the initiation of appropriate enforcement actions or the issuance of orders as 

appropriate by the Board as a result of such violations. Nothing herein shall affect 

. appropriate enforcement actions by any other federal, state, or local regulatory authority. 

(9 VAC 5-80-820 F, 9 VAC 5-80-910, and 9 VAC 5-80-1010) 

14. Right of Entry - The permittee shall allow authorized local, state, and federal 

representatives, upon the presentation of credentials: 

a. To enter upon the permittee's premises on which the facility is located or in which any 

records are required to be kept under the terms and conditions of this permit; 

b. To have access to and copy at reasonable times any records required to be kept under the 

terms and conditions of this permit or the State Air Pollution Control Board Regulations; 

c. To inspect at reasonable times any facility, equipment, or process subject to the terms and 

conditions of this permit or the State Air Pollution Control Board Regulations; and 

d. To sample or test at reasonable times. 

For purposes of this condition, the time for inspection shall be deemed reasonable during 

regular business hours or whenever the facility is in operation. Nothing contained herein 

shall make an inspection time unreasonable during an emergency. 

(9 V AC 5-170-130 and 9 V AC 5-80-850) ( 

15. Change of Ownership - In the case of a transfer of ownership of a stationary source, the new 

owner shall abide by any current permit issued to the previous owner. The new owner shall 

notify the Blue Ridge Regional Office of the change of ownership within 30 days ofthe 

---------- -~~transfer. ----~-----~--~-~~-. 

(9 V AC 5-80-940) 

16. Permit Copy - The permittee shall keep a copy ofthis permit on the premises of the facility 

to which it applies. 

(9 V AC 5-80-860 D) 
ATTACHMENT B

ENGINEERING ANALYSIS FOR

DETERMINATION OF THE CONTROL OF

VISIBILITY-IMPAIRING POLLUTANTS

FROM

MeadWestvaco Corporation

Packaging Resources Group

Alleghany County, Virginia

Registration No. 20328
VIRGINIA DEPARTMENT OF ENVIRONMENTAL QUALITY

Blue Ridge Regional Office

INTRA-AGENCY MEMORANDUM

Permit Writer L.J. Alexander

Memo To Air Permit File Date May 2, 2011

Facility Name MeadWestvaco Corporation Packaging Resources Group

Registration Number 20328

County-Plant I.D. 580-0003

UTM Coordinates (Zone 17) 588.2 Easting (km) 4184.6 Northing (km)

Elevation (feet) 1260

Distance to Nearest Class I 

Area (select one)

104.1 SNP (km) 50.4 JRF (km)

FLM Notification (Y/N) Y1 Required if less than 10K (minor), 100K (state major)

NET Classification (A, SM, B) A Before permit action A After permit action

Title V Major Pollutants PM PM10

SO2 NOX

CO VOC 

HAPs

Before permit action no 

change

After permit action

PSD Major Source (Y/N) Y Before permit action Y After permit action

PSD Major Pollutants SO2 NOX

CO VOC 

PM PM10

TRS; red. 

S cmpds; 

fluorides; 

sulf. acid 

mist

Before permit action no 

change

After permit action

I. Introduction

 MeadWestvaco Corporation Packaging Resources Group (MWV) is a large, integrated kraft 

pulp and paperboard mill located in Covington, Virginia. MWV has BART2

-eligible equipment 

and was issued a BART permit on February 23, 2009 to control the following visibilityimpairing pollutants: NOX, PM10 and SO2. 

This permit action is board-initiated for the purpose of further reducing SO2 emissions and to 

demonstrate reasonable progress3

 

1 The FLM is aware of this process and was given an opportunity to review the draft permit prior to public notice for 

an additional 30 days (40 CFR 51.302(a)&(b)). This opportunity to review and comment was provided via 

electronic correspondence. However a formal notification letter such as that sent for PSD permits was not sent.

 towards achieving natural visibility conditions under the 

2 BART - Best Available Retrofit Technology. 3 DEQ has used the term “reasonable further progress” to describe this process but the term used in 

40 CFR 51.308(d) is “reasonable progress” or “reasonable progress goals.”
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 2 

Regional Haze Program. This permit will not affect any past permits issued for the facility and 

will become a part of the State Implementation Plan (SIP) after approval. DEQ procedures are 

based on EPA’s guidance memo issued June 1, 2007, “Guidance for Setting Reasonable Progress 

Goals under the Regional Haze Program,” hereafter referred to as “EPA’s reasonable progress 

guidance.” EPA stresses in this document that it is “merely guidance and that States . . . may 

elect to follow or deviate from this guidance, as appropriate.” 

Reasonable progress is a required element of Virginia’s SIP even though Virginia is 

surpassing visibility improvement benchmarks as indicated by the glide path4. States included in 

VISTAS5 determined that the pollutant of concern for reasonable progress is SO2. Virginia, 

North Carolina and West Virginia evaluated facilities to identify those with a calculated Class I 

area visibility impact of at least 1%. West Virginia and North Carolina did not find any facilities 

through this analysis that were within their respective state borders, were not electrical 

generating units (EGUs) subject to the Clean Air Interstate Rule (CAIR), and had feasible 

control options for SO2 emissions. DEQ identified the Tall Stack6 at MWV as having a 

calculated impact over 1% on two Class I areas, Dolly Sods and James River Face. For the 

James River Face, the MWV Tall Stack is the single largest calculated point source contributor 

to visibility impairment.

