Georgia Department of Natural Resources,

Air Protection Branch Files

Inland Paperboard and Packaging –

Rome Linerboard Mill

Excerpt from Permit Review for Permit No. 2631-115-0021-V-01-4Prevention of Significant Air Quality Deterioration Review Of Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill Located in Floyd County, Georgia

PRELIMINARY DETERMINATION SIP Permit Application No. 14756

July 2004

State of Geo rgia Department of Natural Resources

Environmental Protection Division

Air Protection Branch

Stationary Source Permitting Program

(SSPP)

Prepared by

Heather Cottrell

–

Chemicals Unit

Modeling Approved by: Jim Stogner Data and Modeling Unit

Reviewed a nd Approved by:

David M. Matos

–

Acting Chemicals Unit Coordinator

John Yntema

–

Acting SSPP Manager

Heather Abrams

–

SSPP Manager

Ron Methier

–

Chief, Air Protection BranchSUMMARY

................................................................................................ ...................................................................................... i

1.0 INTRODUCTION

................................................................................................ ......................................................... 1

2.0 PROCESS DESCRIPTION

................................................................................................ ........................................ 1

3.0 REVIE

W OF APPLICABLE RULES AND REGULATIONS

........................................................................ 3

State Rules

................................................................................................ ......................................................................... 3

Federal Rule

- PSD

................................................................................................ .......................................................... 4

Federal Rule

– 40 CFR 60 Subpart Db

......................................................................................................................... 6

Federal Rule

– 40 CFR 60 Subpart BB

........................................................................................................................ 6

Federal Rule

– 40 CFR 61 Subpart E

........................................................................................................................... 6

Federal Rule

– 40 CFR 63 Subpart S

............................................................................................................................ 7

Federal Rule

– 40 CFR 63 Subpart MM

...................................................................................................................... 7

Federal R ule

– 40 CFR 63 Subpart DDDDD

.............................................................................................................. 8

State and Federal

– Startup and Shutdown and Excess Emissions

.......................................................................... 8

Federal Rule

– 40 CFR 64

- Compliance Assurance Monitoring

............................................................................. 8

4.0 CONTROL TECHNOLOGY REVIEW

................................................................................................................. 9

Summary

– Control Technology Review for PM from Recovery Furnace 5

...................................................... 10

Summary

– Control Technology Review for CO from Recovery Furnace 5

...................................................... 11

Summary

– Control Technology Review for VOC from Recovery Furnace 5

................................................... 12

Summary

– Control Technology Review for TRS and H 2 S from Recovery Furnace 5

..................................... 14

Summary

– Control Technology Review for PM from Po wer Boiler 4

............................................................... 15

Summary

– Control Technology Review for CO from Power Boiler 4

............................................................... 16

Summary

– Control Technology Review for VOC from P ower Boiler 4

............................................................ 17

Summary

– Control Technology Review for PM from the Waste Fuel Boiler

................................................... 18

Summary

– Control Technology Review for CO from the Waste Fuel Boiler

................................................... 20

Summary

– Control Technology Review for VOC from the Waste Fuel Boiler

................................................ 21

Summary

– Control Technolog y Review for TRS and H 2 S from Waste Fuel Boiler WF

................................ 21

Summary

– Control Technology Review for PM from Package Boiler 2

............................................................ 22

Summary

– Control Technology Review for CO from Package Boiler 2

............................................................ 23

Summary

– Control Technology Review for VOC from Package Boiler 2

......................................................... 24

Summa ry

– Control Technology Review for VOC Linerboard Machines P1 and P2

....................................... 26

5.0 TESTING AND MONITORING REQUIREMENTS

....................................................................................... 26

6.0 AMBIENT AIR Q UALITY REVIEW

................................................................................................................... 30

7.0 ADDITIONAL IMPACT ANALYSES

.................................................................................................................. 35

8.0 EXPLANATION OF DRAFT PERMIT CONDITIONS

................................................................................. 36PSD Preliminary Determination Page i

SUM MARY

The Environmental Protection Division (EPD) has reviewed the Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill application for a permit for the construction and operation of modifications at their facility in Rome, Georgia (Floyd County). The project involves the completion of modifications necessary to reduce the mill’s energy costs, improve reliability of the mill boilers, and increase the mill’s production to 2,600 machine

- dried tons per day (MDTPD) of linerboard.

The proposed project includes the permanent shutdown of Power Boilers 1, 2, and 3, Lime Kiln 3A, Recovery Furnace 4, Smelt Dissolving Tanks 3 and 4, and the H

- washer. The facility will also convert existing Recovery Furnace 3 to Waste

Fuel Boiler WF and install fuel oil load bearing guns on Recovery Furnace 5 and Package Boiler 2. The mill also plans to make modifications to the Recovery Furnace 5 combustion air and black liquor supply system in order to increase the firing rate of the unit to 5.3 million pounds of black liq uor solids (BLS) per day. The mill also plans several modifications to Power Boiler 4 including the replacement of the steam generating bank, other steam tube system replacements, and the upgrade of the burners on the unit to low NO

x burners. Finally, sm

all modifications (the replacement of the primary headbox on Linerboard Machine P2 and the inlet piping to the Linerboard Machine P1 primary headbox) are planned for the paper machines in order to improve their performance. A steam saving project is also planned for the F Evaporator set.

Proposed Waste Fuel Boiler WF (converted to Recovery Furnace 3) is designed to combust wood residue, waste wood, No. 2 fuel oil, used oil, tire derived fuel, wastewater sludge, recycle fiber waste, HVLC NCGs, and recovere d boiler ash and will be rated at 856 MMBtu per hour. The facility will use a dry plate electrostatic precipitator to control emissions from this source. Inland will be installing and operating continuous emissions monitoring systems (CEMS) for CO, SO 2 , and NO X and a continuous opacity monitoring system (COMS) as part of this project.

Recovery Furnace 5 is designed to process black liquor and combust low sulfur fuel oil. New load bearing guns will allow the facility to operate the unit at a capacity of 850 MMBtu per hour in order to supply sufficient process steam when needed. Black liquor solids capacity will be 1325 MMBtu per hour. The facility is required to install and operate a furnace oxygen monitor for this unit.

Package Boiler 2 is currently p ermitted to burn only natural gas and to operate in a backup capacity to the Power Boilers and Recovery Furnaces. Inland has proposed that the unit become a full time steam source and, as a result, it is necessary to install load bearing oil guns. The un it will have a capacity of 192 MMBtu per hour when firing oil. Inland will be required to install and operate a COMS and a furnace oxygen monitor for this unit.

Power Boiler 4 is currently permitted to burn coal and No. 5 fuel oil. Following the propose d modification the unit will burn only low sulfur coal and low sulfur fuel oil. Inland will install and operate a CEMS for NO X and a furnace oxygen monitor as a result of this project.

The Rome Linerboard Mill is located in Floyd County, which is classif ied as “attainment” or “unclassifiable” for SO 2 , PM 10 , NO X , CO, and ozone (VOC) in accordance with Section 107 of the Clean Air Act, as amended August 1977.

The EPD review of the data submitted by Inland related to the proposed modifications indicates tha t the project will be in compliance with all applicable state and federal air quality regulations.

It is the preliminary determination of the EPD that the proposal provides for the application of Best Available Control Technology (BACT) for the control of PM 10 , CO, VOC, TRS, and H 2 S, as required by federal Prevention of Significant Deterioration (PSD) regulation 40 CFR 52.21(j).

It has been determined through approved modeling techniques that the estimated emissions will not cause or contribute to

a viola tion of any ambient air standard or allowable PSD increment, either in the area surrounding the facility or the nearby Class I area. It has further been determined that the proposal will not cause impairment of visibility or detrimental

effects on soils o

r vegetation. Any air quality impacts produced by project

- related growth will be inconsequential.

This Preliminary Determination concludes that an Air Quality Permit be issued to Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill for the reque sted modifications. Various conditions have been incorporated into the current Title V operating permit to ensure and confirm compliance with all applicable air quality regulations. A copy of the draft permit amendment is included in Appendix A.PSD Preliminary Determination Page 1 of 49

1.0 INT RODUCTION

On October 6, 2003, Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill (Inland) submitted an application for an air quality permit for modifications to several units at the plant. The facility is located at 238 Mays Bridge Road, Rome (Floyd County), Georgia. The application was updated in April 2004 as a result of a detailed engineering analysis. The project involves the completion of the modifications necessary to reduce the mill’s energy costs, improve reliability of the mill boile rs, and increase the mill’s production to 2,600 machine

- dried tons per day (MDTPD) of linerboard.

The Inland mill is currently classified as a “major” source under the PSD definition of major source because it has the potential to emit more than 100 tpy o f regulated air pollutants and is one of the listed 28 source categories. Thus, the project is subject to a PSD review for those pollutants whose emissions will increase above the corresponding PSD Significant Levels.

PSD regulations require that emissio n increases be calculated based on the difference between past actual emissions (in this case, the average for the two year period from 2001

- 2002) and the potential

- to

- emit at the maximum mill capacity of 2,600 MDTPD. The estimated incremental increases o f regulated pollutants from the mill are listed in

Table 1.

Table 1: Emissions Increases from the Project

Pollutant Potential Emissions Increase / (Decrease)
tpy PSD Significant Levels
tpy Subject to PSD

Review

PM 10 288 15 Yes

PM 288 25 Yes

SO 2 39.0 40 No

NO X (119) 40 No

CO 643 100 Yes

VOC 864 40 Yes

TRS 84 10 Yes

H 2 S 23 10 Yes

Pb 0.123 0.6 No

H 2 SO 4 0.72 7.0 No

Be (2.08 x 10 - 4 ) 4.00 x 10 - 4 No Hg 7.35 x 10 - 3 0.10 No

The net increases were calculated by subtracting the past actual emissions (b ased upon the annual average emissions from 2001 and 2002) from the future potential emissions. The emissions calculations for proposed modifications can be found in detail in the facility’s PSD submittal (see Appendix A of Application No. 14756). These calculations have been reviewed and approved by the Division.

Based on the information in Table 1, Inland’s proposed modification, as specified per Georgia Air Quality Permit Application No. 14756, is classified as a major modification under PSD because t he potential emissions increases of

PM/PM 10 , CO, VOC, TRS, and H 2 S exceed the PSD significant levels.

Through its new source review (NSR) procedure, EPD has evaluated Inland’s proposal for compliance with State and Federal requirements. The findings of E PD have been assembled in this Preliminary Determination.

2.0 PROCESS DESCRIPTION

On October 6, 2003, Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill (Inland) submitted an application for an air quality permit for modifications to several un its at the plant. The application was updated in April 2004 based on a detailed engineering analysis. The facility is located at 238 Mays Bridge Road, Rome (Floyd County), Georgia. The goal of the project is to provide the mill with a more reliable sour ce of steam and to reduce operating costs. When the project is complete, the mill’s maximum production capacity on an annual basis is expected to be 2,600 MDTPD of linerboard. To meet this production, the paper machine will be fed a combination of recycl e and virgin fiber. The maximum virgin production capacity for the mill is expected to be 2,500 air

- dried tons per day (ADTPD) and the maximum production capacity of the recycle fiber plant will be 650 oven dried tons per day (ODTPD).PSD Preliminary Determination Page 2 of 49

Currently, heavy b lack liquor is burned in three recovery furnaces. The organic portion of the heavy black liquor burns and generates steam for use in the mill. The inorganic chemical component, which consists mostly of sodium carbonate and sodium sulfide, is recovered as smelt from the bottom of the furnace. The most significant change in the recovery system will be the decommissioning of Recovery Furnace 4 and the conversion of Recovery Furnace 3 to a Waste Fuel Boiler. With these changes the mill will operate a single recovery furnace (No. 5). The mill will need to modify Recovery Furnace 5 to handle a slightly higher liquor feed rate in order to continue operating the mill at current virgin pulp production levels. With these modifications the production capacity of Recovery Furnace 5 will be 5.3 million pounds of black liquor solids per day (mmlbBLS/day). The final design changes are expected to include the following:

• Combustion air modification which may include increased size of secondary and tertiary air fans an d a new tertiary air fan for controllability;

• Modification of the superheater section to reduce pressure drop and heat flux;

• Upgrade of fuel oil delivery system;

• Upgrade of black liquor delivery system;

• Potential upgrade of the Smelt Tank 5 scrubber system ;

• Combustion air modifications which may include modifications to the size, numbers, and arrangement of secondary and tertiary air ports; and

• Installation of a larger cold air fan to supply secondary and tertiary air ports to improve control of furnace.

R ecovery furnaces perform two functions: chemical recovery and steam generation. At times, the mill has insufficient black liquor to meet the mill’s steam demands (primarily during extended startups or shutdowns). During these times the mill will fire ver y low sulfur fuel oil (< 0.5% sulfur fuel oil) in Recovery Furnace 5. The furnace currently has burners for the purpose of the startup of the unit and for steam generation, however the new burners will allow the unit to operate at full steam production on just fuel oil. The fuel oil burners have a firing rating of 850 MMBtu/hr.

The smelt from the recovery furnace combines with water in the smelt dissolving tank to form green liquor. With the proposed changes, the Smelt Tanks 3 and 4 will be decommission ed.

The proposed project also calls for the decommissioning of Lime Kiln 3A. The load currently carried by Lime Kiln 3A will be shifted to Lime Kilns 1A and 2A. The other equipment associated with Lime Kiln 3A (causticizing, slaking, and white liquor cl arification) may continue to be utilized by the mill. The lime kilns are currently utilized to burn the low volume high concentration (LVHC) non

- condensable gases (NCGs). These gases will continue to

be combusted in Lime Kiln 1A or 2A.

The proposed proj

ect calls for the decommissioning of the Power Boilers 1, 2, and 3. In addition, Recovery Furnace 3 will be converted to a fluidized bed Waste Fuel Boiler. The waste fuel boiler will fire bark, wood waste, No. 2 fuel oil, used oil, waste water sludge, ti re derived fuel (TDF), recycle fiber plant waste and ash, and will be rated at 856 MM Btu/hr. The mill may route the high volume low concentration (HVLC) NCGs, which are required to be collected by Phase II of the Cluster Rule (40 CFR 63 Subpart S), to th e Waste Fuel Boiler. Alternatively, the mill may complete other modifications to achieve equivalent HAP emission reductions under the Clean Condensate Alternative provisions in 40 CFR 63 Subpart S. PM emissions from the Waste Fuel Boiler will be control ed through the use of the existing electrostatic precipitator (Source Code ESP3), which currently controls emissions from Recovery Furnace 3. A new cell and corresponding stack will be added to Source Code ESP3 in order to provide sufficient control of P M emissions.

The mill currently operates a natural gas fired package boiler (Package Boiler 2). The unit is currently used as a

back

- up boiler that operates only when one of the existing power boilers or recovery furnaces is not in operation. With the p roposed changes, the mill will operate the unit as a base load boiler. In addition, the mill will be installing fuel oil firing capability in the Package Boiler in order to provide additional fuel firing flexibility. The

unit will fire No. 2 fuel oil an d used oil with a sulfur content less than 0.5% sulfur.

The project also calls for modifications to Power Boiler 4. The boiler is aging and requires the replacement of several steam tubes including the entire steam generating bank. These steam tube chan ges may allow for an increase in the unit’s overall steam generating efficiency. In addition, the coal burners will be upgraded to low NO

x burners with a total heat input rating of 565 MMBtu/hr. Boiler management controls will also be upgraded.PSD Preliminary Determination Page 3 of 49

Small mo difications are planned for the paper machines in order to improve their performance. The modifications include the replacement of the inlet piping to the Linerboard Machine P1 primary headbox and the primary headbox

on the Linerboard Machine P2.

A steam savings project will be completed for the F Evaporator Set. The project includes modifications to the flash tank and the addition of a heat exchanger. The plant will also re

- pipe so the evaporator set can receive steam directly from a boiler rather than from the concentrator. The modifications are not being performed to increase liquor processing capacity.

