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ANALYSIS FOR BEST A V AILABLE RETROFIT TECHNOLOGY ­

WAIVER REQUEST 


GP CONSUMER PRODUCTS LP 


MUSKOGEE MILL 


MARCH 2007 

GP Muskogee Mill BART Modeling Report 

March 27, 2007 

1.0 INTRODUCTION............................................................................................................. 1 


1.1. Overview of the Regional Haze BART Process ............................................................... 1 


1.2. Organization of the Report ........................ : ...................................................................... 3 


2.0 SITE DESCRIPTION AND EMISSION INVENTORy .............................................. 4 


3.0 CENRAP CONTRIBUTION TO CALPUFF MODELING ......................................... 7 


4.0 MODEL DISCUSSION .................................................................................................... 7 


4.1 General Procedures ...................................................................................................... 7 


4.2 CALPUFF Configuration............................................................................................. 8 


5.0 RESULTS AND DETERMINATION OF IMPAIRMENT........................................ 11 


5.1 Impact Threshold........................................................................................................ 11 


5.2 Presentation of Modeling Results .............................................................................. 11 


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1.0 INTRODUCTION 

1.1. Overview of the Regional Haze BART Process 

Under regional haze regulations, the Environmental Protection Agency (EPA) has issued 

final guidelines dated July 6, 2005 for Best Available Retrofit Technology (BART) 

determinations (70 FR 39104-39172). The regional haze rule includes a requirement for 

BART for certain large stationary sources, such as our pulp & paper facility in 

Muskogee, Oklahoma. Sources are BART -eligible if they meet three criteria concerning 

(1) potential emissions of visibility-impairing pollutants, (2) the date when the source 

was put in operation, and (3) whether they fall within one of the source categories listed 

in the guidance. The guidance requires a BART engineering evaluation using five 

statutory factors for any BART-eligible source that can be reasonably expected to cause 

or contribute to impairment of visibility in any Class I areas protected under the regional 

haze rule. (Note that, depending on the five factors, the evaluation may result in no 

controL) Air quality modeling is an important tool available to the States to determine 

whether a source can be reasonably expected to contribute to visibility impairment in a 

Class I area. 

The process of making a BART determination consists of four steps: 

1) Identify whether a source is "BART-eligible" based on its source category, when 

it was put in service, and the magnitude of its emissions of one or more "visibilityimpairing" air pollutants. The BART guidelines list 26 source categories of 

stationary sources that are BART-eligible. Sources must have been put in service 

between August 7, 1962 and August 7, 1977. Finally, a source is eligible for 

BART if potential emissions of visibility-impairing air pollutants are greater than 

250 tons per year. Qualifying pollutants include primary particulate matter (PMIO) 

and gaseous precursors to secondary fine particulate matter, such as S02 and NOx• 

VISTAS has determined that neither ammonia nor volatile organic compounds 

(VOCs) should be included as visibility-impairing pollutants for BART eligibility. 

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2) Detennine whether a BART-eligible source can be excluded from BART 

controls by demonstrating that the source cannot be reasonably expected to cause or 

contribute to visibility impainnent in a Class I area. The preferred approach is an 

assessment with an air quality model such as CALPUFF or other appropriate model 

followed by comparison of the estimated 24-hr visibility impacts against a threshold 

above estimated natural conditions to be detennined by the States. The threshold to 

detennine whether a single source "causes" visibility impainnent is set at 1.0 

deciview (dv) change from natural conditions over a 24-hour averaging period in 

the final BART rule (70 FR 39118). The guidance also states that the proposed 

threshold at which a source may "contribute" to visibility impainnent should not be 

higher than 0.5 dv although, depending on factors affecting a specific Class I area, 

it may be set lower than 0.5 dv. The test against the threshold is "driven" by the 

contribution level, since if a source "causes", by definition it "contributes". 