 The 2018 calculated visibility impacts on Dolly Sods Wilderness Area, Shenandoah National 

Park, and James River Face Wilderness Area from all point sources in the VISTAS modeling 

domain take into account expected SO2 emission reductions resulting from a variety of programs. 

These programs include, but are not limited to, clean fuel requirements, controls implemented 

due to a variety of federal and state enforcement actions, and programs expected to impact the 

utility sector. MWV’s Tall Stack was originally estimated to have SO2 emissions of 

approximately 9,997 tons7 per year (tpy) resulting in the following visibility impacts:

 Shenandoah National Park - 0.73% calculated visibility impact contribution 

 Dolly Sods Wilderness Area - 1.1% calculated visibility impact contribution

James River Face Wilderness Area - 18.4% calculated visibility impact contribution

 DEQ wrote a letter to MWV on September 25, 2007 requesting further evaluation of the 

emission units associated with the Tall Stack. MWV responded on June 16, 2008 and stated that 

they could achieve an additional 15% SO2 reduction from the (then) proposed BART SO2 limit. 

Now that the BART permit has been issued, MWV has confirmed their goal of 15% further 

reduction from those permit limits in a letter dated January 13, 2010. The proposed Reasonable 

Progress SO2 emission limit for the Tall Stack is 6,817 tpy. 

 

4 Glide path - the projected uniform rate of visibility improvement required to achieve a state of natural condition in 

Class I areas by the year 2064.

5 VISTAS - Visibility Improvement State and Tribal Association of the Southeast formed to address regional haze 

and visibility problems includes FL, GA, AL, MS, NC, SC, TN, KY, VA and WV; there are 18 Class I areas in the 

VISTAS states.

6 CEDS Stack #1.

7

 The 9,997 tons does not take into account BART emission limits that were imposed in 2009. The BART SO2 

emission limit for the Tall Stack is 8,020 tons per year.
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 3 

The modeled visibility impacts comparing BART SO2 emission limits (8,020 tpy) and the 

proposed reasonable progress limits (6,817 tpy) for the three impacted Class I areas are shown 

below: 

Table 1: 98th Percentile Deciview (dv) Visibility Impacts

Class I Area BART Reasonable Progress Improvement

Shenandoah National Park 1.491 dv 1.412 dv 0.079 dv 

Dolly Sods Wilderness Area 0.987 dv 0.888 dv 0.099 dv 

James River Face Wilderness Area 2.842 dv 2.832 dv 0.010 dv 

II. Emission Unit(s) / Process Description(s)

The emission units involved in this permit action are the four boilers in the power house that 

emit via the Tall Stack: 

No. 6 Power Boiler (PWR006) - 550 MMBtu/hr coal boiler 

No. 7 Power Boiler (PWR007) - 440 MMBtu/hr coal, wood boiler 

 No. 8 Power Boiler (PWR008) - 580 MMBtu/hr coal, wood boiler 

 No. 9 Power Boiler (PWR009) - 807 MMBtu/hr coal boiler 

SO2 emissions from these four boilers are controlled by two wet caustic scrubbers. The 

scrubbers were initially installed in the mid 1990’s to achieve emission offsets to avoid PSD 

during a plant expansion. The scrubbers used only waste caustic from the mill and achieved an 

estimated 45-55% SO2 reduction. Due to the unique configuration of the scrubbers, it was not 

possible to impose a practicably enforceable limit for SO2 on the No. 9 Power Boiler alone, the 

only BART-eligible equipment of this group. Consequently, the BART emission limit 

encompasses all four boilers and resulted in a 1,112.3 tpy reduction8 in allowable SO2 emissions 

from the Tall Stack. MWV has proposed an additional 15% control to satisfy reasonable 

progress requirements for this round of regional haze planning as follows: 

BART emission limits 1,831 lb/hr (annual avg.) 8,020 tpy

Proposed reasonable progress limits 1,556 lb/hr (annual avg.) 6,817 tpy

DEQ is proposing to accept MWV’s plan for 15% additional control. The additional control 

will be achieved in part by adding more virgin caustic to the scrubber liquid. MWV also 

proposes to complete certain maintenance activities on the scrubbers during the next mill outage 

some time between 2013 and 2015.9 

 

8 The previous permit limit was 9,132.3 tons/yr (November 3, 2003).

9 The next mill outage is not scheduled at this time - the last outage was in 2008 and mill outages are usually 

scheduled every 5 - 7 years. 
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 4 

MWV has a Continuous Emission Monitor (CEM) for SO2 in the Tall Stack that is currently 

being used to demonstrate compliance with existing emission limits. This same CEM will be 

used to demonstrate compliance with the proposed reasonable progress limits. The CEM meets 

the requirements of 40 CFR 60.13 and 40 CFR Part 60, Appendix B. MWV also has a flow 

meter that meets the requirements of 40 CFR Part 75. The CEM and flow meter will be used to 

demonstrate compliance with the pounds-per-hour emission limit on a daily basis. Daily 

emission totals will be combined to demonstrate compliance with the tpy limit. Compliance with 

the reasonable progress emission limits will be demonstrated by January 1, 2016. 

III. Regulatory Review 

The facility is being permitted subject to the provisions of Article 5 (9 VAC 5-80-800 et seq.) 

of 9 VAC 5 Chapter 80 (Permits for Stationary Sources). The facility as a whole is subject to 

provisions of Article 6 (9 VAC 5-80-1100 et seq.) and of Article 8 (9 VAC 5-80-1605 et seq.) of 

9 VAC 5 Chapter 80 (Permits for Stationary Sources). The federal regulation pertinent to this 

action is 40 CFR 51 Subpart P, Protection of Visibility. 