3.0 REVIEW OF APPLICABLE RULES AND REGULATIONS

State Rules

Georgia Rule for Air Quality Control (Georgia Rule) 391

- 3

- 1

- .03(1) requires that any pe rson prior to beginning the construction or modification of any facility which may result in an increase in air pollution shall obtain a permit for the construction or modification of such facility from the Director upon a determination by the Director tha t the facility can reasonably be expected to comply with all the provisions of the Act and the rules and regulations promulgated thereunder. Georgia Rule 391

- 3

- 1

- .03(8)(b) continues that no permit to construct a new stationary source or modify an existing stationary source shall be issued unless such proposed source meets all the requirements for review and for obtaining a permit prescribed in Title I, Part C of the Federal Act [i.e., Prevention of Significant Deterioration of Air Quality (PSD)], and Secti on 391

- 3

- 1

- .02(7) of the Georgia Rules (i.e., PSD).

Georgia Rule (b) [391

- 3

- 1

- .02(2)(b)] is a general rule that limits the opacity of emissions from any air contaminant source to less than 40%. Georgia Rule (b) applies to Recovery Furnace 5, Power Boiler 4, Package Boiler 2, and Waste Fuel Boiler WF. The 40% opacity limit is subsumed by more stringent opacity limits for Recovery Furnace 5, Package Boiler 2, and Waste Fuel Boiler WF under 40 CFR 60 Subpart BB, 40 CFR 60 Subpart Db, and 40 CFR

52.21. The opacity from all four boilers will be monitored using a COMS.

Georgia Rule (d) [391

- 3

- 1

- .02(2)(d)] is a general rule that contains requirements for fuel burning equipment. Emissions that may be regulated under Georgia Rule (d) include PM, opacity, and NO X

.

Power Boiler 4 is subject to the rule for PM at a rate limited by equation P = 0.7(10/R) 0.202 where P is the emission limit in pounds per million Btu heat input and R is equal to the boiler heat input. The limit is subsumed by a more stringent PSD lim it of 0.070 pounds per million Btu heat input. The facility controls PM emissions from this source using an ESP.

Package Boiler 2 is subject to the rule for PM and opacity. PM emissions are limited to a rate calculated by equation P = 0.5(10/R) 0.5 where P is the emission limit in pounds per million Btu heat input and R is equal to the boiler heat input. The PM limit is subsumed by a more stringent PSD limit of 0.050 pounds per million Btu heat input. Opacity is limited to less than 20% except for one s ix

- minute period of no more than 27%. The facility does not operate a control device on this boiler. Compliance is achieved through burning only natural gas and very low sulfur fuel oil. Opacity will be monitored using a COMS.

Waste Fuel Boiler WF is s ubject to the rule for PM, NO X , and opacity. PM emissions are limited to a rate calculated by equation P = 0.5(10/R) 0.5 where P is the emission limit in pounds per million Btu heat input and R is equal to the boiler heat input. The PM limit is subsumed b y a more stringent PSD limit of 0.025 pounds per million Btu heat input. Opacity is limited to less than 20% except for one six minute period of

no more than 27% and NO X is limited to 0.20 pounds per million Btu heat input. Opacity for the Waste

Fuel Boi ler is subsumed by a more stringent PSD limit of 10%. The facility will control PM and opacity with an ESP. Opacity and NO X emissions will be monitored using a COMS and a CEMS.PSD Preliminary Determination Page 4 of 49

Georgia Rule (e) [391

- 3

- 1

- .02(2)(e)], commonly known as the process weight rule, limits PM emissions based on the following equations:

For P = 30 ton/hr, E = 4.1 × P 0.67

For P> 30 ton/hr, E = 55 × P 0.11

- 40

where E = emission rate (lb/hr) and P = process input rate (ton/hr). Recovery Furnace 5 is subject to Georgia Rule (e). Because the limit is based on the process input weight, the limit is not considered subsumed by any other PM

limit.

Georgia Rule (g) [391

- 3

- 1

- .02(2)(g)] applies to all fuel

- burning sources. Paragraph 1 limits the emission of SO 2 from new fuel burning so urces based on the type of fuel burned in the source. Paragraph 2 of the rule limits the percentage of sulfur, by weight, in the fossil fuel burned to 3.0 percent for fuel

- burning sources with a maximum heat input equal to or greater than 100 MMBtu/hr. P aragraph 2 applies to Recovery Furnace 5, Power Boiler 4, Package Boiler 2, and Waste Fuel Boiler WF. The facility has taken more stringent PSD Avoidance and 40 CFR 60 Subpart Db limits for the burning of fuel oil and coal for all four units. Other fuel sources, such as tire

- derived fuel, still must meet the sulfur content limit in this rule. Waste Fuel Boiler WF is subject to a limit of 0.80 pounds per million BTU heat input under Paragraph 1 of the rule.

Georgia Rule (gg) [391

- 3

- 1

- .02(2)(gg)] applies to Kraft Pulp Mill sources. All limits under Rule (gg) are equivalent to or subsumed by more stringent PSD and Subpart BB limits.

Georgia Rule (lll) [391

- 3

- 1

- .02(2)(lll)] applies to NO X emissions from fuel burning equipment installed or modified

after Ma y 1, 1999, rated equal to or greater than 10 MMBtu/hr and less than or equal to 250 MMBtu/hr, and located on a list of counties which includes Floyd County. The rule limits NO X emissions to 30 ppm @ 3% O 2 on a dry basis during the period of May 1 st to Sep tember 30 th of each year. Package Boiler 2 is subject to this limit.

Georgia Rule 391

- 3

- 1

- .02(6)(a)(iii) applies to Waste Wood Fired Combination Boilers that fire wood waste at a capacity greater than 100 MMBtu/hr. Under the rule, the facility must inst all a COMS for the measurement of opacity. The rule applies to Waste Fuel Boiler WF. The COMS is also a requirement under 40 CFR 60 Subpart Db.

Federal Rule

-

PSD

The regulations for PSD in 40 CFR 52.21 require that any new major source or modification of an existing major source be reviewed to determine the potential emissions of all pollutants subject to regulations under the Clean Air Act. The PSD review requirements apply to any new or modified source which belongs to one of 28 specific source

cate gories having potential emissions of 100 tons per year or more of any regulated pollutant, or to all other sources having potential emissions of 250 tons per year or more of any regulated pollutant. They also apply to any modification of a major stationar y source which results in a significant net emission increase of any regulated pollutant.

The PSD regulations require that any major stationary source or major modification subject to the regulations meet the following requirements:

• Application of BACT f or each regulated pollutant that would be emitted in significant amounts;

• Analysis of the ambient air impact;

• Analysis of the impact on soils, vegetation, and visibility;

• Analysis of the impact on Class I areas; and

• Public notification of the proposed plan t in a newspaper of general circulation.PSD Preliminary Determination Page 5 of 49

Definition of BACT

The PSD regulation requires that BACT be applied to all regulated air pollutants emitted in significant amounts.

Section 169 of the Clean Air Act defines BACT as an emission limitation reflect ing the maximum degree of reduction that the permitting authority (in this case, EPD), on a case

- by

- case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such a facility through applicatio n of production processes and available methods, systems, and techniques. In all cases BACT must establish emission limitations or specific design characteristics at least as stringent as applicable New Source Performance Standards (NSPS). In addition, i f EPD determines that there is no economically reasonable or technologically feasible way to measure the emissions, and hence to impose and enforceable emissions standard, it may require the source to use a design, equipment, work practice or operations st andard or combination thereof, to reduce emissions of the pollutant to the maximum extent practicable.

The BACT determination should, at a minimum, meet two core requirements. The first core requirement is that the determination follow a “top

- down” app roach. The second core requirement is that the selection of a particular control system as BACT must be justified in terms of the statutory criteria and supported by the record and must explain the basis for the rejection of other more stringent candidate control systems.

EPD’s procedures for performing a top down BACT analysis are set forth in EPA’s Draft New Source Review Workshop Manual (Manual), dated October 1990. One critical step in the BACT analysis is to determine if a control option is technica lly feasible. If a control is determined to be infeasible, it is eliminated from further consideration. The Manual applies several criteria for determining technical feasibility. The first is straightforward: if the control has been installed and opera ted by the type of source under review, it is demonstrated and technically

feasible.

For controls not demonstrated using this straightforward approach, the Manual applies a more complex approach that involves two concepts for determining technical feasi bility: availability and applicability. A technology is considered available if it can be obtained through commercial channels. An available control is applicable if it can be reasonably installed and operated on the source type under construction. A t echnology that is available and applicable is technically feasible.

The Manual provides some guidance for determining availability. For example, a control is generally considered available if it has reached the licensing and permitting stages of develo pment. However, the Manual further provides that a source would not be required to experience extended time delays or resource penalties to allow research to be conducted on new technologies. In addition, the applicant is not expected to experience exten ded trials learning how to apply a technology on a dissimilar source type. Consequently, technologies in the pilot scale testing stages of development are not considered available for BACT.

As mentioned before, the Manual also requires available technolo gies to be applicable to the source type under construction before a control is considered technically feasible. For example, deployment of the control technology on an existing source with similar gas stream characteristics is generally a sufficient basi s for concluding technical feasibility. However, even in this instance, the Manual would allow for an applicant to make a demonstration to the contrary. For example, an applicant could show that unresolved technical difficulties with applying a control t o the source under consideration (e.g., size of the unit, location of the proposed site, and operating problems related to the specific circumstances of the source) make a control technically infeasible.

According to the Environmental Appeals Board (see I n re: Kawaihae Cogeneration Project , 7 E.A.D. 107 at page 1996, EAB 1997), the section on “collateral environmental impacts” of a proposed technology has been interpreted to mean that “if application of a control system results directly in the release (or removal) of pollutants that are not currently regulated under the Act, the net environmental impact of such emissions is eligible for consideration in making the BACT determination.” The Appeals Board continues, “The Administration has explained that the primary purpose of the collateral impacts clause is... to temper the stringency of the technological requirements whenever one or more of the specified collateral impacts

– energy, environmental, or economic

– renders the use of the most effective technolog y inappropriate.” Lastly, the Appeals Board document states, “Unless it is demonstrated to the satisfaction of the permit issuer that such unusual circumstances exist, then the permit applicant must use the most effective technology.”PSD Preliminary Determination Page 6 of 49

The five steps of a top

- down BACT review procedure identified by EPA per BACT guidelines are listed below:

Step 1: Identify all control technologies Step 2: Eliminate technically infeasible options Step 3: Rank remaining control technologies by control effectiveness Step 4: Evaluate most effective controls and document results Step 5: Select BACT

Now that the PSD BACT standards have been defined, the next step is to review the remaining applicable federal requirements. This step will aid in citing the appropriate legal authority for each requirement in the Title V permit. This analysis will show that the PSD BACT standards represent the most stringent limit.

Federal Rule

– 40 CFR 60 Subpart Db

Recovery Furnace 5, Package Boiler 2, and Waste Fuel Boiler WF are boilers which were or will be constructed after June 19, 1984 and have heat input capacities greater than 100 MMBtu per hour. The units are therefore subject to NSPS Subpart Db, Standards of Performance for Industrial

- Commercial

- Institutional Steam Generating Un its

. The standard sets limits for PM, opacity, NO X , and SO

2 based on boiler operating conditions.

All three boilers are subject to a limit of less than 20% opacity except for one six minute period of not more than 27%. The opacity limit is subsumed for Waste Fuel Boiler WF by a more stringent PSD limit of 10%. Compliance with this limit will be monitored with continuous opacity monitoring systems. Also, all fuel oil combusted in the units will be required to be very low sulfur fuel oil, thereby allowin g the facility to avoid SO 2 reduction requirements. Fuel oil sulfur content will be monitored by review of fuel receipts.

Recovery Furnace 5, Package Boiler 2, and Waste Fuel Boiler WF are subject to NSPS PM limits; however, the limits are subsumed by mo re stringent PSD limits. Compliance with the PM limits will be achieved using ESPs for the Recovery Furnace and the Waste Fuel Boiler. Compliance with the PM limits will be achieved for Package Boiler 2 through the combustion of clean fuels.

Recovery Fu rnace 5 is not subject to a NO X limit under the subpart due to the use of an annual oil capacity factor of 0.10 for the unit. Both Package Boiler 2 and Waste Fuel Boiler WF are subject to NO X limits of 0.20 pounds per million Btu heat input. Compliance w ith these limits will be assured through the use of NO X CEMS.

Federal Rule

– 40 CFR 60 Subpart BB

Recovery Furnace 5 was constructed after 1976, subjecting it to NSPS Subpart BB, Standards of Performance for Kraft Pulp Mills . Subpart BB establishes a PM limit of 0.044 grain per dscf at ten percent oxygen. This limit is subsumed by a more stringent PSD / 40 CFR 63 Subpart MM limit of 0.21 grains per dscf. PM emissions will continue to be controlled with an ESP. The furnace is also subject to a TRS limi t of 5 ppm. Compliance with the limit is assured through the use of a CEMS. The unit also uses a COMS to provide reasonable assurance of compliance with the opacity limit of 35% that is applicable while no fossil fuels are being fired.

Power Boiler 4 co mbusts total reduced sulfur (TRS) gases subject to NSPS Subpart BB, Standards of Performance for Kraft Pulp Mills ; therefore the boiler must comply with the minimum temperature (1200 degrees Fahrenheit) and residence time (0.5 seconds) requirement prescrib ed by the subpart.

Federal Rule

– 40 CFR 61 Subpart E

NESHAP Subpart E, National Emission Standards for Mercury applies to the drying or incinerating of municipal or industrial wastewater sludge. Waste Fuel Boiler WF will burn industrial wastewater slud ge, therefore Subpart E will apply to the unit. The mercury limit is 7.1 pounds per 24

- hour period and compliance can be determined either by stack testing or sampling of the sludge being burned. Inland has proposed to complete Method 105 sludge analysis to demonstrate compliance with the standard.PSD Preliminary Determination Page 7 of 49

Federal Rule

– 40 CFR 63 Subpart S

In addition to covering the optimization of the mill’s production capacity, this permit application is intended to cover the necessary physical and permitting changes the m ill will be undertaking to comply with the second phase of the Cluster Rule, Subpart S, National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry

.

Phase II of the Cluster Rule requires compliance by April 15, 2006. The mil l will therefore be implementing Phase II of the Cluster Rule during the timeframe of the mill optimization project. The mill is currently investigating how it plans to achieve compliance with this portion of the rule. The mill may either collect the off

- gases from the E, F, and G washers and their associated filtrate tanks, and foam tanks, and route them to Waste Fuel Boiler WF for destruction or the mill may utilize the Clean Condensate Alternative in the rule which may allow continued venting of gases. In order to provide emission allowances in this application for either case, the permit application allowed for both the combustion of the E, F, and G washer and filtrate tank off

- gasses in Waste Fuel Boiler WF, which forms

SO 2 emissions, as well as the continued venting of the VOC and TRS.

Federal Rule

– 40 CFR 63 Subpart MM

40 CFR 63 Subpart MM, National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand

- Alone Semichemical Pulp M ills , promulgated March 13, 2001, sets standards for hazardous air pollutants (HAPs) from chemical recovery combustion equipment on site. After completion of the project, the only impacted units will be Recovery Furnace 5, Smelt Tank 5, Lime Kiln 1A,

and Lime Kiln 2A. If a unit is reconstructed as defined by the MACT (Maximum Achievable Control Technology) II standard, the standards for new sources will apply to the reconstructed unit. Reconstruction is triggered if the

costs for the modifications exceed 50% of the cost to install a new unit. Of these units, the only one being modified is Recovery Furnace 5 and the project costs for this project are well below 50% of the equivalent replacement costs. Therefore Recovery Furnace 5 is not being reconstructe d per 40 CFR 63 Subpart MM by the proposed project. All four units will therefore be covered under the existing unit limits.

The purpose of the MACT II rule is to regulate HAP emissions, but it allows PM to be used as a surrogate for total

HAPs. The MAC

T PM standards, and the regulated units that will operate after the completion of the project, are

summarized in Table 2. The mill

- wide equivalent emission limit is calculated based on the post

- modification flow rates for the lime kilns and recovery furna ces and the post

- modification black liquor solids throughput rate.