3) Detennine BART controls for the source by considering various control options 

and selecting the "best" alternative, taking into consideration: 

a) Any pollution control equipment in use at the source (which 

affects the availability of options and their impacts), 

b) The costs of compliance with control options, 

c) The remaining useful life of the facility, 

d) The. energy and non air-quality environmental impacts of 

compliance, and 

e) The degree of improvement in visibility that may reasonably be 

anticipated to result from the use of such technology. 

If a source agrees to apply the most stringent controls available to BART-eligible 

units, the BART analysis is essentially complete and no further analysis is 

necessary (70 FR 39165). 

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4) Incorporate the BART determination into the State Implementation Plan for 

Regional Haze, which is due by December 2007. 

Step 2 described above reflects 40 CFR Part 51 Appendix Y which states that, "You can 

use dispersion modeling to determine that an individual source cannot reasonably be 

anticipated to cause or contribute to visibility impairment in a Class I area and thus is 

not subject to BART." (70 FR 39162) This "individual source attribution approach" 

determines if a BART-eligible source (i.e., collection of eligible emission units at a 

source) is predicted to cause or contribute to visibility impairment in a Class I area. As 

inentioned above, a predicted impact of 1.0 dv change or more is considered to "cause" 

visibility impairment, and a predicted impact of 0.5 dv change or more is considered to 

"contribute". Any source determined to cause or contribute to visibility impairment in 

any Class I area is subject to BART and will also complete additional visibility impact 

analyses. 

1.2. Organization of the Report 

Section 2 presents facility-specific information. Section 3 presents the contribution by 

CENRAP for the BART analyses. Section 4 summarizes the modeling approach, and 

model configuration. Section 5 presents the criteria and processing of model results to 

demonstrate what impairment, if any, the facility is predicted to create in the Class I areas. 

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2.0 SITE DESCRIPTION AND EMISSION INVENTORY 

The facility is located in Muskogee, Oklahoma (Muskogee County). The Fort Howard 

Corporation began construction on the Mill in 1975. Georgia-Pacific (GP) acquired all of the 

stock of Fort James Corporation (including the Fort Howard Corporation subsidiary) in 

November 2000. The Muskogee Mill is a recycle deinking and bleaching paper Mill classified 

under the Standard Industrial Classification (SIC) code 2621. The Mill manufactures pulp from 

various grades of wastepaper. The Mill then processes the pulp through one of five paper 

machines to produce commercial and retail grades of tissue, toweling, and napkins. The Mill is 

also capable of using purchased virgin pulp in lieu of some or all of the wastepaper to make its 

products 

The facility is located in a moderately-developed area, and few light industrial areas near 

the Mill. The Mill is located along the Arkansas River near Chandler Road. The area 

surrounding the facility includes a creek floodplain, and low-lying land. Figure 1 depicts 

the location of the Mill and illustrates the adjacent terrain. The potentially BART -eligible 

emission units are summarized in Table 1. The two boilers exhaust through a common 

stack. 

Table 1. Model Parameters for Potentially BART-Eligible Sources at GP Muskogee 

Source Description 

Ht 

(m) East 

(km) 

North 

Diameter 

(m) 

Exit 

Velocity 

(m/sec) 

Exit 

Temp 

( K) 

Boiler 1 and 2 Combined Stack 79.3 152.7 -469.211 3.05 13.2 410.93 

The combustion sources currently operate with a variety of fuels as stated below: 

• Package Boiler No.1 conibusts only natural gas. 

• Power Boiler No.2 is permitted for bituminous and sub-bituminous coal. 

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Figure 1. Area Topographic Map for Muskogee, OK 


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€ 

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~ 

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3952000 

I I r 

286000 287000 288000 289000 290000 291000 292000 293000 294000 295000 296000 297000 298000 299000 300000 


UTM Easting (m) 

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GP Muskogee Mill BART Modeling Report 

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The modeling analysis applied one change to the existing permitted operations. While 

Package Boiler No.1 is often used only as a stand-by boiler, the analysis assumed the 

boiler would operate continuously with a new Low-NOx burner. The NOx emission rate 

is limited to 0.1 IblMMBtu at a maximum firing rate or 31 lbs NOx/hr. 