IV. Reasonable Progress Determination

 Section 169A(a)(1) of the Clean Air Act (CAA) sets a national goal of preventing any future 

visibility impairment and remedying any existing visibility impairment in federal Class I areas 

resulting from anthropogenic air pollution. Section 169A(b)(2) goes on to require that EPA 

promulgate regulations requiring SIPs to contain emission limitations, schedules of compliance, 

and other measures to make reasonable progress towards meeting this national goal. The 

following considerations must be taken into account when determining reasonable progress, as 

specified in Section 169A(g)(1): 

• Costs of compliance; 

• Time necessary for compliance;

• Energy and non air quality environmental impacts of compliance; and 

• Remaining useful life of any source subject to such requirements. 

EPA finalized the regional haze rule on July 1, 1999 (64 FR 35714), which described the 

requirements for reasonable progress goals under 40 CFR 51.308(d)(1). EPA’s reasonable 

progress guidance provided several other guidelines for consideration when setting reasonable 

progress goals and strategies, including:

• The long term goal of no manmade impairment encompasses several planning periods so 

that it may be reasonable to defer reductions to later planning periods in order to maintain 

a consistent glide path towards that goal. (Page 1-4) 

• The significant emissions reductions anticipated from BART, CAIR, and the 

implementation of other CAA programs such as attainment planning for ozone and PM2.5

NAAQS may be all that are necessary to achieve reasonable progress in the first round of 

planning. (Page 4-1) 
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 5 

• It is reasonable to conclude that any control requirements imposed in the BART 

determination also satisfy the reasonable progress goal requirements for source review in 

the first round of regional haze planning. (Page 4-3) 

• In assessing compliance costs, average and incremental costs should be evaluated using 

dollar-per-ton ($/ton) and dollar-per-deciview ($/dv) calculations. (Page 5-2)

 On September 25, 2007, DEQ-WCRO sent a letter to MWV concerning the Tall Stack. This

letter described in detail DEQ’s approach to evaluating reasonable progress requirements. These 

requirements are discussed in further detail in the SIP revision submitted to EPA Region III on 

October 4, 2010, entitled “Regional Haze State Implementation Plan For Virginia Class I Areas – 

Shenandoah National Park and James River Face Wilderness Area.” The following is a synopsis 

of the approach DEQ used to determine the sources where a reasonable progress review was 

appropriate: 

• Species contribution assessments on the 20% worst visibility days for all Class I areas in 

the Southeast concluded that sulfate accounts for greater than 70% of the visibility 

impairing pollution. Based on this information, DEQ concluded that controlling SO2

emissions should be the focus of the reasonable progress review for this round of 

planning. 

• Point source emissions in 2018 represent greater than 95% of the total SO2 emissions 

inventory. Therefore, DEQ concluded that source sectors evaluated for reasonable 

progress should be EGU and non-EGU point SO2 emissions.

• DEQ concluded that emission reductions due to the implementation of CAIR constitute 

reasonable progress for the EGU source sector as long as data from IMPROVE monitors 

indicate that expected visibility improvements are being achieved. CAIR has been 

remanded to EPA, and EPA has proposed the Transport Rule (TR) in its place. DEQ 

fully expects that the TR will constitute reasonable progress for the EGU source sector. 

However, should data from the IMPROVE monitors indicate that the projected visibility 

improvements are not being achieved by Virginia’s Class I areas, this expectation may be 

reexamined prior to 2018. 

• DEQ calculated the fractional contribution from all emission units within the SO2 area of 

influence for Virginia’s Class I areas and also for surrounding states’ Class I areas. NonEGU emission units contributing at least 1% to the calculated visibility impairment at any 

of the Class I areas were reviewed for reasonable progress requirements. Using a 

contribution of at least 1% as a cutoff for determining which units should be subject to 

further review allowed DEQ to focus resources on those units responsible for a 

significant portion of the calculated visibility impairment.

• Using an economic cost threshold of $1,200/ton SO2 removed, DEQ examined all stacks 

and their respective units identified in the step above for the potential of additional 

reductions for reasonable progress. Only MWV’s Tall Stack appeared to have the 

potential for additional SO2 reductions using this initial cost threshold. 

 Accordingly, DEQ requested a thorough review of possible control technologies for the Tall 

Stack. The technologies requested to be analyzed needed to control all four boilers exhausting to 

the Tall Stack, including Boiler #9, which was already subject to BART. The permit requiring 
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 6 

BART control on the Tall Stack in lieu of BART solely on Boiler #9 was issued on February 23, 

2009, and submitted to EPA on May 6, 2009 as a SIP revision. MWV submitted their response 

to the reasonable progress request on June 16, 2008, and this response provided costs for the 

installation of a new caustic flue gas desulfurization unit (FGD)/wet scrubber, a lime spray dryer, 

the use of lower sulfur coal, and the upgrade of the existing wet scrubber for enhanced capture 

efficiency. The following table summarizes the information found in this response, including 

control efficiencies analyzed: 

 

Table 2: Summary of Control Options for MWV’s Tall Stack 

Control 

Technology 

% 

Reduction

Cost 

Impact1

$/ton 

Incremental Cost 

Impact Comments

$/ton2 $/dv3

New Caustic FGD 90% $961 $8,220 $138 

Million

Total Capital Investment 

estimated at 

$41,000,000. 

Spray Dryer 90% $528 $4,400 $76 

Million

Total Capital Investment 

estimated at 

$46,000,000. 

