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 1 1 05, Richmond, Virgin i a 23218 TDD (804) 698402 1 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 Resource s 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 a mounts 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, natio nal 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 (f ederal c lass 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 statethat 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 wh ich 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 Commissi on.
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.

V isibility is specifically addressed in 40 CFR 51.166 (o) , a dditional 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 f ederal c lass 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 reg ional 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 th at 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 visibil ity 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 P art 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 Pack aging Resource s 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

. M eadWestvaco's BART permit was issued on February 23, 2009 to control the following visibility impairing pollutants: nitrogen oxides ( NO X 

### )

, particulate matter ( PM 10 

### ), and sulfur dioxide ( SO 2 

### ).

In a ddition 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 determine d the potential for the MeadWestvaco facility's SO 2 

### 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% SO 2 

### reduction could be achieved from the current BART SO 2 

### 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 condit ions of the permit , including the determination and analysis to support the reasonable progress determination for the control of the specific visibility

-

### impairing pollutant ( SO 2 

### ) 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 \ PLN 01 SRCESPEC \ MEADWESTVACO 2\ MW 2- SIP -1 .DOC

### ATTACHMENT A

LEGALLY ENFORCEABLE MECHANISM (PERMIT) TO ENSURE COMPLIANCE WITH REASONABLE PROGRESS REQUIREMENTS FOR

MeadWestvaco Corporation Packaging Resource s Group

Alleghany County , Virginia

Registration No. 20328
Under the authority provided in 9VAC5

- 170

- 180 and Section I I of Agency Policy Statement No. 3- 200 6 (dated October 20, 200 6) , 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) 

### = standbyMeadWestvaco 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 Resource s 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 Resource s 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) Y 1 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 PM 10 SO 2 NO X 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 SO 2 NO X CO VOC PM PM 10 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 BART 2



### - eligible equipment and was issued a BART permit on February 23, 2009 to control the following visibility

impairing pollutants : NO X 

### , PM 10 

### and SO 2 

### . Th is permit action is board-initiated for the purpose of further reducing SO 2 

### emissions and to demonstrate r easonable p rogress 3

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 pr ogress” 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 iss ued for the facility and will become a part of the State Implementation Plan (SIP) after approval. DEQ p rocedures 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 p rogress is a required element of Virginia’s SIP even though Virginia is surpassing visibility improvement benchmark s as indicated by the glide path 4



### . State s included in VISTAS 5 

### determined that the pollutant of concern for r easonable p rogress is SO 2 

### . 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 s tate borders, were not electrical generating units (EGUs) subject to the Clean Air Interstate Rule (CAIR), and had feasible control options for SO 2 

### emissions. DEQ identified the Tall Stack 6 

### 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 tak e into account expected SO 2 

### emission reductions resulting from a variety of programs. These programs include, but are not limited to, clean fuel requiremen ts, 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 SO 2 

### emissions of approximately 9,997 tons 7 

### 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 v isibility 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% SO 2 

### red uction from the (then) proposed BART SO 2 

### 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 SO 2 

### emission lim it for the Tall Stack is 6,817 t py

.

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 T he 9,997 tons does not take into account BART emission limits that were imposed in 2009. The BART SO 2 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 SO 2 

### 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: 98 th 

### Percentile Deci view (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 T all S tack :
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

SO 2 

### emissions from the se 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% SO 2 

### reduction. Due to the unique configuration of the scrubbers, it was not possible to impose a practicably enforceable limit for SO 2 

### on the No. 9 Power Boiler alone , the only BART -eligible equipment of this group. Consequently, the BART emission limit encompasse s all four boilers and resulted in a 1,112.3 tpy reduction 8 

### in allowable SO 2 

### 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 t py Proposed reasonable progress limits 1,556 lb/hr (annual avg.) 6,817 t py 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 SO 2 

### 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 reasona ble 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. D aily emission totals will be combined to demonstrate compliance with the t py 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) se ts 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 stra tegies, 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 c onsistent 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 PM 2.5 

### 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 compl iance 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 M WV 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 Cla ss I Areas – Shenandoah National Park and James River Face Wilderness Area.” The following is a synopsis of the approa ch DEQ used to determin e the sources where a reasonable progress review was appropriate:

**•** Species contribution assessments on the 20% worst visibi li ty days for all Class I areas in the Southeast concluded that sulfate accounts for greater than 70% of the visibility impa iring pollution. Based on this information, DEQ concluded that controlling SO 2 

### 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 SO 2 

### emissions inventory. Therefore, DEQ concluded that source sectors evaluated for reasonable progress should be EGU and non- EGU po int SO 2 

### 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. C AIR 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 project ed visibility improvements are not being achieved by Virginia’s Class I areas, this expectation may be reexamined prior to 2018.

