Final December 201 0 

SlATE 01' WASI-IINGTON 

DEPARTMENT OF ECOLOGY 

PO Box •17600 o Olympia~ WA ~IJS04-7MW o .'160-•107-6000 

71 1 for Washington· Rd<ty Service o J>cr.mus with a speech disability can cal/ 877-iJJJ:..GJ41 

Octobei· 20,2010 

Mr. Roger Loney 

Port Townsend Paper Corporation 

P.O. Box 3170 

100 Mill Road 

Port Townsend, WA 98368 

Dear Mr. loney: · 

Regional I-Iaze Best Available Rctt·ofit Technology (BART) Determination 

Best Available Retrofit Technology (BART) is required to reduce the regional haze impacts of 

emissions of your facility. The enclosed Order #7839, Revision 1, contains our BART 

determination for your facility revised as· requested in your September 27, 2010 comtnents on the 

Washington Regional Haze Plan. 

The primary purpose of the revision is to allow substitution of the cw-rently required etnissions 

monitoring recordkecping and reporting procedures with methods that Ecology detennines 

would provide equal or better information on emissions and compliance status. The substituted 

~equirements have to be contained in a regulatory order issued by Ecology. 

The secondary purposes are to incorporate the revised n1onitoring and recordkeeping 

requirements contained in Order DE 05AQIS~2892, First Modification, and to substitute the new 

modified order for the now rescinded original order. 

Ecology considers these changes to be administrat~ve in nature. 

If you have questions or requests relating to this order, please contact Alan Newtnan at 

(360) 407~6810 or alan.ncwn1an@ccy.wa.gov .. 

Sincerely,· 

Jeff 

·Jib~ Johnston, Ph.D. 

Manager, Science and Engineering Section 

Air Quality Program 

AN:lb 

EnClosure 
Mr. Roger Loney 

· Page 2 of7 

October 20, 20 I 0 

cc: . Marc Heffner, Industrial Section 

Eveleen Muehlethaler, Port Townsend Paper 

Alan Newman, Ecology 

Cmmnenters on the proposed BART Order 

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L- 2~6 

Final December 201 0 
.STATE OF WASHINGTON 

DEPARTMENT OF ECOLOGY 

IN THEM "TEROF AN 

ADMfNTSTR TIVE ORDER AGAINST: 

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TO: Mr. Roger Loney 

Port Townsend Pap 

PO Box 3170 

100 Mill Road · 

Port Townsend, W A 983 

ORDER NO. 7839, 

Final December 2010 

This is an Administrative Order requiri your company to omply with WAC 173-400-15.1 by 

taking the actions that are described belo Chapter 70.9 RCW authorizes the Washington 

State Depm1ment of Ecology's Air Quality ·ogram (E logy) to issue Administrative Orders to 

requir~ compliance with the requirements of .94 RCW and regulations. issued to 

implement it. 

Ecology has determined that portions of your fa lit re subject to the provisions of the federal 

and state visibility protection program (WAC 3-400- 51 and 40 CFR Pm1 51, Subpart .P). The 

rules require that the State determine what t lmologies d level of en1ission control constitutes 

Best Available Retrofit Technology (BAR' for the eligib emission units at your facility. 

FINDINGS 

A. The Port Townsend Paper Corn ration (PTPC) is a Kraft pulp a d paper tuill subject to 

DART. 

B. The BART-eligible en1iss' n units at PTPC are the Recovery Furnace, the Smelt Dissolving 

c. 

Tank, the No. 1 0 Power oiler, and the Lime Kiln. 

units are controlled by: 

a. Use of an ele rostatic precipitator (ESP) to control PM/PM10 emissions fron1 

direct conta evaporator (NDCE) Recovery Fun1ace. 

et scrubber to control PM/PM10 and S02 emissions from the Smelt Disso 

c. of a multiclone and wet scrubber for control of PM/PM 10 emissions frmn the No. 10 

ower Boiler. 

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Final December 2010 

Port To nsend Paper Corporation 

BART Cm )liance Order #7839, Revision 1 

October 20, 2 0 

.. scrubber LO control PM/PMw and so2 emis . 

D. Ecology has detcnnined tha he emission controls currently · stalled at PTPC meet the 

requireJnents of BART. 

E. 