The Mill reserves the right to shut down an emission unit in lieu of the proposed emission 

controls. For example, as we await regulatory approval of the Oklahoma SIP or approval 

of a determination, should shutting down Package Boiler No. 1 be preferred, we would 

remove all emissions from the unit and request a waiver without any further requirement 

on Boiler 2. 

Table 2 presents the available fuel-specific speciation profiles and worst case 24-hr actual 

emissions applying these assumptions. 

Table 2. Summary of Modeled Emission Rates, GP Muskogee 

Model Source 

Parameter Package Boiler 1 Power Boiler 2 

CALPUFF Input (lb/hr) 

S02 0 288.0 

S04 0 8.7 

NOx 31 193 

NH3 0 0.013 

PMC 0 2.33 

PMF 0 1.79 

EC 0 0.08 

SOA 0 2.16 

The Class I Areas (where visibility is an air quality related value) within 300 kilometers 

(km) of the Mill are: 

• Upper Buffalo National Wilderness Area (NW A), 166 km northeast of the Mill; 

• Caney Creek NW A, 178 km east of the Mill; and 

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• 	 Hercules-Glades NWA, 233 km northeast of the Mill. 

• 	 Wichita Mountains NW A nearly 300 km west of the Mill 

3.0 CENRAP CONTRIBUTION TO CALPUFF MODELING 

For this application of BART Modeling, CENRAP and ODEQ have the following data 

bases developed by TRC available: 

• 	 Compiled version of the CALPUFF modeling system, provided directly from 

Kansas Department of Health and Environment ("VISTAS" version) 

• 	 6-km CALMET output files for 2001,2002, and 2003 produced as described 

in the CENRAP Common Protocol. 

• 	 Background ozone files suitable for CALPUFF v.5.7.11. 

4.0 MODEL DISCUSSION 

4.1 General Procedures 

For sources subject to a full BART engineering analysis, GP is beginning with the most 

refined dataset available from CENRAP. The fine grid analyses will use both the highest 

impact value for the 24-hr average at each Class I area. 

The CENRAP Common Modeling Protocol consistently recommends conservative 

assumptions. Individual States ultimately have responsibility to determine which, if any, 

BART controls are recommended in their State Implementation Plans (SIPs). The 

CENRAP protocol presents additional detailed information on the meteorological fields, 

and specific settings for CALPUFF and CALPOST. 

The analysis was performed in the following sequence for 2001, 2002 and 2003 

indi viduall y: 

Step 1. Produce raw concentration files by executing CALPUFF for the two emission 

units individually with the following 10 species: 

1. 	 S02 

2. 	 S04 

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3. NOx 

4. HN03 

5. N03 

6. NH3 

7. PMC 

8. PMF 

9. EC 

10. SOA 

Step 2. Execute CALPOST for each of the four Class I Areas with the total concentration 

file from Step 1. 

CALPOST result filenames use the "PS" prefix. 

Step 3. Import the CALPOST result file input the New IMPROVE Excel spreadsheet 

provided by VISTAS. Step 5 is only applied to CALPOST result sets showing a 

maximum value greater than 0.5 dv. 

4.2 	 CALPUFF Configuration 

Source emissions should be defined using the maximum 24-hour actual emission rate 

during normal operation for the period 2001-2003. If maximum 24-hr actual emissions 

are not available, continuous emissions data, permit allowable emissions, potential 

emissions, and emissions factors from AP-42 source profiles may be used as available. 

Specific configuration settings presented in the CENRAP Common Modeling Protocol 

are listed below: 

• 	 Use default data provided by CENRAP for background concentrations of S04 and 

total N03(HN03+ N03). 

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• 	 Use hourly ozone data as the background ozone input as prepared by CENRAP. 

(Note that the format for the data is only compatible with CALPUF 5.7.l1a, not 

the "VISTAS" version of CALPUFF) 

• 	 Use the Pasquill-Gifford dispersion method. 