Improve existing 

FGD ~15% $717 --- $8 

Million

Costs are associated 

mainly with increased 

caustic use.

Switch to 1% S 

coal from 1.58% S 

coal

Varies $2,636 No incremental analysis provided since cost 

effectiveness is above $1,200/ton removed.

1

Cost impact based on SO2 reductions assuming worst case coal quality (2.2% S) and maximum 

operating hours. 

2

Incremental $/ton costs for emissions controls compared to reductions achieved through 

improving the existing FGD (an annual limitation of 6,817 tpy SO2).

3

Incremental $/dv costs for visibility improvements beyond those achieved through the BART 

limitations of 1,831 lbs SO2/hr and 8,050 tpy SO2. 

The estimated cost effectiveness in terms of $/ton for a new caustic FGD, a new spray dryer, 

and improving the existing FGD are very reasonable and are well within the range of costs for 

the SO2 control required by CAIR. Incremental cost effectiveness in terms of $/ton for installing 

either a new caustic FGD or a new spray dryer, as compared to the costs for improving the 

existing scrubber, are somewhat higher. Both a new caustic FGD and a new spray dryer require 

very large capital investments, whereas improving the existing FGD requires no capital 

investment. Also, cost effectiveness for a coal switch was determined to be above the $1,200/ton 

threshold. Incremental cost effectiveness in terms of $/dv improvement are quite high for both 

the new caustic FGD and new spray dryer options. 

 Cost effectiveness is only one aspect that must be considered for the reasonable progress 

determination. Consideration must also be given to the level of visibility improvement expected 

within the regional haze planning cycle for 2018. Exhibit 1, Exhibit 2, and Table 3 below 
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 7 

consider all federal and state control measures and strategies, including BART reductions, in the 

estimated visibility measurements expected in the Shenandoah National Park and the James 

River Face Wilderness Area. These exhibits do not consider any reductions from the Tall Stack

beyond the BART limitations of 8,050 tpy SO2. These data originate from Virginia’s October 4, 

2010 Regional Haze SIP revision. 

 Exhibit 1, Exhibit 2, and Table 3 clearly show that even without the improvements expected 

from any additional reductions beyond BART from MWV’s Tall Stack, both the James River 

Face Wilderness Area and the Shenandoah National Park are projected to have visibility 

improvements that surpass the improvement benchmarks for achieving natural conditions by 

2064 on the 20% worst visibility days. Additionally, these data show that not only will visibility 

be protected on the 20% best days, but visibility is also expected to improve on 20% best 

visibility days in both Class I areas by 2018. 

Review of the expected visibility improvements associated with the first round of regional 

haze planning in conjunction with the guidelines provided by EPA’s reasonable progress 

guidance support a conclusion that additional reductions for reasonable progress may be deferred 

to later planning periods. This conclusion would rely upon programs such as CAIR or TR, 

federal onroad and nonroad programs, clean fuel programs, attainment planning control 

strategies, BART and other mandated strategies to facilitate the reasonable progress goal for 

Virginia’s Class I areas. 

 However, the option to improve the existing FGD system for an additional 15% control of 

SO2 emissions, resulting in a federally enforceable limit of 6,817 tpy SO2, not only had no 

capital costs but had a cost effectiveness of well under $1,200/ton removed. Additionally, the 

necessary changes to support these improvements can be done during scheduled mill outages, 

thereby costing minimal downtime charges. 

Exhibit 1: Expected Visibility Improvement on the 20% Worst Days at Shenandoah 

Uniform Rate of Reasonable Progress Glide Path

Shenandoah - W20% Data Days

Base G4a Projections, 12 km grid, New IMPROVE Equation

29.3

27.8

25.1

22.1

19.1

16.2

13.2

11.4

21.9

0

5

10

15

20

25

30

35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 8 

Exhibit 2: Expected Visibility Improvement on the 20% Worst Days at James River Face

Table 3: Virginia Reasonable Progress Goals

Class I Area

Natural 

Conditions, 

dv 

Baseline 

Visibility, dv * 

Expected Visibility 

by 2018, dv Reasonable Progress Goal

Base G4a

(Improvement by 2018)

dv

Deciview 

Improvement 

Needed from 

Base G4a

2018-2064

Base G2 Base G4a

Shenandoah 

National Park

11.4 20% WD 29.3 22.1 21.9 Δ 7.4 dv Δ 10.8 

3.1 20% BD 10.9 8.8 8.7 Δ 2.2 dv --- 

James River Face 

Wilderness Area

11.1 20% WD 29.1 22.6 22.4 Δ 6.7 dv Δ 11.0

4.4 20% BD 14.2 12.5 12.4 Δ 1.8 dv --- 

*WD=worst day, BD=best day

Based on this information, DEQ proposes that improvements to the existing scrubbers on the 

Tall Stack resulting in emission rates of 1,556 lbs SO2/hour and 6,817 tpy SO2 constitute 

reasonable progress for the Tall Stack for this round of regional haze planning. This 

determination is based on the following: 

• The significant capital investment necessary for the construction of a wet scrubber or 

spray dryer;

• The incremental cost effectiveness of either a wet scrubber or spray dryer over the costs 

associated with improvements at the existing wet scrubber;

• The significant emission reductions of visibility impairing pollutants from programs such 

as CAIR, BART, attainment planning endeavors, and federal onroad and nonroad 

Uniform Rate of Reasonable Progress Glide Path

James River Face - W20% Data Days

Base G4a Projections, 12 km grid, New IMPROVE Equation

29.1

27.6

24.9

21.9

18.9

15.9

12.9

11.1

22.4

0

5

10

15

20

25

30

35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews) 