F. On September 27, 2010 Port Towns d Paper sub ·ted comments on the Washington State 

Proposed Regional Haze State In emcntation Plan. · - comments requested a revision to 

this Order to rencct the April , 2010 revision to Con~oh ·ted Order DE OSAQIS-2892 and 

to clarify that the compan ·ould choose to implement altcrna 'yes, such as continuous 

emission monitoring, t e cuncntly required EPA Reference od stack testing. This 

revision incorporat the company request. Ecology has reviewed t 1 request and concur 

that the changes re acceptable and nonsubstantive. 

nnation and analysis is available in the BART Determination Supp 

for Port T nsend Paper Corporation, Port Townsend, Washington, preptued by the shington 

State partment of Ecology, October 2008, and the Best Available Retrofit Technology 

icability Analysis and Deten11ination Report for Port Townsend Paper Corporation, Pm 

ownsend, Washington, prepared by Trinity Consultants on behalf of Port Townsend Paper 

Corporation, December 2007. 

YOU ARE ORDERED: To operate existing emission control equipment for the Recovery 

fmnace, Smell Dissolver Tank, Lime Kiln, and No. 10 Power 13oiler in accordance with the 

following conditions: 

l. BART Emission Litnitations 

1.1. Meet the emission limitations tor particulate matter, nitrogen oxides, arid sulfur dioxide 

found in Order DE OSAQIS-2892, First tvlodilication, issued to the Port Townsend Paper 

Corpora lion on April 20, 20 l 0, by the \Vushington State Department of Ecology's 

Industrial Section. 

1.2. Meet the S02 and NOxlimitations in PSD-l issued June 1, 1984. 

1.3. Compliance will be determined as specified in Order DE 05i\QIS··2892, First 

1\tloditication. 

2. Schedule for Compliance 

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Pmt Townsend Paper Corporation 

BART Compliance Order #7839, Revision 1 

October 20, 2010 

Final December 201 0 

Page 3 of4 

2.1. Compliance with the ctnission limitations for particulate matter, nitrogen oxides, and 

sulfur dioxide is required upon the effective date of this Order. 

3. Monitoring and Recordkeeping Requirements 

3.1. Monitoring and rccordkeeping requirements for particulate matter, nitrogen oxides, and 

sulfur dioxide arc contained in Order No. DE OSAQIS-2892, First Modification. 

4. Rcpmting Requirements 

4.1. Reporting requiretnents for particulate matter, nitrogen oxides, and sulfur dioxide arc 

contained in Order No. DE OSAQIS-2892, First Modification. 

Ecology may, by regulatory order, revise the monitoring, reporting and recordkeeR· 

equiren1ents specified in this order. The revised monitoring, reporting or reco ccping 

ods tnust provide equal or better information on the con1pliance status · the source or 

unit subject to the revised monitoring, reporting or recordkee · g methods. 

Failure to comply 'th this Order may result in the issuance of civi enalties or other actions, 

whether administrati vc judicial, to enforce the terms of this aer. 

0 

receipt" of this document. 

hours. 

o Serve your appeal on t )epartment of Ecology ithin 30 days of the "date of receipt" 

of this document. ·vice may be accmnplished by a of the procedures identified in 

(10). "Dale of receipt" is defined at R 43.21B.001(2). 

elude a copy of this document with your Notice of Appeal. 

Serve and 11lc your appeal in paper form; electronic copies are not accepted. 

To file your appeal with the Pollution Control Hearing Board: 

L- 219 
Po Townsend Paper Corporation 

BART pliance Order #i839, Revision 1 

October 20, 0 

lVIail appeal to: 

The Pollution Control Hearings Bo, · 

P.O. Dox 40903 

Olympia, W A 98504-0903 

To serve your appeal on the·De 

Mail appeal to: 

The Dcpar · ent of Ecology 

Appe, . Coordinator 

P . l3ox 4 7608 

Olympia, W A 98504-7608 

OR 

L- 220 

The Depar1ment of Ecology 

Appeals Coordinator 

300 Desmond Drive SE 

Lacey, WA 98503 

Final December 2010 
Port Townsend Paper Corporation 

BART Compliance Order #7839, Revision 1 

October 20, 20 I 0 · 

d send a copy of your appeal packet to: 

ewman 

Dcpartn nt of Ecology 

Air Qualit rogram 

P.O. Box 476 

Olytnpia, WA 98 4-7600 

For additional information, g 

http://www.cho. wa.gov. 

To find laws and agency rules, go to the Washingt 

http://vV\VW l.leg.wa.gov/CodeReviser. 

Final December 201 0 

Page 5 of4 

Your appeal alone will not slay the ef~ veness · ~this Order. Stay request~ n1ust be submitted 

in accordance with RCW 43.21B.J2 . These proccdt · s are consistent with 

Chapter 43.21 B RCW. 

DATED this 2Q_ day of t::.-kt:ev- , 20 ro at Olympia, Was . gton . 

. m,P~---- .Nlmr er, Science and Engineering Section 

parhnent of Ecology 

Air Quality Program 

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