Table 2: Chemical Recovery Combustion Source MACT PM Emission Limits

Unit MACT Emission Limit EQ. MACT Emission Limit

Lime Kiln 1A 0.064 gr/dscf@ 10% O 2 0.152 lb/ton BLS

Lime Kiln 2A 0. 064 gr/dscf@ 10% O 2 0.152 lb/ton BLS

Smelt Tank 5 0.20 lb/ton BLS 0.20 lb/ton BLS Recovery Furnace 5 0.044 gr/dscf @ 8% O 2 0.978 lb/ton BLS Mill Wide Equivalent Emission Limit 1.482 lb/ton BLS 1.482 lb/ton BLS

As an alternative to the specific emissio n limits shown in Table 2, the MACT rule allows pulp and paper mills to establish facility wide bubble PM emission limits for the individually regulated sources. This option allows for the

calculation of a total mill

- wide emission limit for all combustio n sources based on the MACT standards and then allows for the allocation of these emissions to the individual emission sources as determined by the mill. This “bubble” option will thereby allow the mill to over control some sources while under controlling others. The bottom of Table 2 provides the mill’s overall lb PM/ton BLS limit (1.482 lb/ton BLS).

In the case of the regulated units at the mill, Recovery Furnace 5 and Smelt Tank 5 are already regulated at or below

the MACT emission limits. The lime kilns are currently permitted at a process weight rate rule limit which is greater than the 0.064 gr/dscf emission limit for lime kilns. The mill therefore proposes to implement a bubble limit. Table 3 outlines the proposed limit for each of the units as well as the corresponding mill wide equivalent emission

limit.PSD Preliminary Determination Page 8 of 49

Table 3: Proposed MACT PM Bubble Limit Emission Limits

Unit MACT Emission Limit EQ. MACT
Emission Limit Basis

Lime Kiln 1A 0.106 gr/dscf@ 10% O 2 1 0.306 lb/ton BLS

Lime Kiln 2A 0.155 gr/dscf@ 10% O 2 0.290 lb/ton BLS Exhaust concentration at peak production rate and the process weight rate rule production limit.
Smelt Tank 5 0.14 lb/ton BLS 0.14 lb/ton BLS Current Permit Limit Recovery Furnace 5 0.021 gr/dscf @ 8% O 2 0.467 lb/ton BLS Prop osed BACT emission Limit Mill Wide Equivalent Emission Limit 1.203 lb/ton BLS 1.203 lb/ton BLS EPA MACT Compliance Spreadsheet

1 This limit would apply only when firing fuel oil. The current NSPS Subpart BB current limit of 0.067 gr/dscf would still appl

y when firing natural gas.

Federal Rule

– 40 CFR 63 Subpart DDDDD

New Waste Fuel Boiler WF will be subject to 40 CFR 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial/Commercial/Institutional Boilers and Process He aters upon startup

. The standard was proposed on January 13, 2003 and has been finalized, but has not yet entered the Federal Register. The final rule sets PM emission limits of 0.025 lb/MMBtu (as a surrogate for metal HAPs), as well as CO emission

limits (400 ppm @ 7% O 2 ), HCl limits (0.02 lb/MMBtu), and mercury limits (0.000003 lb/MMBtu) for large (>10 MMBtu/hr) industrial solid fuel fired boilers. Alternatively, the total selected metals limit of 0.0003 lb/MMBtu may

be used instead of the 0.025 lb/MMBt u PM limit. The industrial boiler MACT also sets an opacity limit of 10 percent opacity. The requirements for this subpart will not be included in the permit until it is published as final in the Federal Register.

Power Boiler 4 will eventually be cover ed under the standards set for existing large solid fuel fired boilers. The costs of the proposed modifications to the Power Boiler are estimated at 6.2 million dollars and the estimated replacement cost for the unit is 60 million dollars. The costs are well below 50% of the replacement costs; therefore the modifications will not trigger the MACT standard for the unit. The unit will have three years to comply with the standard once it is published.

State and Federal

– Startup and Shutdown and Excess Emi ssions

Excess emission provisions for startup, shutdown, maintenance, and malfunction are provided in Georgia Rule 391

- 3

- 1

- .02(2)(a)7. Excess emissions from the units associated with the proposed modification will most likely result

from a malfunction of

the associated control equipment. The facility cannot anticipate or predict malfunctions. However, the facility must minimize emissions during periods of startup, shutdown, and malfunction.

Federal Rule

– 40 CFR 64

- Compliance Assurance Monitoring

40 CFR 64, Compliance Assurance Monitoring applies to pollutant specific emission units (PSEUs) as defined in the subpart.

PSEUs are units for which there exists an emission standard for which there is a Part 64 control device and where the pre

- control poten tial emission rate is equal to or greater than 100 percent of the major source threshold. The frequency of data collection under Part 64 depends on whether the controlled potential to emit exceeds 100 tons per year, in which case it is considered to be a “large PSEU.”

Recovery Furnace 5 and Waste Fuel Boiler WF are being modified and qualify as large PSEUs for the emission of PM. The facility is therefore required to collect four or more data values for the respective ESPs (ESP power) equally spaced over

each hour. CAM requirements for Power Boiler 4 are not being incorporated at this time because the changes being made to the boiler do not qualify as modifications based on emission changes. CAM requirements for the Power Boiler and all other applicable units will be added in the first Title V renewal permit.PSD Preliminary Determination Page 9 of 49

4.0 CONTROL TECHNOLOGY REVIEW

RECOVERY FURNACE 5

– PARTICULATE MATTER

Step 1: Identify all Control Technologies

The currently available particulate matter (PM) controls include electrostatic p recipitators (ESP), wet ESPs (WESP), baghouses, and high efficiency wet scrubbers. In the case of an ESP, high voltage electrodes impart a negative charge to the particles entrained in the exhaust gas stream. These negatively charged particles are then a ttracted to a grounded collecting surface, which is positively charged. The cleaned gas then exits the ESP. Inside the ESP, the particles build up on the collecting plates. At periodic intervals the plates are rapped, causing the agglomerated particles to fall into hoppers. The particles are then removed from the hoppers by a gravity fed rotary screw arrangement. In the case of wet ESPs, a liquid wash down collects the particulates and wet sluicing is used to remove the particles. ESPs offer very high efficiencies for particulates of very small size (above 1 micron in size).

Dry filtration is a common method for removing dry particulate matter from many types of industrial gas streams. Filters are available in a variety of types, materials, and sizes . Fabric filters are reusable filters that can be cleaned by shaking, reversing the airflow, or pulsing the airflow.

Wet scrubbers remove particulates from a gas stream by capturing the particles in liquid droplets. Scrubber systems are generally more e xpensive to purchase and operate than dry filtration. However, scrubbers present a particulate removal alternative for applications where dry filtration is not recommended based on particulate matter

characteristics.

Option 1: Dry Electrostatic Precipit ator

Option 2: Wet Electrostatic Precipitator Option 3: Dry Filtration (Baghouse) Option 4: Wet Scrubber

Step 2: Eliminate Technically Infeasible Options

Option 3

– Dry Filtration (Baghouse)

While baghouses offer the best PM control for the smalles t particles, the high moisture content of the exhaust gases along with the hydroscopic nature of the salt cake would blind a baghouse; therefore it is not considered a practical solution. There are no known applications of baghouses on recovery furnaces.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Wet and dry ESPs are considered the most effective means of controlling PM from a recovery furnace. Most operating recovery furnaces utilize this technology. A venturi scrubber wo uld be technically viable; however the scrubber would not be expected to be as effective as an ESP.

Table 4: Ranking of Control Technology
Control Technology Ranking Control Technology Control Efficiency

1 ESP ~99%

2 Wet Scrubber ~75%

Step 4: Evalua te Most Effective Controls and Document Results

Table 4

- 2 of the PSD application is a list from the U.S. EPA BACT / LAER Clearinghouse (RBLC) database of PM emission rates and controls for recovery furnaces. As indicated, the most utilized PM control tec hnology for recovery furnaces is the ESP. Since Recovery Furnace 5 currently utilizes a dry ESP for PM emission control and ESPs are the most effective technology for removing PM emissions from recovery furnaces, no additional controls are being proposed for the project.PSD Preliminary Determination Page 10 of 49

Step 5: Select BACT

The BACT database emission limits for PM emissions from a recovery furnace range from 0.021 gr/dscf @ 8% O 2 to 0.15 gr/dscf @ 8% O 2 . Inland proposes to meet a limit of 0.021 gr/dscf @ 8% O 2 while firing either fuel

oil or black liquor. This limit is approximately equal to that of Georgia Rule (e) for PM at the maximum production rate. Showing compliance with this limit will also serve to demonstrate compliance with 40 CFR 63 Subpart MM.

Emissions due to the firin g of fuel oil are expected to be lower than that from firing black liquor solids; therefore the proposed limit will be met when firing black liquor solids or fuel oil.

Conclusion

– PM Control

The Division has determined that Inland’s proposal to use a dr y ESP to minimize PM emissions constitutes BACT. The BACT emission limit has been established as 0.021 gr/dscf @ 8% O 2 as also proposed by Inland . Compliance with the PM limit must be demonstrated through performance testing and monitoring of the associa ted ESP.

Summary

– Control Technology Review for PM from Recovery Furnace 5

To fulfill the PSD permitting requirements for PM, a BACT analysis was conducted for Recovery Furnace 5. The BACT selection for Recovery Furnace 5 is summarized in Table 5. The emission limit selected is representative of previous PSD BACT determination levels published in the RBLC database.

Table 5: BACT Summary for Recovery Furnace 5

Pollutant Control Technology Proposed BACT Limit

PM Dry ESP 0.021 gr/dscf @ 8% O 2

RECOVER

Y FURNACE 5

– CARBON MONOXIDE

Step 1: Identify all Control Technologies

CO is a result of incomplete combustion and can be minimized through the use of good combustion practices (including assuring sufficient air

- to

- fuel ratios). Good combustion practi ces can be enhanced through the use of staged combustion, which involves the injection of combustion air at different levels in the furnace. Beyond combustion control, the remaining CO could be oxidized to CO 2 in a downstream control device. This could b e an incinerator, which would combust fuel to raise the temperature of the gases to combustion temperature, or a catalyst bed, which would allow oxidation to CO 2 at lower temperature. Fuel would also be required for a CO catalyst application because the e xhaust gas temperature would not be sufficiently high for a catalyst to be effective.

Option 1: Staged Combustion and Good Combustion Practices Option 2: Oxidation (Incineration) Option 3: Catalytic Reduction

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 6: Ranking of Control Technology
Control Technology Ranking Control Technology Control Efficiency

1 Staged combustion and go od combustion practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%PSD Preliminary Determination Page 11 of 49

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 4 of the PSD application is a list from the RBLC database of CO emission limits an d controls that are in place for recovery furnaces. It indicates that the only control technology in use for minimizing CO emission from recovery furnaces is the combination of staged combustion and good combustion operation practices. Currently,

Recover y Furnace 5 is operated with staged combustion and good combustion practices. The proposed project calls for the installation of a dedicated fan for the third stage of combustion air. This should allow for more combustion air and thereby enhance the comb ustion process.

CO control through the utilization of good combustion controls is designed into all recovery furnaces. To further reduce CO emissions, the addition of an oxidation catalyst could potentially be utilized. However, the exhaust gas

stream t emperature must be significantly higher for the oxidation catalyst to work. At exhaust gas temperatures below 800 degrees Fahrenheit, the oxidation catalyst becomes ineffective. The average temperature of Recovery Furnace 5 exhaust gases is roughly 300 d egrees Fahrenheit. An oxidation catalyst would not be effective at reducing CO emissions in Recovery Furnace 5 unless the exhaust gas temperature was raised considerably by reheating. Raising the temperature of the gases would require significant heat in jection through additional fuel firing or through a derating of the boiler. In either case, significant energy costs would result. Furthermore, significant emissions of products of combustion , notably NO X , would result from the combustion needed to eith er raise the temperature of the exhaust gases or through increased fuel consumption to make up for the loss in boiler efficiency if the recovery furnace was derated. Based on these energy and environmental costs, neither oxidation alone, or with a catalys

t, is considered practically feasible. There would also be significant technical hurdles because of the sulfur compounds contained in the off gases.

Step 5: Select BACT

The BACT limits in the database range from 169 to 879 ppm and control technologies include combustion control, furnace design and operation, and good combustion practices. Inland proposes that CO BACT be defined as staged combustion and good combustion practices and an emission rate of 650 ppm @ 8% O 2 . This level is proposed to

account for process variations such as black liquor concentration and the wood species being burned. This proposed BACT emission limit is intended to apply while firing black liquor solids and fuel oil in combination. See Package Boiler BACT analysis for CO lim it while burning fuel oil alone.

Conclusion

– Carbon Monoxide Control

The Division has determined that Inland’s proposal to use staged combustion and good combustion practices to

minimize CO emissions constitutes BACT. The BACT emission limit has been e stablished as 650 ppm @ 8% O 2 while burning black liquor solids as proposed by Inland. Compliance with the CO limit must be demonstrated through performance testing and monitoring furnace oxygen. See Package Boiler BACT analysis for the CO limit

while bu rning fuel oil alone.

Summary

– Control Technology Review for CO from Recovery Furnace 5

To fulfill the PSD permitting requirements for CO, a BACT analysis was conducted for Recovery Furnace 5. The BACT selection for Recovery Furnace 5 is summarized in Table 7. Although there are BACT analyses that have limits less than those proposed by the facility, it should be noted that the new limit does not equal a linear increase of CO emissions based on the increase of black liquor solids throughput. See Packa ge Boiler BACT analysis for the CO limit while burning fuel oil alone.

Table 7: BACT Summary for Recovery Furnace 5

Pollutant Control Technology Proposed BACT Limit

CO Staged Combustion and Good Combustion Practices 650 ppm @ 8% O 2 while burning BLS

CO Good Combustion Practices 0.20 lb/MMBTU while burning fuel oil alonePSD Preliminary Determination Page 12 of 49

RECOVERY FURNACE 5

– VOLATILE ORGANIC COMPOUNDS

Step 1: Identify all Control Technologies

As with CO, VOCs are a result of incomplete combustion and VOC can be controlled through o xidation as well as catalytic technologies.

Option 1: Staged Combustion and Good Combustion Practices Option 2: Oxidation (Incineration) Option 3: Catalytic Reduction

Step 2: Eliminate Technically Infeasible Options

All options are technically feas ible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 8: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Staged Combustion and Good Combustion Practices N/a

2 Oxidation (I ncineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 5 of the PSD application is a list from the RBLC database of VOC emission limits and controls that are currently in place for recovery furnaces. The most effective control technology in the database for minimizing VOC emissions from recovery furnaces is staged combustion and good combustion operation practices. Currently, Recovery Furnace 5 uses staged combustion and good combu stion practices. The same economic and environmental conclusions apply for VOC that were applicable for CO for the use of oxidation or catalytic

reduction.

Step 5: Select BACT

The BACT limits in the database range from 0.03 to 0.48 lb/MMBtu and control technologies include combustion control, furnace design and operation, and good combustion practices. Inland proposes VOC BACT to be defined as staged combustion and good combustion practices and an emission rate of 0.04 lb/MMBtu. See Package Boiler

BAC T analysis for the VOC limit while burning fuel oil alone.

Conclusion

– VOC Control

The Division has determined that Inland’s proposal to use staged combustion and good combustion practices to

minimize VOC emissions constitutes BACT. The BACT emission l imit has been established as 0.04 lb/MMBtu, as proposed by Inland, while burning black liquor solids. Compliance with the VOC limit must be demonstrated through performance testing and surrogate monitoring of furnace oxygen. See Package Boiler BACT analy sis for the VOC limit while burning fuel oil alone.

Summary

– Control Technology Review for VOC from Recovery Furnace 5

To fulfill the PSD permitting requirements for VOC, a BACT analysis was conducted for Recovery Furnace 5. The

BACT selection for Reco very Furnace 5 is summarized in Table 9. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database. See Package Boiler BACT analysis for the VOC limit while burning fuel oil alone.