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 9 

measures, which are expected to result in 2018 visibility improvements that surpass the 

benchmarks for progress toward natural conditions on 20% worst visibility days at each 

Class I area; 

• The EPA’s reasonable progress guidance, which suggests that consideration may be 

given to the application of BART on units subject to reasonable progress requirements; 

• Suggestions within this same guidance that indicate the significant emission reductions 

resulting from BART, CAIR, and other CAA programs may be all that are necessary to 

achieve reasonable progress in the first round of planning; 

• Further suggestions in this same guidance that indicate deferral of emission reductions 

into future rounds of regional haze planning may be appropriate to ensure steady 

improvement toward reaching the national goal of natural conditions at Virginia’s Class I 

areas; and

• The lack of capital investment costs and the minimal downtime costs associated with an 

improvement in current scrubber operations. 

V. Dispersion Modeling

Visibility impairment modeling for NOX, PM10 and SO2 was conducted in conjunction with 

the BART permit process in 2008. No further modeling has been conducted or is required as a 

part of this permitting process.

A. Regulated Pollutants

Dispersion modeling for regulated pollutants is not a consideration for this review.

B. Toxic Pollutants

Toxic Pollutants are not a consideration for this review. 

VI. Boilerplate Deviations 

SOP Generic Boilerplate - Feb 2006.doc (last modified 2/27/2006) 

• The title page and introduction wording has been edited to reflect Reasonable Further 

Progress requirements of 40 CFR 51.308. 

Conditions added to General Conditions for Reasonable Progress to cover SIP requirements 

as specified in DEQ guidance “Requirements for Administrative Mechanisms to be included in 

the SIP and used to enforce SIP Requirements”10

• Relationship to Other Requirements (#8) 

: 

• Federal Enforceability (#9)

• Permit Modification (#10) 

• Failure to Comply (#11) 

SOP Skeleton Boilerplate - May 2006.doc (last modified 5/22/2006): the following 

conditions from this boilerplate have been omitted: 

• 4. Violation of Ambient Air Quality Standard 

 

10 as found on DEQnet TEMPLATES\SOURCE-SPECIFIC\#adm mech guidance-source specific
MeadWestvaco Corporation Packaging Resources Group

Registration No.:20328 

Engineering Analysis May 2, 2011

Page 10 

• 6. Permit Suspension/Revocation 

• [O] State Only Enforceable Requirements

VII. Compliance Demonstration

Compliance will be demonstrated through SO2 CEM data, monitoring of the wet scrubbers’ 

operating parameters (water flow and pH) and record keeping. 

VIII.Title V Review - 9 VAC 5 Chapter 80, Part II, Article 1 

Title V applicability is not a consideration for this review. The conditions of this permit, 

once finalized, will be incorporated into the Title V upon renewal. 

IX. Other Considerations

A 30-day review was provided to the FLMs from August 20, 2010 to September 21, 2010. 

Responses to the comments received from the FLMs were provided on February 14, 2011. A 30-

day public notice was conducted by placing an ad in the Virginian Review on March 28, 2011. 

The notice expired on April 28, 2011 with one comment received11 and no request for public 

hearing. No response was required for the comment. The permit is now finalized for signature on 

May 6, 2011 and will go through the necessary procedures to become part of the SIP.

X. Recommendations

Recommend permit approval. 

Attachments

MW Tall Stack SO2 Evaluation dated June 12, 2008 

 

11 The comment (via email) was from Mike Gordon with EPA who stated that he had reviewed the draft permit and 

had no comments
COMMONWEALTH OF VIRGINIA

STATE IMPLEMENTATION PLAN REVISION

FOR

IMPLEMENTATION OF

REASONABLE PROGRESS

ENGINEERING ANALYSIS

FOR

MeadWestvaco Corporation

Packaging Resources Group

FEDERAL LAND MANAGER REVIEW

As provided in 40 CFR 51.302(b)(2), the FLMs were given the opportunity to comment 

on this permit on August 20, 2010. Comments were received on September 21, 2010. 

DEQ responded to the comments in a letter dated February 14, 2011. This 

correspondence is attached. 
From: Alexander, Lillian (DEQ)

To: "don_shepherd@nps.gov"; "patricia_f_brewer@nps.gov"; "Cindy M Huber"

Cc: Brown, Jed (DEQ); Adams, Frank (DEQ); Monroe, Mary (DEQ); McLeod, Doris (DEQ); Thompson, Tamera

(DEQ); Ballou, Thomas (DEQ)

Subject: draft reasonable progress permit for Meadwestvaco

Date: Friday, August 20, 2010 11:34:00 AM

Attachments: 20328 AUG19 FNLDFT.doc

20328 2010-FINAL DFT RFPSOP eng.doc

Cindy/Don/Patricia

In accordance with 40 CFR 51.302 (a) &(b), attached please find the draft reasonable progress

State Operating Permit and associated engineering analysis for Meadwestvaco in Covington,

Virginia. Please review and provide your comments no later than September 21, 2010. The June

12, 2008 Tall Stack SO2 Evaluation document referenced as an attachment in the engineering

analysis was sent to you in early June and I have not re-attached it since there were some

problems associated with emailing the large pdf file.

If you have any questions, please advise.