• 	 In CALPOST, use Method 6 with monthly average RH for calculating extinction, 

as recommended by the EPA. 

• 	 Use EPA default calculations of light extinction under average background 

conditions. 

The major features and options of the meteorological and dispersion model are 

summarized and discussed in the CENRAP Common Modeling ProtocoL 

As also discussed in the CENRAP Common Modeling Protocol, CALPUFF is currently 

not recommended for addressing visibility impacts from VOC because its capability to 

simulate secondary organic aerosol formation from VOC emissions is not adequately 

tested, especially for anthropogenic emissions. (Separately, condensable organic carbon 

can be calculated from PMlO.) 

GP completed the analysis with the south domain 6-km meteorological datasets provided 

by CENRAP. Figure 2 presents the modeling domain, the Class I Area model receptors 

and Muskogee Mill. 

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GP Muskogee Mill BART Modeling Report 

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CENRAP South 6 km Modeling Domain with GP Mill and Class I Areas Within 300 km 

Hercules-Glades 

-200 

GPMILL 

Upper Buffalo ..

1 


Wichita Mtns 

Caney Creek 

E 

~ -800 .c: 

1::: 

o 

Z 

o 

o -1000 ~ ~ 

-1200 

- -1 -1400 ­

Terrain (m) 

-1600 

-1000 -800 -600 -400 -200 

LCC East (km) 

200 400 600 800 

I 


o 

4500 


3900 


3700 


3500 


3300 


3100 


2900 


2700 


2500 


2300 


2100 


1900 


1700 


1500 


1300 


1100 


900 


700 


500 


300 


100 


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5.0 RESULTS AND DETERMINATION OF IMPAIRMENT 

5.1 Impact Threshold 

The final BART guidance recommends a threshold value of 0.5 dv change from natural 

conditions to define whether a source "contributes" to visibility impairment(although 

states may set a lower threshold) .. The 98th percentile (8th highest annual) 24-hr average. 

predicted impact at the Class I area, as calculated using CALPOST Method 6 (monthly 

average relative humidity values), is to be compared to this contribution threshold value. 

For this comparison, the predicted impact at the Class I area on any day is taken to be the 

highest 24-hr average impact at any receptor in the Class I area on that day. (Note that the 

receptor where the highest impact occurs can change from day to day.) According to 

clarification of the BART guidance presented in the final CENRAP modeling protocol, 

for a three-year simulation the modeling values to be compared with the threshold are the 

greatest of the three maximum values over all three years. CALPUFF presents the 

visibility change in both a % change and a dv change form. 

5.2 Presentation of Modeling Results 

Table 3 summarizes the CALPOST result for the highest predicted % change for each 

year and each Class I Area. In addition to the highest change in deciview value on each 

day over all the receptors in a particular Class I area, the CALPOST summary table in 

Table 3 contains the coordinates of the receptor, receptor type (D indicates discrete 

receptors), the total haze level (background + source, in dv), the background haze in 

deciviews, the change in haziness (delta dv), the humidity term applied to hygroscopic 

aerosols (F(RH)), and the contribution of each species to light extinction (in percent of 

the total source contribution) for S04, N03, organics, elemental carbon, coarse and fine 

particulate matter. 

As shown, the maximum predicted impact for all datasets is below the 0.5 dv criteria. 

The new IMPROVE equation was not applied to any model result. 

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Table 3. Maximum Predicted Visibility Impact for 2001-2003, GP Muskogee Mill 

Model Year Model Year 

I Area 

Julian Day 

Receptor # 

Delta dv 

2001 

286 

18 

0.33 

2002 

Caney Creek 

309 

52 

0.47 

60 

67 

0.49 

2001 2002 2003 

Hercules-Glades 

348 309 61 

161 161 147 

0.37 0.35 0.24 

Class I Area UEEer Buffalo Wichita Mountains 

Julian Day 348 302 314 309 302 314 

Receptor # 175 239 239 288 289 282 

Delta dv 0.37 0.36 0.31 . 0.11 0.47 0.34 

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