Table 9: BACT Summary for Recovery Furnace 5

Pollutant Control Technology Proposed BACT Limit

VOC Staged Combustion and Good Combustion Practices 0.04 lb/MMBtu while burning BLS

VOC Good Combustion Practices 0.02 lb/MMBtu while burning fuel oil alonePSD Preliminary Determination Page 13 of 49

RECOVERY FURNACE 5

– TOTAL REDUCED SULFUR (INCLUDING H 2 S)

Step 1: Identify all Control Technologies

The TRS compounds from a recovery furnace consist of hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The amount of TRS emissions is highly dependent upon the type of evaporator (direct or indirect) used to concentrate the black liquor solids. Direct contact evaporators use furnace exhaust gases to concentrate black liquor solids while non

- contact evaporators utilize indirect heat fro m steam generated by the furnace to concentrate the liquor under vacuum. Indirect contact evaporators result in significantly less TRS compounds being emitted.

TRS emissions can be reduced by process modifications, improved operating conditions, efficien t operation of the recovery furnace, avoiding overloading, and by maintaining sufficient oxygen, residence time, and turbulence. The

utilization of non

- direct contact evaporators (NDCE) in new recovery furnaces reduces TRS emissions substantially.

Causti c packed tower scrubbers are also effective in controlling a portion of TRS emission, primarily H 2 S, but not the organic forms of TRS (methyl mercaptan, dimethyl sulfide, and dimethyl sulfide). It is estimated that 80% of the TRS from Recovery Furnace 5 i s H 2 S; therefore, by assuring BACT is met for TRS, it is assumed that BACT for

H 2 S will also be met.

Option 1: NDCE System Design / Good Operation Practices

Option 2: Wet Scrubber

Step 2: Eliminate Technically Infeasible Options

Both options are tech

nically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

The utilization of NDCE design for recovery furnaces is most effective in the reduction of TRS emissions. Caustic

scrubbers are less effective in the control of T RS emission because they only control a portion of the TRS.

Table 10: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 NDCE System Design / Good Operation Practices ~99% 1

2 Wet Scrubber ~65%

1 Direct con

tact unit versus non

- direct contact unit according to The Compilation of Air Pollutant Emission Factors,

AP

- 42, Fifth Edition, Volume 1 (AP

- 42), Chapter 10.2, Table 10.2

- 1.

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 6 of the P SD application is a list from the RBLC database of TRS emission limits and controls that are in place for recovery furnace. It indicates that the most effective control technology for minimizing TRS emissions from recovery furnaces is furnace design (NDCE system) and good operating practices. Recovery Furnace 5 utilizes a NDCE system and good operating practices.

Step 5: Select BACT

The limits in the BACT database range from 3 to 20 ppm and control technologies include combustion control and

furnace de sign and operation as well as low odor design and non

- contact evaporator system design. Recovery Furnace 5 is an NSPS unit and the NSPS limit for TRS emission from an NDCE recovery furnace is 5 ppm. Inland proposes a BACT limit of 5 ppm, on a dry basis c orrected to 8% oxygen, on a 12

- hour basis. The limit is the same BACT level established for the Georgia Pacific Cedar Springs recovery furnace that recently went through a BACT analysis in Georgia. It is estimated that 80% of the TRS is H 2 S; therefore th

e proposed BACT level for H 2 S, is set at 4 ppm @ 8% oxygen.PSD Preliminary Determination Page 14 of 49

Conclusion

– TRS Control (Including H 2 S)

The Division has determined that Inland’s proposal to use NDCE design and good operating practices to minimize

TRS and H

2 S emissions constitutes BACT. The BACT emission limits have been established as 5 ppm and 4 ppm, respectively, corrected to 8% O 2 . Compliance with the emission limits must be demonstrated through continuous emissions monitoring.

Summary

– Control Technology Review for TRS and H 2 S fro m Recovery Furnace 5

To fulfill the PSD permitting requirements for TRS and H 2 S, a BACT analysis was conducted for Recovery Furnace 5. The BACT selection for Recovery Furnace 5 is summarized in Table 11. The emission limits selected are representative o f previous PSD BACT determination levels published in the RBLC database.

Table 11: BACT Summary for Recovery Furnace 5

Pollutant Control Technology Proposed BACT

Limit Averaging Period

TRS NDCE Design and Good Operating Practices 5 ppm, 8% O 2 12 hours

H 2 S NDCE Design and Good Operating Practices 4 ppm, 8% O 2 12 hours

POWER BOILER 4

– PARTICULATE MATTER

Step 1: Identify all Control Technologies

The current available PM controls include electrostatic precipitators, wet ESPs, baghouses, and high effic iency wet scrubbers. The theory and operation of each of these control technologies was discussed in detail in the Recovery Furnace 5 BACT analysis.

Option 1: Dry Electrostatic Precipitator Option 2: Wet Electrostatic Precipitator Option 3: Dry Filtra tion (Baghouse) Option 4: Wet Scrubber

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

According to AP

- 42, baghouses are considered the m ost effective means of PM control from a pulverized coal fired power boiler followed second by ESP technology. A scrubber would be expected to be the least effective of the available PM control technologies.

Table 12: Ranking of Control Technology

Contr ol Technology Ranking Control Technology Control Efficiency
1 Dry Filtration (Baghouse) ~99.8%

2 ESP ~99.2%

3 Wet Scrubber ~97%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 7 of the PSD application is a list from the RBLC da tabase of PM emissions limits and controls that are in place for pulverized coal fired boilers. It shows that the units with the lowest emission rates are controlled by baghouses, with the remaining units being controlled by ESPs.PSD Preliminary Determination Page 15 of 49

Step 5: Select BACT

The units with the lowest emission rates in the BACT database are controlled by baghouses. The remaining units are controlled by ESPs. Based on EPA AP

- 42 emissions data, ESPs on pulverized coal fired boilers are typically 99.2% efficient at controlling P M while baghouses are typically 99.8% efficient. If a baghouse were used instead of the current ESP, it would be expected to collect an additional 0.6% of the uncontrolled PM emission from Power Boiler 4. EPA estimates the uncontrolled PM from a pulveriz ed coal fired boiler at 100 pound per ton of coal, based on a typical ash content of 10%. Based on this emission factor, 0.6% would equate to 57 tpy from the modified

boiler.

The costs of installing a baghouse in place for the existing ESP are evaluated using the latest EPA cost estimating spreadsheets for baghouses. The results of this analysis found that the annualized costs for operating a baghouse on the exhaust gas stream from Power Boiler 4, in lieu of the existing ESP, would be roughly $1,300,000 per year. The expected incremental economic cost of installing a baghouse would therefore be estimated at $22,800 per ton of PM reduced, which exceeds what would be considered economically reasonable. A baghouse is therefore not considered economically f

easible for the proposed application. The primary difference in this application and the other units listed in the clearinghouse is that this BACT analysis is for a modified unit that already has an ESP and not the

installation of a new unit. The BACT an alysis has taken into account the effectiveness of the pollution controls that are currently in place.

The ash content of the coal, as well as the fly ash resistivity, can significantly impact the collection effectiveness of the ESP. Inland plans to burn coal with a sulfur content up to 1.29%. Inland proposes a BACT level of 0.07 lb / MMBtu, which falls between the range of PM emission rates found in the clearinghouse (0.01 to 0.286 lb / MMBtu). The proposed level represents a 77% reduction from what wo uld be the state permitted level under Rule (d) for the unit. The limit is also equal to the limit in the proposed MACT rule 40 CFR 63 Subpart DDDDD (Boiler MACT).

Conclusion

– PM Control

The Division has determined that Inland’s proposal to use the exi sting dry ESP to minimize PM emissions constitutes BACT. The BACT emission limit has been established as 0.07 lb/MMBtu, as proposed by Inland. Compliance with the PM limit must be demonstrated through performance testing and monitoring of the ESP.

Summa ry

– Control Technology Review for PM from Power Boiler 4

To fulfill the PSD permitting requirements for PM, a BACT analysis was conducted for Power Boiler 4. The BACT

selection for Power Boiler 4 is summarized in Table 13. The emission limit selected i s representative of previous PSD BACT determination levels published in the RBLC database.

Table 13: BACT Summary for Power Boiler 4

Pollutant Control Technology Proposed BACT Limit

PM Dry ESP 0.07 lb/MMBtu

POWER BOILER 4

– CARBON MONOXIDE

Step 1: I dentify all Control Technologies

The generation of CO can be minimized through the use of good combustion practices, oxidation to CO 2 in a downstream unit, or by passing the gases over a catalyst at sufficiently high temperatures.

Option 1: Staged Combu stion and Good Combustion Practices Option 2: Oxidation Option 3: Catalyst Technology

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.PSD Preliminary Determination Page 16 of 49

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

T able 14: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Staged Combustion and Good Combustion Practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 9 of the PSD application is a list from the RBLC database of CO emission limits and controls that are in place for pulverized coal fired boilers. The most effective control technology listed in the RBLC dat abase for minimizing CO emissions from pulverized coal fired boilers is good combustion operation practices. Power Boiler 4 currently uses good combustion practices. Oxidation and catalytic reduction are not practically feasible due to the

same economic and environmental impacts discussed for Recovery Furnace 5.

Step 5: Select BACT

The BACT CO emission limits in the database range from 0.018 to 0.80 lb/MMBtu and control technologies include combustion control, furnace design and operation, and good com bustion practices. Currently there is not a NSPS limit for CO emissions from power boilers. Inland proposes CO BACT to be defined as staged combustion and good combustion practices and an emission rate of 300 ppm @ 3% O 2 , which is roughly equivalent to 0 .25 lb/MMBtu. With this proposed project the mill will be installing low NO X burners on the coal

- fired boiler. This installation is expected to reduce NO X to less than half its current level. With this reduction in NO X , CO emissions may potentially incr

ease because of the design of the low NO X burners. A small increase in CO would, however, be considered warranted due to significant reduction in NO X , which is considered a higher priority pollutant.

Conclusion

– CO Control

The Division has determined t hat Inland’s proposal to use good combustion practices to minimize CO emissions constitutes BACT. The BACT emission limit has been established as 300 ppm @ 3% O 2 , as propose by Inland

. Compliance with the CO limit must be demonstrated through performance testing and monitoring furnace oxygen.

Summary

– Control Technology Review for CO from Power Boiler 4

To fulfill the PSD permitting requirements for CO, a BACT analysis was conducted for Power Boiler 4. The BACT

selection for Power Boiler 4 is summariz ed in Table 15. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database.

Table 15: BACT Summary for Power Boiler 4

Pollutant Control Technology Proposed BACT Limit

CO Stage Combustion and Good Combustion Practices 300 ppm @ 3% O2

POWER BOILER 4

– VOLATILE ORGANIC COMPOUNDS

Step 1: Identify all Control Technologies

As with CO, VOC is a result of incomplete combustion and VOC can be controlled through oxidation as well as catalytic tech

nologies.

Option 1: Staged Combustion and Good Combustion Practices Option 2: Oxidation (Incineration) Option 3: Catalytic Reduction

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.PSD Preliminary Determination Page 17 of 49

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 16: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Staged Combustion and Good Combustion Practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Cataly tic Reduction 95%

- 98%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 10 of the PSD application is a list from the RBLC database of VOC emission limits and controls that are in place for pulverized coal fired power boilers. As specified in that table, the most effective control technology for minimizing VOC emissions from pulverized coal fired boilers is good combustion practices. Currently, the operation of Power Boiler 4 qualifies as good combustion practice.

Oxidation and c atalytic reduction are not practically feasible due to the same economic and environmental impact reasons discussed for Recovery Furnace 5.

Step 5: Select BACT

The BACT emission rates in the RBLC database vary from 0.0036 to 1.8 lb/MMBtu. Currently the re is not a NSPS

limit for VOC emissions from coal

- fired boilers. Inland proposes VOC BACT to be defined as staged combustion and good combustion practices and an emission rate of 0.01 lb/MMBtu.

Conclusion

– VOC Control

The Division has determined that Inland’s proposal to use staged combustion and good combustion practices to minimize VOC emissions constitutes BACT. The BACT emission limit has been established as 0.01 lb/MMBtu, as proposed by Inland. Compliance with the emission limit must be demonstr ated through performance testing and monitoring furnace oxygen.

Summary

– Control Technology Review for VOC from Power Boiler 4

To fulfill the PSD permitting requirements for VOC, a BACT analysis was conducted for Power Boiler 4. The

BACT selection for Power Boiler 4 is summarized in Table 17. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database.

Table 17: BACT Summary for Power Boiler 4

Pollutant Control Technology Proposed BACT Limi t

VOC Staged Combustion and Good Combustion Practices 0.01 lb / MMBtu

WASTE FUEL BOILER

– PARTICULATE MATTER

Step 1: Identify all Control Technologies

The current available PM controls include electrostatic precipitators, wet ESPs, baghouses, and hig h efficiency wet scrubbers. The theory and operation of each of these control technologies was discussed in detail in the Recovery Furnace 5 BACT analysis.

Cyclones are also used to control the PM from waste fuel boilers. PM is removed from the flue gas by a combination of centrifugal and gravitational forces developed from swirling winds in the cyclone that force the particulate to collect in a hopper below. Cyclone control is limited to the collection of heavier particles and is typically used as a pr

e

- filter before other control devices.

Option 1: Dry Electrostatic Precipitator Option 2: Wet Electrostatic Precipitator Option 3: Dry Filtration (Baghouse) Option 4: Wet Scrubber Option 5: CyclonePSD Preliminary Determination Page 18 of 49

Step 2: Eliminate Technically Infeasible Options

All options are considered technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

ESPs are considered the most effective means of PM control from a waste fuel boiler. The proposed waste fuel

boiler will be convert ed from existing Recovery Furnace 3, which currently has an ESP to control PM. This ESP will continue to be used for particulate control on the new waste fuel boiler. According to the RBLC database, a baghouse is the second most effective control method followed by cyclones and venturi scrubbers. Though the units listed in the clearinghouse with the lowest emission rates have ESPs, a baghouse might offer improved reduction

efficiencies over an ESP.

Table 18: Ranking of Control Technology

Control Techno logy Ranking Control Technology Control Efficiency

1 ESP ~99%

2 Baghouse ~99%

3 Cyclones and Scrubbers ~90%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 11 of the PSD application is a list from the RBLC database of PM emissi on limits and controls in place for wood waste fired boilers. The units with the lowest emission rates are controlled by ESPs with the remaining units controlled by baghouses, cyclones, and venturi scrubbers.

Step 5: Select BACT

For the proposed projec

t, Inland will be converting Recovery Furnace 3 to Waste Fuel Boiler WF. The new waste fuel boiler at the mill will burn woodwaste (including bark and municipal woodwaste such as pallets), wastewater sludge, tire derived fuel, No. 2 Fuel oil, used fuel oi l, waste from the recycle fiber plant, and boiler ash recovered from the mill’s landfill. Recovery Furnace 3 is currently equipped with an ESP for the control of PM emissions. As indicated in the clearinghouse, PM limits range from 0.02 to 0.1 lb/MMBtu. Many of these units do not burn the wide range of fuels that will be burned in the proposed boiler. The units that most closely match the Inland boiler are the Interstate Paper boiler located in Riceboro, Georgia (not currently listed in the clearinghous e) and the

Beaver

- Livermore Falls boiler located in Maine. Both these units burn a similar mix of fuels and were permitted at 0.03 lb/MMBtu. Inland proposes a PM emission limit of 0.025 lb/MMBtu for the unit, which is lower than these

similar units.

In order to achieve an emission level as low as 0.02 lb/MMBtu it is expected that the unit would need to install a baghouse in lieu of the existing ESP. Based on the EPA costs estimating spreadsheets and the proposed boiler design, the baghouse would cost an estimated $1,200,000 per year. A baghouse would be expected to allow for a reduction of the PM limit from 0.025 lb/MMBtu to 0.02 lb/MMBtu, for a reduction of 0.005 lb/MMBtu. A baghouse would therefore be expected to result in a PM reduction of 18.7 tpy at an incremental cost of $64,000 per ton reduction, which would not be considered cost effective. Inland proposes to use the existing ESP and an

emission limit of 0.025 lb/MMBtu as BACT for the Waste Fuel Boiler.