Lillian J. Alexander, Air Permit Engineer

VADEQ, Blue Ridge Regional Office

3019 Peters Creek Road Roanoke, VA 24019

phone 540/562-6783 fax 540/562-6725

new email address lillian.alexander@deq.virginia.gov
From: Cindy M Huber

To: Cindy M Huber

Cc: Brown, Jed (DEQ); don_shepherd@nps.gov; Alexander, Lillian (DEQ); pat_brewer@nps.gov; Cindy M Huber

Subject: Re: draft reasonable progress permit for Meadwestvaco

Date: Tuesday, September 21, 2010 12:48:38 PM

Lillilan and Jed, 

As a follow-up to our conversation yesterday I am resubmitting this email with comments on the

Reasonable Progress Permit for MeadWestvaco. It is my understanding that this email serves as a

formal comment. 

I understand that all Control Options considered had approximately the same control efficiency. We

would like VDEQ to 1) include a discussion (possibly in the Intra-agency memorandum) that clearly

states why higher control efficiencies were not investigated further (and required), and 2) why Option 1

was chosen over the others presented by MeadWestvaco in their reports dated June 12, 2008 and July

10, 2009.

Thank you for the opportunity to comment. 

Cindy Huber

******************************

Cindy M. Huber 

Air Resource Specialist

USDA Forest Service

5162 Valleypointe Parkway

Roanoke, VA 24019

Phone 540-265-5156

Fax 540-265-5109

Email chuber@fs.fed.us

www.fs.fed.us/air

******************************

Cindy M Huber/R8/USDAFS

09/16/2010 03:49 PM

To "Alexander, Lillian (DEQ)" <Lillian.Alexander@deq.virginia.gov>

cc david.brown@deq.virginia.gov, pat_brewer@nps.gov,

don_shepherd@nps.gov, Cindy M Huber/R8/USDAFS@FSNOTES

Subject Re: draft reasonable progress permit for MeadwestvacoLink

Lillian and Jed, 

I appreciate the work that has gone into getting to the draft permit for Reasonable Progress. It will be

great to see additional sulfur dioxide emissions reductions. I do have a comment and a question that I

am sending via email. Please call me if you would like clarification or you want to discuss. 

1. We would like VDEQ to include a discussion (possibly in the Intra-agency Memorandum) clearly

stating why Option 1 was chosen over the others. 
2. MW states that all Options achieve the same control efficiency of 90%, is that true? 

Thanks, 

Cindy

******************************

Cindy M. Huber 

Air Resource Specialist

USDA Forest Service

5162 Valleypointe Parkway

Roanoke, VA 24019

Phone 540-265-5156

Fax 540-265-5109

Email chuber@fs.fed.us

www.fs.fed.us/air

******************************

"Alexander, Lillian (DEQ)"

<Lillian.Alexander@deq.virginia.gov>

08/20/2010 11:35 AM

To <don_shepherd@nps.gov>, <patricia_f_brewer@nps.gov>, "Cindy M

Huber" <chuber@fs.fed.us>

cc "Brown, Jed (DEQ)" <David.Brown@deq.virginia.gov>, "Adams,

Frank (DEQ)" <Frank.Adams@deq.virginia.gov>, "Monroe, Mary

(DEQ)" <Mary.Monroe@deq.virginia.gov>, "McLeod, Doris (DEQ)"

<Doris.McLeod@deq.virginia.gov>, "Thompson, Tamera (DEQ)"

<Tamera.Thompson@deq.virginia.gov>, "Ballou, Thomas (DEQ)"

<Thomas.Ballou@deq.virginia.gov>

Subject draft reasonable progress permit for Meadwestvaco

Cindy/Don/Patricia

In accordance with 40 CFR 51.302 (a) &(b), attached please find the draft reasonable progress

State Operating Permit and associated engineering analysis for Meadwestvaco in Covington,

Virginia. Please review and provide your comments no later than September 21, 2010. The June

12, 2008 Tall Stack SO2 Evaluation document referenced as an attachment in the engineering

analysis was sent to you in early June and I have not re-attached it since there were some

problems associated with emailing the large pdf file.

If you have any questions, please advise.

<<20328 AUG19 FNLDFT.doc>> <<20328 2010-FINAL DFT RFPSOP eng.doc>>

Lillian J. Alexander, Air Permit Engineer

VADEQ, Blue Ridge Regional Office

3019 Peters Creek Road Roanoke, VA 24019

phone 540/562-6783 fax 540/562-6725

new email address lillian.alexander@deq.virginia.gov[attachment "20328 AUG19 FNLDFT.doc"
deleted by Cindy M Huber/R8/USDAFS] [attachment "20328 2010-FINAL DFT RFPSOP eng.doc"

deleted by Cindy M Huber/R8/USDAFS]
---------------------------~---~------------

Douglas W. Domenech 

Secretary of Natural Resources 

Lynchburg Office 

7705 Timberlake Road 

Lynchburg, Virginia 24502 

(434) 582-5120 

Fax (434) 582-5125 

COMMONWEALTHofWRGIN~ 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Blue Ridge Regional Office 

www.deq.virginia.gov 

February 14, 2011 

Ms. Cindy Huber, Air Resource Specialist 

United States Deparhnent of Agriculture, Forest Service 

5162 Valleypointe Parkway 

Roanoke, VA 24019-5100 

RE: Comments concerning MeadWestvaco's Reasonable Progress 'draft SOP 

Dear Ms. Huber: 

David K. Paylor 

Director 

Robert J. Weld 

Regional Director 

Roanoke Office 

3019 Peters Creek Road 

Roanoke, Virginia 24019 

(540) 562-6700 

Fax (540) 562-6725 

Thank you for your comments on Meadwestvaco's draft SOP. DEQ believes the 

additional S02 scrubbing of the four Tall Stack boilers required by the proposed permit is 

consistent with reasonable progress requirements. More information has been added to the draft 

engineering analysis to better clarify why DEQ proposed this determination. The draft 

engineering analysis has also been updated to better clarify the information provided by the 

facility concerning control strategy pollution removal efficiencies. 