**•** DEQ calculated the f r actional contribution from all emission units within the SO 2 

### area of influence for Virginia’s Class I areas and also for surrounding states’ Class I areas. Non

EGU 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 SO 2 

### 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 SO 2 

### 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 th e Tall Stack, including Boiler #9, which was already subject to BART. The permit requiringMeadWestvaco 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. M WV 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 Impact 1



### $/ton Incremental Cost Impact Comments $/ton 2 

### $/dv 3

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 SO 2 

### 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 SO 2 

### ). 3 

### Incremental $/dv costs for visibility improvements beyond those achieved through the BART limitations of 1,8 31 lbs SO 2 

### /hr and 8,050 tpy SO 2 

### .

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 SO 2 

### 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 existin g 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 dr yer options.

C ost effectiveness is only one aspect that must be considered f or 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 belowMeadWestvaco 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 t py SO 2 

### . 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, t hese 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 SO 2 

### emissions, resulting in a federally enforceable limit of 6,817 tpy SO 2 

### , 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.

Exhib it 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 YearHaziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 PredictionMeadWestvaco 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, d v * Expected Visibility by 2018, d v 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 d v Δ 10.8

3.1 20% BD 10.9 8.8 8.7 Δ 2.2 d v --- James River Face Wilderness Area 11.1 20% WD 29.1 22.6 22.4 Δ 6.7 d v Δ 11.0

4.4 20% BD 14.2 12.5 12.4 Δ 1.8 d v --- 

### *WD=worst day, BD=best day

Based on this information, DEQ proposes that improvements to the existing scrubber s on the Tall Stack resulting in emission rates of 1,556 lbs SO 2 

### /hour and 6,817 t py SO 2 

### constitute reasonable progress for the Tall Stack for this round of regional haze planning. This determi nation is based on the following:

**•** The sig nificant capital investment necessary for the construction of a wet scrubber or spray dryer;

**•** The incremental cost effectiveness o f either a wet scrubber or spray dryer over the costs associated with improvements at the existing wet scrubber;

**•** The significan t 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 YearHaziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 PredictionMeadWestvaco 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 pro gress requirements ;

**•** S uggestions 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 thi s 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

V isibility impairment modeling for NO X 

### , PM 10 

### and SO 2 

### 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 t his 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 t itle 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 specificMeadWestvaco 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 SO 2 

### 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 FLM s 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 Virginia n Review on March 28, 2011. The notice expired on April 28, 2011 with one comment received 11 

### 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 SO 2 

### 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 Resource s 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 a ttached.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 SO 2 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 w ere 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.govFrom: 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 Meadwestvaco 

### Link

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 SO 2 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 forMs. 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 , 20 11.
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 commen t is located at the Air Division of the Department of Environmental Quality. The d epartment contact to access this information is the Director, Air Division . A summary of the testimony received and responses thereto is attached.

COMPLIANCE WITH STATE A DMINISTRATIVE 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 \ MEADWESTVACO 2\ MW 2- 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~** ,

.... ',;.., • ..Jo.**....'-:...:'":!.,~.i~;;** ... " .•**:'!.;(;,;.;.:.:~!: "~,,):,"!-r~;""";;l**  ...**)t!l:·~','!: ·.3.~.;** **;.~-·!.·u..:.."'" "i~:,1'**  .... ,;"

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

...**:"~~~~** .. _- ...**'~~--:-.~'.':-',** . :,-,:"**-~·~·""·"-···~-···r--r;·--:-~.7~-:.,~::::·** .. -·,'**~-~-.- L,~{-**  .. ;' .;; ,"**;~.** . '.

, '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 d epartment contact to access this information is the Air Division

.
The state did not receive testimony on this particular revision.

TEMPLATES \ SOURCE

- SPECIFIC \ PLN03 SRCESPEC \ MEADWESTVACO 2\ MW 2- SIP

- 3.DOC