Conclusion

– PM Control

The Division ha

s determined that Inland’s proposal to use a dry ESP to minimize PM emissions constitutes BACT. The BACT emission limit has been established as 0.025 lb/MMBtu as requested by Inland. Compliance with the emission limit must be determined through performan ce testing and monitoring of the ESP.

Summary

– Control Technology Review for PM from the Waste Fuel Boiler

To fulfill the PSD permitting requirements for PM, a BACT analysis was conducted for the Waste Fuel Boiler. The

BACT selection for Waste Fuel Boi ler WF is summarized in Table 19. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database. The facility is also taking an opacity limit of 10% on a 6 minute average, except for one 6

- minute period per hour of not more than 27% opacity.PSD Preliminary Determination Page 19 of 49

Table 19: BACT Summary for the Waste Fuel Boiler

Pollutant Control Technology Proposed BACT Limit

PM Dry ESP 0.025 lb/MMBtu

Opacity Dry ESP 10% on a six minute average One 6 minute period per hour of not m ore than 27%

WASTE FUEL BOILER

– CARBON MONOXIDE

Step 1: Identify all Control Technologies

The generation of CO emissions is minimized through the use of good combustion practices, oxidation in a secondary unit, or catalytic conversion to CO 2 . In th e case of the waste fuel boiler combustion effectiveness and the CO emission rate is largely determined by the design of the furnace. The primary types of furnaces used to burn bark are stoker fired units and fluidized bed systems. In fluidized bed syste ms the combustion air is forced up through the boiler at a sufficient velocity to fluidize the boiler bed and therefore heat the fuel quickly and evenly. This technique provides good fuel air mixing and therefore provides more complete combustion than in a stoker

fired boiler. Such boilers are inherently low emitters of CO. The proposed boiler will utilize a fluidized bed boiler design.

Option 1: Staged Combustion and Good Combustion Practices

Option 2: Oxidation (Incineration) Option 3: Catalytic Co nversion

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 20: Ranking of Control Technology Control Technology Ranking Control Techn ology Control Efficiency

1 Staged combustion and Good Combustion Practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 13 of the PSD application is a list from the RBLC database of CO emission limits and controls that are in place for wood waste boilers. The most effective control technology in the database for minimizing CO emission from wood waste boilers is staged combustion and good combustion prac tices. The new waste fuel boiler will be operated using good combustion practices and will utilize a fluidized bed design that should minimize CO emissions. Oxidation and catalytic reduction are not practically feasible due to the same economic and

envir onmental impacts discussed for Recovery Furnace 5.

Step 5: Select BACT

The BACT emission limits for CO range from 0.15 to 0.66 lb/MMBtu and control technologies include combustion control, furnace design and operation, and good combustion practices. Cu rrently there is not a NSPS limit for CO emissions from wood waste boilers. Inland proposes CO BACT to be defined as staged combustion and good combustion practices and an emission rate of 368 ppm @ 3% O2. This is below the proposed MACT limitations for wood waste boilers (400 ppm @ 3% O2) and corresponds to 0.3 lb/MMBtu heat input, which also falls well within theBACT / LAER Clearinghouse levels.

Because the bark and wood waste comes from various sources, and in most cases is stored outdoors, the moistu re content of the fuel can vary widely. The proposed CO BACT level is expected to allow for this fuel variability. This proposed BACT emission limit is intended to apply during all operating conditions, which include firing wood waste, sludge, TDF, and f uel oil separately or in combination.PSD Preliminary Determination Page 20 of 49

Conclusion

– CO Control

The Division has determined that Inland’s proposal to use staged combustion and good combustion practices constitutes BACT. The BACT emission limit has been established as 368 ppm @ 3% O 2 as proposed by Inland. Compliance with the emission limit must be demonstrated through performance testing and monitoring with a

CEMS.

Summary

– Control Technology Review for CO from the Waste Fuel Boiler

To fulfill the PSD permitting requirements for CO, a BACT analysis was conducted for the Waste Fuel Boiler. The

BACT selection for the Waste Fuel Boiler is summarized in Table 21. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database for waste fuel boilers.

Table 21: BACT Summary for the Waste Fuel Boiler

Pollutant Control Technology Proposed BACT Limit Averaging Period

CO Staged Combustion and Good Combustion Practices 386 ppm @ 3% O2 30

- day

WASTE FUEL BOILER

– VOLATILE ORGANIC COMPO UNDS

Step 1: Identify all Control Technologies

As with CO, VOC from a boiler is a result of incomplete combustion and VOCs can be controlled through oxidation as well as catalytic technologies.

Option 1: Staged Combustion and Good Combustion Practices Option 2: Oxidation (Incineration) Option 3: Catalytic Reduction

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 22: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Staged Combustion and Good combustion practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate most effective controls an d document

Table 4

- 14 of the PSD application is a list from the RBLC database of VOC emission limits and controls that are in place for wood waste fired boilers. Good combustion practices are the only control methods listed in the database.

The new wast

e fuel boiler will be operated using good combustion practices. Oxidation and catalytic reduction are not practically feasible due to the same economic and environmental impacts discussed for Recovery Furnace 5.

Step 5: Select BACT

The BACT emission li mits in the database range from 0.016 to 0.23 lb/MMBtu and control technologies include combustion control, furnace design and operation, and good combustion practices. Currently there is not a NSPS

limit for VOC emission from wood waste boilers. Inland proposes VOC BACT to be staged combustion and good combustion practices and an emission rate of 0.05 lb/MMBtu. This proposed BACT emission limit is intended to apply during all operating conditions, which includes the firing of wood waste, sludge, TDF, an d fuel oil separately

or in combination.PSD Preliminary Determination Page 21 of 49

Conclusion

– VOC Control

The Division has determined that Inland’s proposal to use staged combustion and good combustion practices

constitutes BACT. The BACT emission limit has been established as 0.05 lb/MMBtu as proposed by Inland. Compliance with the emission limit must be demonstrated through performance testing and surrogate monitoring of CO emission levels and boiler combustion temperature.

Summary

– Control Technology Review for VOC from the Waste Fuel B oiler

To fulfill the PSD permitting requirements for VOC, a BACT analysis was conducted for the Waste Fuel Boiler.

The BACT selection for the waste fuel boiler is summarized in Table 23. The emission limit selected is representative of previous PSD BACT determination levels published in the RBLC database.

Table 23: BACT Summary for Waste Fuel Boiler

Pollutant Control Technology Proposed BACT Limit

VOC Staged Combustion and Good Combustion Practices 0.05 lb / MMBtu

WASTE FUEL BOILER

– TOTAL REDUCED S ULFUR (including H 2 S)

Summary

– Control Technology Review for TRS and H 2 S from Waste Fuel Boiler WF

Waste Fuel Boiler WF is a potential source of TRS and H 2 S gases. The unit will be used to burn HVLC NCGs, which contain TRS gases, should the facility no t choose to comply with the Clean Condensate Alternative under the Cluster Rule. By injecting these gases into the Waste Fuel Boiler, most, if not all, will be combusted to form SO 2

. Because these gases are controlled to a very high degree (99%+), and no other control technology is considered better, no additional evaluation was considered. The facility will be required to control the TRS gases by at least

99%.

PACKAGE BOILER 2

– PARTICULATE MATTER

Step 1: Identify all Control Technologies

The curren

tly available PM controls include dry ESPs, wet ESPs, cyclones, baghouses, high efficiency wet scrubbers, and burning relatively clean fuels. The theory and operation of each of these control technologies was discussed in detail in previous BACT analyses.

Option 1: Dry Electrostatic Precipitator Option 2: Wet Electrostatic Precipitator Option 3: Dry Filtration (Baghouse) Option 4: Venturi Scrubber Option 5: Cyclone Option 6: Low Sulfur Fuel Oil/Natural Gas

Step 2: Eliminate Technically Infeasible Options

The combustion of natural gas results in very limited PM emissions and it is thought technically infeasible to collect PM from natural gas combustion. Similarly, fuel oil combustion also results in very low PM emissions. The PM

emissions result ing from fuel oil combustion corresponds with the ash content of the fuel oil. Therefore, by burning fuel oil with minimal ash content, PM emissions will be minimized. All options are feasible for fuel oil combustion.PSD Preliminary Determination Page 22 of 49

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 24: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Dry Filtration (Baghouse) ~99.8%

2 ESP ~99.2%

3 Wet Scrubber ~97%

4 Cyclone ~85%

5 Low Sulfur Fuel Oil / Natural Gas 1 N/a

1 According to AP

- 42 emission factors, No. 5 fuel can result in the emissions of twice as much PM per gallon as No. 2 fuel oil, and No. 6 fuel oil (assuming 3% sulfur) can result in fifteen times as much PM per gallon as No. 2 fuel oil.

Step 4: Evaluate Most Effective Controls and Document Results

Table 4

- 15 of the PSD application is a list from the RBLC database of PM emission limits and controls that are in place for natural gas/fuel oil fired boilers. As previously discussed, the o nly technically feasible, and therefore the most effective means of PM control from a natural gas / fuel oil fired package boiler, is through the use of low sulfur (< 0.5% S) fuel oil.

A baghouse would be the most economical and effective add

- on control t echnology available. Based on the EPA cost estimating spreadsheets and the boiler design, the cost of operating a baghouse on the unit is estimated to be $281,000 per year. Based on the total PM emission rate of 16.6 tpy and 99% PM collection, this would equate to a cost effectiveness of $16,900 per ton of PM reduced. Control of PM from this source is therefore not considered

cost effective.

The installation and operation of a venturi scrubber or ESP are equally or even more costly. The cost of operati ng a scrubber is estimated at $270,000 per year. This is equal to $16,400 per ton of PM reduced, not including the handling and treatment of wastewater. An ESP would cost an estimated $630,000 per year, or $38,000 per ton of

PM reduced.

Step 5: Select BACT

The BACT limits in the database range from 0.01 to 0.1 lb/MMBtu. A review of literature for low sulfur oil vendors indicates that the ash content of fuel oil can vary between 0.01% and 0.1% ash. The lowest permitted units would therefore appear to correspond with the lowest range of ash content for fuel oil. However, there is a natural variability of the ash content in fuel oil, and such a limit would not account for this fuel variability. It has not been confirmed that any of the listed units sho wed compliance with a low PM limit when firing fuel with an ash content on the higher end of the ash content range for low sulfur fuel oil. Because of the natural range of fuel oil ash content, Inland proposes a BACT emission level of 0.05 lb/MMBtu, which is expected to correspond with the mid

range of low sulfur fuel oil ash content.

Conclusion

– PM Control

The Division has determined that Inland’s proposal to use low sulfur fuel oil to minimize PM emissions constitutes

BACT. The BACT emission limit ha s been established as 0.05 lb/MMBtu, as proposed by Inland. Compliance with the emission limit must be demonstrated through performance testing and fuel monitoring.

Summary

– Control Technology Review for PM from Package Boiler 2

To fulfill the PSD perm

itting requirements for PM, a BACT analysis was conducted for Package Boiler 2. The BACT selection for Package Boiler 2 is summarized in Table 25. The emission limits selected are representative of previous PSD BACT determination levels published in the RBLC database.

Table 25: BACT Summary for Package Boiler 2

Pollutant Control Technology Proposed BACT Limit

PM Natural Gas/Low Sulfur Fuel Oil 0.05 lb/MMBtuPSD Preliminary Determination Page 23 of 49

PACKAGE BOILER 2

– CARBON MONOXIDE

Step 1: Identify all Control Technologies

As previously discussed, the generation of CO emissions is minimized through the use of good combustion practices, oxidation in a secondary unit, or catalytic conversion to CO 2

.

Option 1: Good Combustion Practices Option 2: Oxidation Option 3: Catalytic Conversion

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 26: Ranking of Control Technology
Control Technology Ranking Control Technology Con trol Efficiency

1 Good combustion practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate most effective controls and document

Oxidation and catalytic reduction are not practically feasible due to the same economic and environmental impact issues discussed for Recovery Furnace 5. It is estimated that an RTO (the most economical of the options) would cost $7,400 per ton of CO reduced. NO X emissions would also increase with the use of an RTO by about 20 tpy

. Any increase in NO X

emissions is highly undesirable because NO X forms ozone in the presence of heat and sunlight. The North Georgia area is already impacted by excess ozone, so it is important to preserve the 119 ton per year

reduction in NO

X emissions achieved by this project. Good combustion practices are the only feasible control

methods.

Step 5: Select BACT

Table 4

- 17 of the PSD application is a list from the RBLC database of CO emission limits and controls that are in place for fuel oil boilers . These limits range from 0.08 to 1.76 lb/MMBTU and control technologies include combustion control, furnace design, and good combustion practices. Currently there is not a NSPS limit for CO emissions for fuel oil boilers. Inland proposes CO BACT to be good combustion practices and an emission limit of

0.20 lb/MMBtu.

Conclusion

– CO Control

The Division has determined that Inland’s proposal to use good combustion practices to minimize CO emissions

constitutes BACT. The BACT emission limit has been est ablished as 0.20 lb/MMBtu as proposed by Inland. Compliance with the emission limit must be demonstrated through performance testing and monitoring furnace

oxygen.

Summary

– Control Technology Review for CO from Package Boiler 2

To fulfill the PSD permi

tting requirements for CO, a BACT analysis was conducted for Package Boiler 2. The BACT selection for Package Boiler 2 is summarized in Table 27. The emission limits selected are representative of previous PSD BACT determination levels published in the R BLC database.

Table 27: BACT Summary for Package Boiler 2

Pollutant Control Technology Proposed BACT Limit

CO Good Combustion Practices 0.20 lb / MMBtuPSD Preliminary Determination Page 24 of 49

PACKAGE BOILER 2

– VOLATILE ORGANIC COMPOUNDS

Step 1: Identify all Control Technologies

As with CO, VOC emissions from a boiler are a result of incomplete combustion and VOCs can be controlled through oxidation as well as catalytic technologies.

Option 1: Good Combustion Practices Option 2: Oxidation (Incineration) Option 3: Catalytic Reduction

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 28: Ranking of Control Technology Control Technology Ranking Control Technology Con trol Efficiency

1 Good combustion practices N/a

2 Oxidation (Incineration) 95%

- 98%

3 Catalytic Reduction 95%

- 98%

Step 4: Evaluate most effective controls and document

Table 4

- 18 of the PSD application is a list from the RBLC database of VOC emis sion limits and controls that are in place for fuel oil fired boilers. Good combustion practices are the only control methods in the database. Oxidation and catalytic reduction are not practically feasible due to the same economic and environmental impac t issues discussed for Recovery Furnace 5. It is estimated that an RTO (the most economical of the options) would cost $180,000 per ton of VOC reduced. NO X emissions would also increase with the use of an RTO by about 20 tpy. Any NO X increase is undesir able for the reason previously discussed.

Step 5: Select BACT

The BACT emission limits range from 0.0017 to 0.09 lb/MMBtu and control technologies include combustion control, furnace design and operation, and good combustion practices. Inland proposes VOC BACT to be defined as staged combustion and good combustion practices and an emission limit of 0.02 lb/MMBtu.

Conclusion

– VOC Control

The Division has determined that Inland’s proposal to use good combustion practices to minimize VOC emissions

const itutes BACT. The BACT emission limit has been established as 0.02 lb/MMBtu as proposed by Inland. Compliance with the emission limit must be demonstrated through performance testing and monitoring furnace

oxygen.

Summary

– Control Technology Review for VOC from Package Boiler 2

To fulfill the PSD permitting requirements for VOC, a BACT analysis was conducted for the Package Boiler 2. The BACT selection for Package Boiler 2 is summarized in Table 29. The emission limits selected are representative of

p revious PSD BACT determination levels published in the RBLC database.

Table 29: BACT Summary for Package Boiler 2

Pollutant Control Technology Proposed BACT Limit

VOC Good Combustion Practices 0.020 lb/MMBTUPSD Preliminary Determination Page 25 of 49

LINERBOARD MACHINES P1 and P2

- VOLATILE O RGANIC COMPOUNDS

Step 1: Identify all Control Technologies

The virgin pulp supplied to a linerboard machine has an organic component, which can be emitted to the atmosphere during the linerboard making process. In particular, the drying step can subjec t the pulp to high temperatures, which can cause some of the organics to be emitted. In addition, some linerboard machines can use additives or cleaners that contain VOCs, which are in turn emitted from the machines.