As detailed in the engineering analysis, the reasonable progress process required 

significant research and analysis on the part of VISTAS and DEQ. This background helped to 

determine, among other findings, the appropriate pollutants and emissions source sectors where 

scarce resources could best be focused to implement the reasonable progress requirements ofthe 

Clean Air Act. EPA's 2007 reasonable progress guidance provided additional guidelines tQ 

supplement the requirements ofthe Clean Air Act in regards to reasonable progress. DEQ has 

applied these guidelines to· this reasonable progress determination for Meadwestvaco as well as 

to the Regional Haze SIP revision that DEQ submitted to EPA on October 4,2010. As you 

know, the reasonable progress requirements of the Clean Air Act do not have the same goals as a 

BACT or LAER review although both may rely at least in part on economic data developed 

using OAQPS documentation. 

The reasonable progress process has proven to be quite complicated during this round of 

Regional Haze planning. Issues surrounding the guidance document concerning reasonable 

progress have been further exacerbated by the uncertain regulatory environment. However, even 

without issuing to Meadwestvaco a reasonable progress permit requiring additional reductions 

beyond BART, Virginia's Class I areas are expected to surpass glide path projections for 
Ms. Cindy Huber 

February 14, 2011 

Page 2 

visibility improvements. The reductions proposed for the reasonable progress permit will 

provide further assurance that the 2018 visibility benchmarks for both Shenandoah National Park 

and James River Face Wilderness Area.will be attained. 

If you have further questions or comments on this draft permit or the draft engineering 

analysis, please do not hesitate to contact me at 540/562-6783. 

Sincerely, 

J9~~ 

L~an J. Alexander 

Air Permit Engineer 

enc1: draft permit and engineering analysis 

cc: :file 

. James Taylor - MeadWestvaco (via email) 

Melissa Linden - EPA (via email) 

Doris McLeod, DEQ (via email) 
ENCLOSURE 2

PUBLIC PARTICIPATION CERTIFICATION

AND COMPLIANCE WITH

STATE ADMINISTRATIVE PROCEDURES

As required by 40 CFR 51.102 and Section 2.1 of Appendix V of 40 CFR Part 51, the 

following information regarding public participation activities and compliance with state 

administrative procedures is provided.

PUBLIC PARTICIPATION ACTIVITIES

As required by 40 CFR 51.102(a), a public comment period to provide the opportunity to 

submit written comments concerning a proposed revision to the Commonwealth of 

Virginia State Implementation Plan was held from March 28 to April 28, 2011. 

As required by 40 CFR Part 51.102(a) and (d)(1) and (2), the public was given notice of 

the public comment period in the Covington Virginian Review (for the Valley of Virginia

Intrastate Air Quality Control Region), along with the location of the proposal for public 

inspection, on March 28, 2011. The notice included procedures to afford the public the 

opportunity to request that a hearing be held pursuant to 40 CFR 51.102(a); no such 

request was received. The attached copy of the notice provides the evidence required 

by Section 2.1(f) of Appendix V of 40 CFR Part 51. 

The Regional Administrator for the U.S. Environmental Protection Agency was notified 

of the public comment period. This notification follows the requirements of 40 CFR Part 

51.102(d)(3). As provided in 40 CFR 51.302(b)(2), the federal land managers (FLMs) 

were given the opportunity to comment on this permit on August 20, 2010. A number of 

comments were received and responded to; the relevant correspondence is included in 

Attachment B to Enclosure 1. No meeting was requested by the FLMs. This 

information regarding FLM consultation was provided in the public hearing notice.

The complete record of public comment is located at the Air Division of the Department 

of Environmental Quality. The department contact to access this information is the 

Director, Air Division. A summary of the testimony received and responses thereto is 

attached.

COMPLIANCE WITH STATE ADMINISTRATIVE PROCEDURES

As required by Section 2.1(b) of Appendix V of 40 CFR Part 51, the permit was issued 

by the Department of Environmental Quality on May 4, 2011, to be effective that same 

day. The statement of authority and procedures followed for approval and issuance of 

the permit and the signature of the Regional Director on the permit are included in 

Attachment A to Enclosure 1, providing the evidence required by Section 2.1(b) and (e) 

of Appendix V of 40 CFR Part 51. As required by Section 2.1(d) of Appendix V of 40 
CFR Part 51, a copy of the actual permit submitted for approval and incorporation by 

reference into the Commonwealth of Virginia State Implementation Plan is included in 

Attachment A to Enclosure 1.

TEMPLATES\SOURCE-SPECIFIC\PLN02

SRCESPEC\MEADWESTVACO2\MW2-SIP-2.DOC
· ,--- vrnGINIAN REVIEW, MQNDAY, MARCH 28,2011 

Public Notice - Environmental Permit 

Purpose of notice: The Department of Environmental Quality (DEQ) is announcing an opportunity 

for public comment on a permi~ to limit air pollution emittep by a facility in Alleghany County, 

Virginia. The Commonwealth intends to submit the permit as a revision to its State Implementation 

Plan (SIP) in accordance with the requirements of §110(a) of the federal Clean Air Act. The SIP i~ 

th~ plan developed by the Commonwealth in order to fulfill its responsibilities under the federal 

Clean Air Act to attain and maintain the ambient air quality standards promulgated by the U.S. 