Though no known linerboard machines use VOC control devices, oxidation of the organics in a RTO or similar device must be considered. Good work practices are the control method primarily utilized for VOC emissions from

linerboard machines.

Option 1: Good Work Practices

Option 2: RTO

St ep 2: Eliminate Technically Infeasible Options

All options are technically feasible.

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 30: Ranking of Control Technology Control Technology Ranking Control Technology Control Efficiency

1 Good Work Practices N/a

2 RTO 95%

- 98%

Step 4: Evaluate most effective controls and document

Table 4

- 15 of the PSD application provides a list of the VOC emission limits that are currently in place for

linerboard machines in the EPA BA CT/LAER Clearinghouse database. As shown, the VOC emission limits vary between 19.75 and 260 pounds per hour VOC. The database shows that the most effective control technology for minimizing the VOC emissions from linerboard machines is good work place o perations, which include properly washing the pulp before it is sent to the linerboard machines.

No applications have been identified which utilize oxidation for the control of VOC emission from a paper machine. An economic analysis for installing an RTO was completed to evaluate the potential costs involved. Costs are largely dependent upon the exhaust flow rates from a system, and because of the large size of a paper machine and the large volume of exhaust air, the costs would be significant. The EPA costs spreadsheet for RTOs and estimated flow rates from the paper machine vents (2,300,000 acfm from 64 vents) were used to estimate the costs of operating an RTO on the exhaust gases from the linerboard machines.

An RTO on the linerboard machines would require an estimated capital investment of $60,000,000 with operating costs of $14,000,000 per year. Based on the proposed BACT emission rate, this equates to $16,400 per ton of VOC removed. This addresses only the estimated cost of the control device. The cost of hooding, to collect all emissions, and the necessary ductwork would likely increase these costs significantly. Because a primary function of the paper machine is to remove water from the pulp, this air stream would contain significant amounts of water. This would result is very high fuel costs to heat the water while heating up the organic component of the air stream for destruction. The use of an RTO is therefore not considered BACT because of the high costs, significant increase in

energy c onsumption (natural gas and electricity used by the RTO), and the significant increase in NO X emissions (estimated at greater than 100 tpy) that would result from the combustion of natural gas in the RTO.PSD Preliminary Determination Page 26 of 49

Step 5: Select BACT

The information known about the amount of VOC emitted from linerboard machines utilizing virgin fiber is limited to a stack testing study conducted by the National Council for Air and Stream Improvement (NCASI). The results of this study are documented in NCASI Technical Bulletin 6 81. NCASI conducted Total Hydrocarbon (THC) Method 25A and Method 18 stack testing of linerboard machines utilizing softwood and hardwood as well as recycled fiber. Inland is proposing a VOC BACT limit of 1.82 pounds per air dried ton pulp (based on the sum of the speciated VOC compounds) for the linerboard machines without controls. This level will be achieved through the good work place practice of properly washing the pulp before it is sent to the machines.

This proposed value is higher on a pound pe r hour basis than several of the units listed in the EPA BACT/LAER Clearinghouse. However, the sizes of the listed paper machines are not known; therefore they cannot be compared on a pound per air dried ton basis. Furthermore, the proposed BACT level is based on the sum of the speciated VOC compounds. Based on the permit dates, it is expected that the units listed in the RBLC database were based on Method 25A sampling. The tested linerboard machines used as a basis for the proposed BACT level had a Met hod 25A result of 0.62 pounds per air dried ton pulp, which is significantly lower as compared to the sum of the speciated value.

Conclusion

– VOC Control

The Division has determined that Inland’s proposal to use good work practices for linerboard VOC co ntrol constitutes BACT. The BACT emission limit has been established as 1.82 pounds per ton air dried pulp as proposed by Inland. Compliance must be assured by making sure that the pulp is properly washed before it is sent to the

linerboard machines and by performance testing.

Summary

– Control Technology Review for VOC Linerboard Machines P1 and P2

To fulfill the PSD permitting requirements for VOC, a BACT analysis was conducted for Linerboard Machines P1

and P2. The BACT selection for the machines is summarized in Table 31.

Table 31: BACT Summary for Linerboard Machines P1 and P2

Pollutant Control Technology Proposed BACT Limit

VOC Good Work Practices 1.82 lb/adtp

5.0 TESTING AND MONITORING REQUIREMENTS

Recovery Furnace 5:

Testing Requirements Recovery Furnace 5 is currently required by the current Title V permit to undergo annual PM and SO 2 stack testing and biennial TRS testing. This testing will continue at the frequency outlined in the current Title V permit. The facility is required by th is amendment to conduct initial performance tests for PM, opacity, TRS, H 2 S, CO, VOC,

and SO 2 . The tests are necessary to determine compliance with limits under PSD, 40 CFR 60 Subpart Db, 40 CFR 60 Subpart MM, and 40 CFR 60 Subpart BB at the new, higher, black liquor solids production rate.

Monitoring Requirements The Permittee is required to continuously monitor TRS, H 2 S, furnace oxygen, and opacity in accordance with 40 CFR 52.21, 40 CFR 60 Subpart BB, 40 CFR 63 Subpart MM, and 40 CFR 60 Subpart Db. Th e continuous monitoring systems are necessary to determine compliance with the limits found in Condition 3.3.6 of this

amendment.

The facility is required to monitor secondary current and secondary voltage of the Recovery Furnace ESP on a

continuous basis . The total power performance indicator is then calculated from the current and voltage data. The proper operation of the ESP provides a reasonable assurance of compliance with the PM emission limits under 40 CFR 63 Subpart MM and 40 CFR 52.21 found in C onditions 3.3.6 and 3.4.5.PSD Preliminary Determination Page 27 of 49

The Permittee is required to monitor the black liquor feed rate and black liquor solids content as fed to the Recovery Furnace. The black liquor records are necessary to demonstrate compliance with the Georgia Rule (e) PM limi t in

Condition 3.4.5 and the SO 2 PSD limit in Condition 3.3.6. The records are also necessary to determine compliance with the PSD limit for daily black liquor solids in Condition 3.3.62.

The Permittee is required to monitor the amount and type of fuel b urned in Recovery Furnace 5 on a continuous basis. The fuel records are necessary to provide a reasonable assurance of compliance with the annual capacity factor limit in Condition 3.3.7 (40 CFR 60 Subpart Db) and the low sulfur fuel oil limit in Conditio n 3.3.8 (40 CFR 60 Subpart Db). The fuel records are also necessary to determine compliance with the fuel oil firing limit (PSD Avoidance) in Condition 3.3.61.

No direct periodic monitoring is required for CO or VOC emissions. For both pollutants, exces s emissions are a result of incomplete combustion. The completeness of combustion is indicated by the furnace oxygen (percent oxygen) value. The facility will therefore be required to continuously monitor furnace oxygen to assure sufficiently complete co mbustion to demonstrate ongoing compliance with the PSD limits for both pollutants.

CAM Applicability The monitoring of the secondary power on Source Code ESP5 will meet the requirements of the Compliance Assurance Monitoring (CAM) plan. See Section 3.0 of the Preliminary Determination for a discussion of CAM requirements.

Power Boiler 4:

Testing Requirements Power Boiler 4 is currently required to undergo annual PM stack testing. This testing will continue at the frequency

outlined in the current Titl e V permit. The facility will be required to undergo initial performance testing for opacity, PM, CO, VOC, and NO X emissions from Power Boiler 4 when the modifications to unit are completed.

Monitoring Requirements The Permittee is required to measure th e secondary current and secondary voltage for the electrostatic precipitator controlling emissions from this boiler on a continuous basis. The secondary parameters must then be used to calculate the total power once per shift. Monitoring of the secondary parameters and calculating the total power provides a reasonable assurance of compliance with the PM limit found in Condition 3.3.63 (PSD).

The Permittee is required to operate a COMS on the power boiler. The monitor provides a reasonable assurance of

c ompliance with the Georgia Rule (b) opacity limit found in Condition 3.4.11.

The Permittee is required to operate a CEMS for NO X for Power Boiler 4. The CEMS is necessary to provide a reasonable assurance of compliance with the PSD Avoidance limit in Con dition 3.3.63.

Compliance with the PSD and PSD Avoidance limits for SO 2 from Power Boiler 4 will be determined using the calculation method discussed in Condition 6.2.26. The facility will need to continue to monitor fuel type, quantity,

and sulfur conte

nt to calculate the emissions on both an hourly and a 12

- month rolling basis.

The facility is required to operate a continuous monitoring system for furnace oxygen for Power Boiler 4. Furnace oxygen is an indicator of the completeness of combustion. Goo d combustion practices keep emissions of CO and VOC to a minimum. The furnace oxygen continuous monitor provides a reasonable assurance of compliance with

the CO and VOC PSD limits found in Condition 3.3.63.

The Permittee is required to monitor the amoun t of fuel burned in Power Boiler 4 on a continuous basis. The fuel records are necessary to provide a reasonable assurance of compliance with allowable fuel Condition 3.3.64, the low sulfur fuel oil limit in Condition 3.3.67, the coal sulfur limit in Cond ition 3.3.66, and the fuel oil burning limit in

Condition 3.3.65. All of the limits are for PSD Avoidance.

Package Boiler 2:

Testing Requirements Package Boiler 2 will be required by this amendment undergo annual CO stack testing. The facility will be required by this amendment to conduct initial performance tests for PM, opacity, CO, VOC, and NO X . The tests are necessary to determine compliance with limits under PSD and 40 CFR 60 Subpart Db.PSD Preliminary Determination Page 28 of 49

Monitoring Requirements The Permittee is required to use a C EMS to monitor emissions of NO X . The monitor provides a reasonable assurance of compliance with the limits found in Conditions 3.4.31 and 3.3.56 (40 CFR 60 Subpart Db and Georgia Rule (lll)). The facility is also required to continuously monitor opacity in order to demonstrate compliance with the limit in Condition 3.3.68 (Subpart Db).

The Permittee is required to monitor the amount of fuel burned in Package Boiler 2 on a continuous basis. The fuel records are necessary to provide a reasonable assurance of compliance with the allowable fuel / low sulfur fuel oil limit in Condition 3.3.57 (PSD Avoidance). The records are also necessary to demonstrate compliance with the annual fuel oil limit in Condition 3.3.69 (PSD Avoidance).

The Permittee is required to maintain records for each steam

- generating unit operating day for Package Boiler 2. These records are necessary to demonstrate compliance with the NO X limits in 40 CFR 60 Subpart Db.

No periodic monitoring is required for PM. Based on the fuels burn ed in the boiler (natural gas and very low sulfur fuel oil) violation of this limit is not likely. In addition, monitoring of furnace oxygen provides a reasonable assurance of good combustion practices, which will minimize PM emissions.

No direct periodi

c monitoring is required for CO or VOC emissions. Good combustion practices keep emissions of CO and VOC to a minimum. Furnace oxygen is an indicator of good combustion. The furnace oxygen continuous monitor provides a reasonable assurance of compliance with the CO and VOC PSD limits found in Condition

3.3.68.

No direct monitoring is required for SO 2 emissions. Based on the sulfur content limit for fuel oil to be burned in the boiler, violation of this limit is highly unlikely. The Permittee is requir ed to maintain records of the sulfur content

of the fuel oil burned in the boiler.

Waste Fuel Boiler:

Testing Requirements Waste Fuel Boiler WF will be required by this amendment to undergo annual PM stack testing as well as initial performance testing f

or PM, opacity, CO, VOC, SO 2 , and NO X . The tests are necessary to determine compliance with limits under PSD and Subpart Db. The facility will also have to conduct initial performance tests for HVLC NCG destruction per 40 CFR 63 Subpart S and wastewater sludge mercury emissions per 40 CFR 61 Subpart E.

Monitoring Requirements The Permittee is required to use CEMS to monitor emissions of NO X , SO 2 , and CO. The monitors provide a reasonable assurance of compliance with the limits found in Conditions 3.3.73 and 3.4.32 (40 CFR 60 Subpart Db, PSD, PSD Avoidance, and Georgia Rule (g)). The facility is also required to continuously monitor opacity in order to demonstrate compliance with the limit in Condition 3.3.73 (40 CFR 60 Subpart Db and 40 CFR 52.21).

The Permittee is required to continuously measure the secondary current and secondary voltage for the electrostatic precipitator controlling emissions from this boiler. The secondary parameters must then be used to calculate the total power. Monitoring of t he secondary parameters and the total power provides a reasonable assurance of compliance with the PM limit found in Condition 3.3.73 (PSD).

The Permittee is required to monitor the types of fuels and fuel quantities combusted in the Waste Fuel Boiler. T he records are necessary to determine compliance with the fuel burning limits in Condition 3.3.74 (PSD Avoidance).

The Permittee is required to maintain records for each steam

- generating unit operating day for Waste Fuel Boiler

WF. These records are nece ssary to demonstrate compliance with the NO X limits in 40 CFR 60 Subpart Db.

No direct periodic monitoring is required for VOC emissions. The facility will use a two

- pronged approach to provide assurance of compliance with the VOC limit. During the VOC initial performance test, the facility must establish a maximum CO concentration that indicates compliance with the VOC limit. The facility will also establish a minimum combustion temperature for the boiler. A reasonable assurance of compliance can be a chieved through monitoring these two parameters. Also, if the facility is in compliance with the CO PSD limit, it is highly unlikely that the VOC limit will be exceeded, based on AP

- 42 emission factors and the emission limits set forth in the permit.PSD Preliminary Determination Page 29 of 49

The facility is required to conduct wastewater sludge sampling on a quarterly basis. The facility is then required to use the data to calculate the emission rate of mercury per 24

- hour day. The sampling requirements provide a reasonable assurance of complia nce with the mercury limit found in Condition 3.3.76 (40 CFR 61 Subpart E).

The facility will also re required to continuously monitor and record the combustion zone temperature of Waste Boiler WF when burning waste gases from the HVLC NCG systems (if thi s control strategy is implemented). The facility must monitor steam production rate and the number of hours that HVLC gases are burned in the boiler in order to properly calculate SO 2 emissions. This data can also be used to verify compliance with 40 CFR 63 Subpart S, Phase II.

CAM Applicability: Waste Fuel Boiler WF is subject to the requirements of CAM (compliance assurance monitoring) as specified in 40 CFR Part 64. CAM is applicable to emission units that have potential emissions greater than the ma jor source threshold, located at a major source, use a control device to control a pollutant emitted in an amount greater that the major source threshold for that pollutant, and there is a specific emission standard for that pollutant. The facility

uses a control device to control PM emissions (use of the dry ESP) and potential emissions of PM are greater than 100 tpy; therefore, a CAM plan was submitted by Inland. Under the CAM plan submitted for the unit, the mill will monitor secondary power on the ESP to monitor compliance with the PM limit. See Section 3.0 of the Preliminary Determination for a discussion of CAM requirements.

Lime Kilns:

Testing Requirements The lime kilns will be required by the amendment to undergo retesting for TRS and SO 2 and t o perform an initial test for particulate matter under Subpart MM.

Monitoring Requirements The Permittee is required by the current permit to continuously monitor TRS and O 2 from the Lime Kilns in order to

calculate and record 12/24 hour total reduced sul fur averages in accordance with 40 CFR 60 Subpart BB. The data is needed to demonstrate compliance with the TRS limits found in Conditions 3.3.1 and 3.4.3

Pressure drop and scrubbant flow rate for the lime kiln scrubbers are required to be measured and r ecorded on a continuous basis in accordance with 40 CFR 60 Subpart BB and 40 CFR 63 Subpart MM. The proper operation of the scrubbers provides a reasonable assurance of compliance with the PM and opacity limits found in Conditions
3.3.1, 3.3.59, 3.4.1, an d 3.4.2. These limits include those contained in Georgia Rules (b) and (e).

There is no monitoring required for SO 2 from the lime kilns. The regenerated lime acts as a scrubbing agent for the pollutant; therefore the likelihood of violation of the PSD l imits in Conditions 3.3.1 and 3.3.2 is minimal.

In order to collect operational data for the kilns, the facility is required to monitor and record the lime mud production rate and the lime mud solids content.

Smelt Tank 5:

Testing Requirements
The smelt tank will be required to undergo retesting for TRS and SO 2 . Also, an initial performance test is required for PM under Subpart MM.

Monitoring Requirements The Permittee is required to continuously monitor the pressure drop and scrubbant flow rate for th e smelt tank scrubber in accordance with 40 CFR 63 Subpart MM. The proper operation of the scrubber provides a reasonable assurance of compliance with PM opacity limits found in Conditions 3.3.11.a and 3.4.9 (40 CFR 63 Subpart MM, PSD, and Georgia Rule (b )). Also, because the scrubbant is caustic, the operation of the scrubber also provides a reasonable assurance of compliance with the SO 2 and TRS limits in Conditions 3.3.11 and 3.4.8 (PSD and Georgia Rule (gg)).PSD Preliminary Determination Page 30 of 49

HVLC NGCs:

If the facility does not com ply with the Clean Condensate Alternative allowed by the Cluster Rule, the HVLC gases will be combusted in the Waste Fuel Boiler. There are no monitoring requirements under the Cluster Rule for the introduction of the gases with the primary fuel or into t he flame zone. Under PSD, the facility is required to achieve 99% destruction efficiency for these TRS gases. The facility is required to monitor combustion temperature to provide a reasonable assurance that the minimum destruction efficiency is achieved

.

Linerboard Machines P1 and P2:

Testing Requirements The amendment requires the facility to conduct performance testing for the linerboard machine VOC limit under

Condition 3.3.78.

Monitoring Requirements The facility is required to develop and submit for approval a set of good work practice standards for the handling of pulp so that VOC emissions at the paper machines are minimized.

6.0 AMBIENT AIR QUALITY REVIEW

An air quality analysis is required to determine the ambient impacts associated with the proposed mill optimization project. The purpose of the air quality analysis is to demonstrate that emission increases or decreases from the proposed project, will not cause or contribute to a violation of any applicable National Ambient Air Quality

Stand ard (NAAQS) or PSD increment in a Class I or Class II area. This analysis is required for each pollutant emitted in an amount over the PSD significant emission rate threshold. As shown in Table 1 of this document,

PM/PM 10 , CO, TRS, and H 2 S exceed the PSD

significant threshold. Thus an air quality analysis was performed for these pollutants. Compliance with any NAAQS or PM increment is based on the modeled ambient impact caused by the applicant’s proposed emissions as well as those sources surrounding th e mill within the impact area.

Modeling Basis:

The Rome Linerboard Mill is located off of a section of Mays Bridge Road in Rome, Georgia between Turner Bend Road and State Route 20. The facility owns property on both sides of the road. During the devel opment of this project, the facility determined that the modeling indicated an exceedance of the 24

- hour NAAQS for PM/PM 10 on and along the road. The facility therefore assume that the public is exposed to pollutant concentrations on the road 24 hours per

day and 365 days per year because it is open to the public.

The facility considers this optimization project key to the mill’s survival and is aware that a permit cannot be issued when the modeling for the modification indicates a NAAQS exceedance. The mill therefore began discussions with the Floyd County Commission to close the Inland section of Mays Bridge Road before submitting the permit application to the EPD. It is the EPD’s understanding that the County Commission agreed to close the road provid ed that EPD modeling duplicated the results found by Inland’s consultant. The EPD Data and Modeling Unit has confirmed that the modeling for this modification project shows a 24

- hour PM/PM 10 concentration of 181 ug/m 3

on the road. This is above the stand ard of 150 ug/m

3

.

The modeling results presented in this preliminary determination were obtained based on the understanding that the section of Mays Bridge Road in question will be closed to the public. A requirement to this effect is included in Part

6. 0 of the permit amendment. It should be noted, however, that the decision regarding the closure of Mays Bridge Road to the public rests with the Floyd County Commission.

Monitoring:

EPD maintains a state and local ambient monitor (SLAM) for PM in Floyd County in the vicinity of the Rome Linerboard Mill. The ambient air quality in Floyd County can be adequately estimated by using background concentrations for similar areas in Georgia. The existing network of Georgia monitors has been determined to be

ab le to provide representative data that may be used in place of pre

- construction monitoring by the company.PSD Preliminary Determination Page 31 of 49

Modeling:

In general, the EPD assesses the ambient impact of a source through the use of mathematical dispersion models.

The models are based on the assumption that the dispersion of pollutants is primarily a function of wind speed and direction, atmospheric stability conditions, and the characteristics of the effective point discharge of the exhaust plume. To predict ambient air concentrations, t he models simulate the plume exhausting from the stack, rising a certain distance into the atmosphere, leveling off, and continuing downwind over relatively flat terrain. The concentrations of the pollutants are assumed to have a Gaussian distribution abo ut the downwind axis centerline of the plume.

In analyzing the air quality impact of these modifications, the EPA Industrial Source Complex Short

- Term Version 3 (ISCST3) model was used for all PSD modeling results presented in the preliminary determinatio n. ISCST3 is a Gaussian plume dispersion model that estimates hour

- by

- hour ground

- level concentrations of emissions from an elevated source. The model provides maximum 24

- hour and annual average concentrations for receptors located on many grid types aro und the source for various downwind distances. The model also takes into account the effect of downwash caused by nearby buildings and structures.

For the air quality analyses, National Weather Service (NWS) meteorological data from the years 1974

- 1978 f or Atlanta, Georgia were used as surface data and the same years for Athens, Georgia were used as upper air data. EPA’s Building Profile Input Program (BPIP) was used to calculate flow vectors based on 36 possible wind

directions in order to allow for bui lding downwash. The modeling included all stacks with applicable emission changes resulting from the production increase, and the individual stack parameters were used in calculating building downwash using BPIP.

Increment Consumption:

The PSD regulatio ns establish specific maximum allowable increases in ambient concentrations (or increments) for

PM 10 , NO

x , SO

2 , and CO for all areas in compliance with the NAAQS. All areas of the country are categorized as a function of overall use. The regulations were designed to prevent significant air quality deterioration by specifying allowable incremental changes in PM 10 , NO X , SO 2 and CO concentrations within each area category. The area categories are defined below:

Class I

– Those areas where almost any deterio ration of current air quality is undesirable, and little or no industrial development would be allowed (e.g., national parks, wilderness areas).

Class II

– Those areas where moderate, well

- controlled energy or industrial growth is desired without air qual ity deterioration up to the national standards (all attainment areas not categorized as Class I were initially designated Class II).

Class III

– Those areas where substantial energy or industrial development is intended, and where modest

increases in ambi

ent concentrations above Class II increments, but below national standards, would be allowed (designation to Class III must follow strict redesignation procedures).

The Floyd County area and all other attainment areas in Georgia, not designated as Class I areas, are Class II areas. The Class I areas nearby the facility are Cohutta Wilderness, Sipsey NWA, Joyce Kilmer NWA, and The Smokey

Mount National Wildlife Area.

The first step in the air quality analysis was to determine whether the incremental ambien t impacts due to new emissions from the project were greater than U.S. EPA

- prescribed Modeling Significance Levels. This “significance analysis” determined whether the Inland mill could forgo a full

- scale impact analysis to demonstrate compliance

with the NAAQS and PSD Class II Increments.

The results of the significance analysis conducted for the Rome Linerboard mill expansion project are summarized in Table 32. The impacts due to the total project emissions of PM 10, CO, TRS, and H 2 S were calculated in th is analysis using the ISCST3 dispersion model. Table 32 shows the highest concentration modeling result for each pollutant. The complete modeling analysis results are located in Section 5 of the Permit Application. The EPD modeling results are found in Appendix C of this document.PSD Preliminary Determination Page 32 of 49

Table 32. Significant Impact Levels and Significant Monitoring Concentrations

Pollutant Averaging

Period PSD Significant

Impact Level (ug/m 3 ) Monitoring

Concentration Level (ug/m 3 ) Modeled

Concentration (ug/m 3 ) Notes

24

- Hour 5 10 67.2 Additional modeling needed PM 10 Annual 1

-- 8.8 Additional modeling needed

1

- Hour 2,000

-- 1197 No further modeling needed CO 8

- Hour 500 575 447 No further modeling needed

H 2 S 1

- Hour

-- 0.2 27.1 No further modeling needed

TRS 1

- Hour

-- 10 560 No further modeling needed

As shown in Table 32, the project’s impact is below the significant impact level (SIL) for both CO averaging periods; therefore no further modeling is required for this pollutant. The maximum CO concentration is below its corresponding pre

- construction monitoring levels; therefore no monitoring is required for CO.

The maximum PM 10 concentration did exceed its SIL; therefore refined modeling is required for the pollutant.

PM 10 , H 2 S, and TRS did exceed their pre

- constructi on monitoring levels. A state local area monitor (SLAM) for

PM 10 is close enough to be considered representative of background emission, therefore pre

- construction monitoring is not considered necessary for PM 10 . The mill currently has on

- site TRS monito rs; therefore no additional monitoring of that pollutant is considered warranted. H 2 S is a component of TRS; therefore pre

- construction monitoring of that pollutant was also not considered necessary.

Because the modeled PM 10 concentration increases excee d the SILs, further modeling is required under PSD to

ensure that the Class II PSD increment for the area is not consumed. This further evaluation must include all sources within 50 kilometers of the project’s area of impact. The area of impact is determ ined by the farthest distance from the site that exceeded the SIL. This distance was 14 km; therefore, along with the modeled sources,

all increment

- consuming sources within 64 km (14 km + 50 km) of the Rome mill were included in the modeling. Georgia EP D has provided (via our web page) Inland Rome with a list of all the increment consuming sources that qualify.

Table 33. Class II PSD Increment Impacts

Pollutant Averaging

Period PSD Increment

(ug/m 3 ) Modeled Concentration (ug/m 3 ) Notes

24

- Hour 30 15.7 Includes all sources within 64 km PM 10 Annual 17 1.7 Includes all sources within 64 km

As shown in Table 33, the modeled impacts of PM 10 are below the PSD increment. Given this, the proposed project will comply with the PSD Class II Increment analysis.

Ambient Air Quality:

The NAAQS are established as ambient ceilings applicable to the entire country, and they must be attained and maintained. PSD requires that any pollutant that has predicted significant impacts due to the modification alone

must be evaluated for NAAQS compliance. Table 32 shows that PM 10 was above the significant impact level; therefore it must be evaluated further. The ISCST3 model was used with the addition of all contributing sources within 64 km of the Inland mill. The backgro und concentrations, as determined by the EPD, were added to the modeled results. In all cases, the modeled impacts are below the associated NAAQS limits.

Table 34. Ambient Air Quality Impacts

Pollutant Averaging Period Modeled Conc. (ug/m 3 ) Background Conc.

(ug/m 3 ) Combined Conc.

(ug/m 3 ) NAAQS

(ug/m 3 )

24

- Hour 84.1 38 122.1 150 PM 10 Annual 14.7 20 36.8 50PSD Preliminary Determination Page 33 of 49

Class I Evaluation:

The impacts for the proposed project on the Class I area within 100 km of the Rome Linerboard Mill were also

evaluated. Since

the mill is located roughly 98 km from the Cohutta Wilderness Class I Area in North Georgia, a modeling evaluation of Cohutta was completed. This analysis was completed per discussions with the Cohutta Wilderness Area and as outlined in the “Air Quality Related Values Status and Information Needs for PSD Class I Area Impact Analysis (per Flag)” dated May 31, 2001 and the Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) Phase I Report” dated December 2000.

The purpose of the Class I Area modeling analysis is to demonstrate that the new project will not consume more than the available Class I PSD Increments in the Class I Area. A significance analysis was conducted, first to determine whether the project could be expected to have a signif icant impact in the Class I Area. Table 35 details the findings of the modeling for the Cohutta Wilderness Class I Area for the proposed project. PM and SO 2 emission at the Cohutta Wilderness Class I Area are below the EPA Class I screening levels and no further analysis is required.

Table 35. Class I Area Evaluation

Pollutant Averaging

Period AQRV Level

(ug/m 3 ) Modeled Conc.

(ug/m 3 ) Notes

24

- Hour 0.32 0.18 No additional modeling required PM 10 Annual 0.16 0.013 No additional modeling required

3

- H our 1 0.086 No additional modeling required

24

- Hour 0.2 0.022 No additional modeling required SO 2 Annual 0.08 0.0013 No additional modeling required

Complex Terrain:

Because s ome of the area surrounding the mill is classified as complex terrain (terrain which is equal to or exceeds the lowest stack height of the sources being modeled), a complex terrain modeling analysis was completed. The complex terrain modeling was based on the EPA guidance memo on complex terrain modeling “Complex Terrain Modeling P rocedures” dated May 19, 1999. Following the guidance, screening modeling was completed in the default mode for complex terrain that takes the greater of the applicable predictions from the complex and simple terrain algorithms. If the resulting concentr ations are below the SIL, no further air quality analysis (modeling to demonstrate compliance with the NAAQS or PSD Increment) is required. As demonstrated, the project’s impact is below the SILs for CO, however above the SIL for PM 10 ; therefore, complex terrain analysis is required for PM 10

. A further evaluation of the PM 10 modeling found the complex terrain algorithms were the controlling algorithm in the complex terrain, and therefore a CTSCREEN modeling analysis was required. The CTSCREEN runs were

c ompleted using identical source emission data that was utilized in the ISCST3 NAAQS and PSD Increment models. All modeled hills showed compliance with both the NAAQS and PSD Increment standards. This was verified by

the EPD.

Air Toxics:

There are no ap

plicable NAAQS or specific Georgia ambient air standards for the non

- criteria pollutants listed in Table 1. Impacts from each of the pollutants listed Table 5

- 18 of the permit application were analyzed using the

EPD Guidance for Ambient Impact Assessment of Toxic Air Pollutant Emissions (referred to as the Georgia Air Toxics Guideline; Version June 21, 1998). The Georgia Air Toxics Guideline is a guide for estimating the environmental impact of sources of toxic air pollutants.

A toxic air pollutant is d efined as any substance that may have an adverse effect on public health, excluding any specific substance that is covered by a State or Federal ambient air quality standard. The EPA SCREEN3 computer screening dispersion model was used to predict the maxi mum 15

- minute, 24

- hour, and annual average ground level concentration (referred to as Maximum Ground Level Concentration (MGLC)) for each pollutant. Each MGLC was compared to its respective Acceptable Ambient Concentration (AAC). The basis for calculati on of AAC comes from the pollutant toxicity rating systems described in the Georgia Air Toxics Guideline (dated June 1998). If the screening analysis did not demonstrate an acceptable M GLC, the ISCST3 refined dispersion model was used to predict a more ac curate MGLC.PSD Preliminary Determination Page 34 of 49

The SCREEN3 evaluation demonstrated that maximum impacts of toxic air pollutants due to the proposed project are less than the maximum AAC levels for all compounds except acrolein, benzene, arsenic, chloroform, methyl mercaptan, formaldehyde , hexavalent chromium, and hydrogen sulfide. As per the Georgia Guidelines, ISCST3 modeling was completed for those pollutants that were not screened out through the SCREEN3 program. Based on EPD’s analysis, the predicted MGLC for each applicable polluta nt is below its Georgia EPD AAC. Appendix C of this document contains the toxic modeling results.

Class I Visibility Analysis:

Emissions from certain sources can create visible, defined plumes that are noticeable to the casual observer. An exhaust plum

e visibility analysis was performed for this project to assure that the emissions from the project do not create a noticeably visible plume in a Class I Area.

The visibility analysis breaks up the evaluation approach into two groups for evaluation: Sourc es that are within 50 km of the Class I Area and sources which are greater than 50 km from the Class 1 Area. In the case of the Inland mill, the distance from the mill to the closest Cohutta Class I Area boundary is 98 km; therefore the “greater than 50

k m” method was utilized in order to determine the project’s impact on Cohutta. The goal of this approach is to utilize the Calpuff model to determine the change from the specified reference levels for the Class I Area and compare the change with the prescr ibed threshold values.

Under the Cohutta Class I Area guidance, if the proposed project results in a percent change in B

- extinction which is always less than 5 %, the project can proceed without further analysis. This analysis found a maximum B ext for th e 5 years of modeled data of 0.88%, which is below the 5% level. Therefore no further analysis was completed.