Environmental Protection, Agency (EPA) under the Act~ , 

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;'Rl:Jblic commentl Qeriod" :Marcm 28)to;Aprik281,"20~~~'" ;·,,,'m'·'"'' "'~ .'~"'~" 'T ,. c' c _.,~... _.,~"_, _ _ 

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, 'State public hearing 'procedure: Interested persons may request a public hearing. The request must 

be made in writing to ,the contact listed below, and be received by DEQ by the last day of the comment p.eriod. In order to be considered, the request must include the, full name, address and telephone number of the peirson requesting the hearing and of all people represented by the requester. 

Tl)e request must also include: (i) the reason why' a public hearing is requested; (ii) a brief statement seitin'g forth the factual nature and extent of interest in the proposed permit, including how 

the operation of the facility affects the req!Jester; and (iii) specific references to 'applicable terms 

and conditions of concern as well as suggested revisions. 'A public hearing may be held as required 

by §10.1-1322.01 of state law if at least 25 requests are received in accordance with these procedures. Notice of the date, time, and location ot'any requested public hearing will be announced in 

a separate notice, and anotber 30-day comment period will be conducted. 

, . 

Federal public hearing procedure: Interested persons may request a public hearing. The request 

must be made'in writing to the contact Iisted'below, and be received by DEQ by the last day of the 

comment period. In order to be considered, ,the request must include the full name, address and 

telephone number of the person requesting the hearing and of all people represented by the 

requester. A public heating will be held as required by 40 CFR 51.1 02(a) if a request is received in 

acco'rdance with these 'procedures: Notice of t~e date, time, and location of any requested public 

hearins will be announced iri a separate notice, and another 30-day comment period will be conducted. " 

Permit name: State operating permit issued by DEQ, under the authority of. the State Air Pollution 

Control Board. . -

Name, address and registration number: 'MeadWestvaco Corporation Packaging Resources 

'Group, 104 East Riverside Street, Covington, VA 24.426; Registration No. 20328. ' 

"Description of proposal: The proposed revision consists of a permit to control emissions of sulfur 

dioxide (S02) to the atmosphere from the above-listed facility. 

In essence, the propo~ed revision will consist of a determination of reasonable progress for the 

control cif emissions of S02 to the atmosphere from the, tall stack located at the' MeadWestvaco ' 

mill. The reasonable progress determination is being made pursuant to 40 CFR 51.208(d) and to 

Article 5 (9VAC5-80-800 et seq.) of 9VAC5-80, Permits for Stationary Sources. Reasonable 

progress for 802 emissions from the, tall stack have been determined to be an additional 15% 

reduction in hourly and annual emissjons. ' 

A state operati,ng pe.rmit is to be issued as the administrative mechanism to ensure .compliance with 

reasonable progress requirements. The permit is being issued pursuant to Article 5 (9VAC5-80-800 

et seq.) of 9VAC5-80 (Permits for Stationary Sources) of state'regulations and is federally enforceable upon issuance. The permit win establish emission limits for cqntrol of S02. . 

Federal information: This notice ,is also being given to satisfy the public participation requirements 

of federal regulations (40 CFR 51.102). The permit will be sUb'mitted as a revision to the 

Commonwealth of Virginia SIP under §110(a) of the federal Clean Air Act in accordance with 40 

CFR 51,104. ' 

Consultation with federal land,managers (FLMs): As provided in 40 CFR 51.302(b)(2), the FLMs 

were given the opportunity to comment on this permit August 20, 2010. Comments were received 

on September 21, 2010. DEQ responded to the comments in a letter dated February 14, 2011: 

,\ .. How to comment: DEQ accepts written comments by email, fax, and postal mail. In order to be considered, written comments must include the full name, address and telephone number of the person commenting and be received by DEQ by the last day of the comment period. Due to problems -

, with the quality of faxes, commenters are encouraged to provide the signed original by postal mail 

within one week. All testimony, exhibits and docul1lents received are part of the public record. 

Please note this permit is beingcoricu~rently ,reviewed by EPA. 

To review proposal:'TtJe proposal and any supporting documents are available on the' DEQ Air 

PublJc Notices, for, Plans website (http://wwyv.deq.virginia.gov/air/permitting/planotes.html). The 

documents may also be obtained by contacting the DEQ representative named below. The public 

may review the ,documents between 8:30 am and 4:30 pm of each business day until the close of 

the public comment period at the. following DEQ locations: 1) Main Street Office, '8th Floor, 629 E. 

Main St, Richmond VA, 804-698-4070 a'nc;:l 2),Blue Ridge Regior;lal Office, 3019 ,Peters Creek Rd, 

Roanoke VA, 540-562"6700. 

,Contact ·for putJtic comments, document requests and additional information: Lillian Alexander, 

, Environmental Engineer, DEQ Blue Ridge Regional Office, 3019 Peters Creek Rd, Roanoke VA 

(phone 540-562-678~,. fax 540~562-6725, emaillillian.alexander@deq.virginia.gov). 
ENCLOSURE 3

PUBLIC PARTICIPATION RECORD

As required by 40 CFR 51.102(e), the complete record of testimony is located at the 

Department of Environmental Quality. The department contact to access this 

information is the Air Division. 

The state did not receive testimony on this particular revision.

TEMPLATES\SOURCE-SPECIFIC\PLN03

SRCESPEC\MEADWESTVACO2\MW2-SIP-3.DOC