In addition to the visibility analysis, an evaluation of the incremental consumption of particulate matter on Cohutta was also completed. In ad dition to providing visibility impacts, the Calpuff model provided peak concentrations of the pollutants modeled. Current EPA guidance indicates that if the increment consumption is less than the PM and

SO 2 , screening levels then no additional modeling is required. As shown in Table 35 the concentrations are below these levels for all pollutants; therefore no additional modeling evaluation was necessary for increment consumption

at Cohutta.

Class II Visibility Analysis:

A Class II visibility analysis wa s evaluated for the nearest Class II area to the facility utilizing the VISCREEN model. The nearest Class II area is the Richard B. Russell Airport, which is approximately 18.4 km from the Inland facility.

The primary variables that affect whether a plum e is visible or not at a certain location are (1) quantity of emissions, (2) types of emissions, (3) relative location of source and observer, and (4) the background visibility range. For this project, visibility analysis was performed using the latest ve rsion of the EPA VISCREEN model according to the guidelines published in the Workbook for Plume Visual Impact Screening and Analysis (EPA

- 450/4

- 88

- 015). The VISCREEN model is designed specifically to determine whether a plume from a facility may be visib le from a given vantage point. VISCREEN performs visibility calculations for two assumed plume

- viewing backgrounds (horizon sky and a dark terrain object). The model assumes that the terrain object is perfectly black and located adjacent to the plume on the side of the centerline opposite the observer.

The VISCREEN visibility model was set

- up to model the increase in particulate emissions from the facility based on the worst case plume dispersion characteristics. The worst case dispersion characteristi c was developed using the

method described in the manual for the VISCREEN Model. To obtain the worst

- case meteorological conditions, it is necessary to determine the dispersion condition (wind speed and stability class of wind in the direction of the

Clas s II area) that has a cumulative probability of 1%. This 1% level is a conservative approach that is expected to represent the worst case plume emissions on the day when the meteorological conditions are best for maximizing visual plume impacts. The 1% l evel corresponded with a wind speed of 3 meters per second and a stability class of

F.PSD Preliminary Determination Page 35 of 49

For both views inside and outside the Class II area, calculations are performed by the model for the two assumed plume

- viewing backgrounds. The VISCREEN model output shows separate tables for inside and outside the Class II area. Each table contains several variables: theta, azi, distance, alpha, critical and actual plume ? E, and critical and actual plume contrast. These variables are defined as follows:

1. Theta

– Scattering angle (the angle between direction solar radiation and the line of sight). If the observer is looking directly at the sun, theta equals zero degree s. If the observer is looking away from the sun, theta equals 180 degrees.

2. Azi

– The azimuthal angle between the line connecting the observer and the line of sight.

3. Alpha

– The vertical angle between the line of sight and the plume centerline.

4. ? E

– Used to characterize the perceptibility of a plume on the basis of the color difference between the plume and a viewing background. A ? E of less than 2.0 signifies that the plume is not perceptible.

5. Contrast

– The contrast at a given wavelength of two colored objects such as plume/sky or plume/terrain.

The analysis is generally considered satisfactory if ? E and Contrast are less than critical values of 2.0 and 0.05, respectively. Both of these critical values are Class I, not Class II, area thres holds. The Division has reviewed the VISCREEN results presented in the permit application and has determined that the visual impact criteria are met

both inside and outside the Richard B. Russell Airport. ? E and Contrast have been determined to be 0.52 a nd 0.005, respectively.

7.0 ADDITIONAL IMPACT ANALYSES

PSD requires an analysis of impairment to visibility, soils, and vegetation that will occur as a result of a modification to the facility and an analysis of the air quality impact projected for the a rea as a result of the general commercial, residential, and other growth associated with the proposed project.

Visibility:

Visibility impairment is any perceptible change in visibility (visual range, contrast, atmospheric color, etc.) from

that which wou

ld have existed under natural conditions. Poor visibility is caused when fine solid or liquid particles, usually in the form of volatile organics, nitrogen oxides, or sulfur oxides, absorb or scatter light. This light scattering or absorption actually re duces the amount of light received from viewed objects and scatters ambient light in the line of sight. This scattered ambient light appears as haze.

Another form of visibility impairment in the form of plume blight occurs when particles and light

- absorb ing gases are confined to a single elevated haze layer or coherent plume. Plume blight, a white, gray, or brown plume clearly visible against a background sky or other dark object, usually can be traced to a single source such as a smoke stack.

Inland pr esented visibility impact analyses in Section 6.0 of this document as discussed in the previous section. The results of these analyses showed that the proposed project should have no perceptible impact on visibility within the Class I Area of interest, th e Cohutta Wilderness, or in any of the Class II Areas of interest.

Soils and Vegetation:

No sensitive soil types are known to exist within the significant impact area of the project. Moreover, the areas of maximum impact are generally cultivated or fore sted and demonstrate no obvious sensitivity to industrial air

emissions.

Since ground level concentrations of PM, NO X , and CO are not expected to increase by a significant degree as a result of this project, the impacts on soil and vegetation are predicte d to be insignificant. There are currently no known adverse impacts on local environment from Inland’s emissions and no discernible changes are expected to result from the proposed modifications to Inland’s operations.PSD Preliminary Determination Page 36 of 49

Growth:

The modification to the I nland Mill is not expected to cause any related industrial or commercial growth that would have an impact on local ambient air quality.

8.0 EXPLANATION OF DRAFT PERMIT CONDITIONS

The permit requirements for this proposed facility are included in draft Pe rmit Amendment No. 2631

- 115

- 0021

- V

01

- 4.

Part 1.0 Facility Description

The EPD has provided a description of the modifications to the facility in Section 1.3 of the amendment.

Part 2.0 Requirements Pertaining to the Entire Facility

There are no modific ations or additions to Section 2.0 of the permit.

Part 3.0 Requirements for Emission Units

Condition 3.2.1 has been modified. The condition limits the amount of linerboard the facility can produce. The limit has been increased from 815,852 scaled tons during any twelve consecutive months to 949,000 scaled tons. This was previously a PSD Avoidance condition. The citation has been changed to 40 CFR 52.21.

Condition 3.2.2 has been deleted. The condition referred to equipment associated with the Power I sland, which will

not be built.

Condition 3.3.1.b has been modified. The condition previously limited PM emissions from Lime Kiln 1A to 0.13 grains per dscf when burning fuel oil as required by 40 CFR 60 Subpart BB. The condition now limits the emission s to 0.106 grains per dscf based on the bubble limit calculated per 40 CFR 63 Subpart MM. Subpart MM also limits emissions from the pulp mill chemical recovery system beyond what was required by 40 CFR 60 Subpart BB.

Condition 3.3.1.d has been modified. The allowable emission rate of SO 2 from Lime Kiln 1A has been increased from 8.97 pounds per hour to 9.79 pounds per hour. Reference to the 1986 mill expansion PSD has been deleted from the citation. The facility has demonstrated that the ambient concen tration of SO 2 does not increase due to this change because of the shutdown of some equipment and the new SO 2 limits imposed on other equipment.

Condition 3.3.2 has been modified. The allowable emission rate of SO 2 from Lime Kiln 2A has been reduced from 13.65 pounds per hour to 9.04 pounds per hour. The limit has been lowered as per a request by the facility. Reference to the 1986 mill expansion PSD has been deleted from the citation.

Conditions 3.3.3 through 3.3.5 have been deleted. The conditions r eferred to requirements for Lime Kiln 3A, Recovery Furnace 3, and Recovery Furnace 4, which will all be decommissioned.

Condition 3.3.6.a has been modified. The condition previously limited PM emissions from Recovery Furnace 5 to 0.044 grains per dscf. The condition now limits emissions to 0.021 grains per dscf. This is the limit set by the PSD BACT analysis and 40 CFR 63 Subpart MM.

Condition 3.3.6.b has been modified. The condition limits the emission of TRS from Recovery Furnace 5 to 5 ppm.

The ci tation has been updated to indicate the limit is also a result of the PSD BACT analysis.

Condition 3.3.6.c has been modified. The allowable emission rate of SO 2 from Recovery Furnace 5 has been increased from 328 pounds per hour to 486 pounds per hour. Reference to the 1986 mill expansion PSD has been deleted from the citation. The facility has demonstrated that the ambient concentration of SO 2 does not increase due to this change because of the shutdown of some equipment and the new sulfur SO 2 limits i mposed on other equipment.PSD Preliminary Determination Page 37 of 49

Condition 3.3.6.f has been added to the permit. The condition limits the emission of CO from Recovery Furnace 5 to 650 ppm corrected to 8 percent oxygen while burning black liquor solids. The limit is the result of the PSD

BAC T analysis.

Condition 3.3.6.g has been added to the permit. The condition limits the emission of VOC from Recovery Furnace 5 to 0.040 pounds per million BTU heat input of black liquor solids. The limit is the result of the PSD BACT analysis.

Condition 3.3.6.h has been added to the permit. The condition limits the emission of H 2 S from Recovery Furnace 5 to 4 ppm corrected to 8 percent oxygen. The limit is the result of the PSD BACT analysis.

Condition 3.3.6.i has been added to the permit. The conditi on limits the emission of CO from Recovery Furnace 5 to 0.20 pounds per million BTU heat input when firing fuel oil alone. The limit is the result of the PSD BACT analysis.

Condition 3.3.6.j has been added to the permit. The condition limits the emiss ion of VOC from Recovery Furnace 5 to 0.02 pounds per million BTU heat input when firing fuel oil alone. The limit is the result of the PSD BACT analysis.

Condition 3.3.8 has been modified. The condition requires the facility to burn only “very low su lfur oil” in Recovery Furnace 5 as required by 40 CFR 60 Subpart Db. The definition of very low sulfur fuel oil has been added

to the condition.

Conditions 3.3.9 and 3.3.10 have been deleted. The conditions referred to requirements for Smelt Tanks 3 and 4,

which will be decommissioned.

Condition 3.3.11.a has been modified. The citation has been updated to include 40 CFR 63 Subpart MM for the PM

limit for Smelt Tank 5.

Condition 3.3.11.b has been modified. The allowable SO2 emission rate from Smelt Ta nk 5 has been reduced from 6.59 pounds per hour to 1.77 pounds per hour. The limit has been lowered as requested by the facility. Reference to the 1986 mill expansion PSD permit has been removed.

Condition 3.3.12 has been deleted. The condition referre d to requirements for Power Boilers 1 and 3, which will be

decommissioned.

Condition 3.3.13 has been modified. Reference to Power Boilers 1, 2, and 3 have been removed. The emission limit has been changed to a PSD limit solely for Power Boiler 4. The a llowable SO 2 PSD emission rate from the Power Boiler has been set at 1,130.0 pounds per hour (the allowable emission rate for all four power boiler was previously 1,516.3 pounds per hour). A 12

- month rolling limit of 3,827 tons of SO 2 has also been added to the condition for the purposes of PSD Avoidance.

Conditions 3.3.14 through 3.3.35 have been deleted. The conditions referred to requirements for the Power Island equipment, which will not be built.

Condition 3.3.36 has been modified. Lime Kiln 3A ha s been removed from the condition because it will be

decommissioned.

Condition 3.3.39 has been deleted. The condition allowed the facility to burn used oil, provided that it met certain

criteria without dilution. The citation for the condition was 40 CF R 279.11

– Standards for the Management of Used Oil. The condition has been deleted because 40 CFR 279 is not an air regulation and therefore does not belong in an air quality permit. This permit change has not been requested by the facility; however, th e Division finds it necessary to correct this error during this permitting action to avoid difficulties in the future.

Condition 3.3.41 has been modified. The condition requires the facility to reduce HAP emissions from the LVHC system by incineration ac cording to 40 CFR 63 Subpart S. Reference to Lime Kiln 3A, which is to be decommissioned, has been removed from the condition.PSD Preliminary Determination Page 38 of 49

Condition 3.3.42 has been modified. The condition refers to the control requirements for Phase II of the Cluster

Rule. The f

acility has determined that HVLC gases will be controlled with the Waste Fuel Boiler or the facility will comply with the Clean Condensate Alternative. The condition has been modified to add reference to the Waste Fuel Boiler and to add details concerning the Clean Condensate Alternative. The permit application includes the

emissions from both scenarios.

Condition 3.3.57 has been modified. Previously the condition allowed the facility to burn only natural gas in Package Boiler 2. The condition has been modified to allow the combustion of very low sulfur fuel oil as well. This will allow the unit to operate continuously instead of in a backup capacity only. The citation has been updated to indicate that Georgia Rule 391

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- .02(2)(g) is subsumed by the requirement that the facility combust only very low sulfur fuel oil. The definition of very low sulfur fuel oil has been added to the condition.

Condition 3.3.58 has been deleted. The condition allowed the facility to operate Package Boiler 2 only when one of the Power Boilers or Recovery Boilers was down. This allowed the facility to continue to operate with sufficient steaming capacity. The boiler will be permitted to operate full time; therefore the condition is no longer necessary.

Condition 3.3. 59 has been added to the permit. The condition limits the emission of PM from Lime Kiln 2A to 0.155 grains per dscf corrected to 10 percent oxygen. The limit is a result of the bubble limit calculated in accordance with 40 CFR 63 Subpart MM.

Condition 3 .3.60 has been added to the permit. The condition requires the facility to comply with all applicable parts of 40 CFR 60 Subpart Db for the operation of Recovery Furnace 5.

Condition 3.3.61 has been added to the permit. The condition limits the fuel oil firing in Recovery Furnace 5, when it is not being co

- fired with black liquor solids, to 1.3 million gallons per any twelve consecutive month period. Testing on similar units has shown that SO 2 emissions do not increase from recovery furnaces when co

- fir ing with black liquor solids. For this reason, the fuel oil limit does not include fuel oil being fired with black liquor solids. This limit, along with the requirement to burn fuel oil with a maximum sulfur content of 0.5% sulfur, will assure that

SO 2 e missions from Recovery Furnace 5 will be at or below the maximum level in the permit application.

Condition 3.3.62 has been added to the permit. The condition limits the amount of black liquor solids that can be processed in Recovery Furnace 5 to 5.3 mil lion pounds per day. The limit is required for PSD Avoidance.

Condition 3.3.63.a has been added to the permit. The condition limits PM emissions from Power Boiler 4 to 0.07 lb per million Btu heat input. The limit is the result of the PSD BACT analysis

.

Condition 3.3.63.b has been added to the permit. The condition limits CO emissions from Power Boiler 4 to 300 ppm corrected to three percent oxygen. The limit is the result of the PSD BACT analysis.

Condition 3.3.63.c has been added to the permit. T he condition limits NO X

emissions from Power Boiler 4 to 0.50 pounds per million BTU heat input. The limit is the result of PSD Avoidance.

Condition 3.3.63.d has been added to the permit. The condition limits VOC emissions from Power Boiler 4 to 0.01

po unds per million BTU heat input. The limit is the result of the PSD BACT analysis.

Condition 3.4.64 has been added to the permit. The allows the facility to burn only coal, No. 2 or No. 5 fuel oil, or

used oil in Power Boiler 4. The basis for this cond ition is 40 CFR 52.21 Avoidance.

Condition 3.3.65 has been added to the permit. The condition limits the amount of fuel oil that can be fired in Power Boiler 4 during any 12 months to 35,352,857 gallons. This limit is a requirement of PSD Avoidance.

Co ndition 3.3.66 has been added to the permit. The condition limits the sulfur content of coal burned in Power Boiler 4 to 1.29 percent, by weight. The condition is a requirement of PSD Avoidance.

Condition 3.3.67 has been added to the permit. The condit ion limits the sulfur content of fuel oil burned in Power Boiler 4 to 0.5 percent, by weight. The condition is a requirement of PSD Avoidance.

Condition 3.3.68.a has been added to the permit. The condition limits the emission of PM from Package Boiler 2 to 0.050 pounds per million BTU heat input. This limit is the result of the PSD BACT analysis. The limit subsumes the existing particulate matter allowable under Georgia Rule 391

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- .02(2)(d).PSD Preliminary Determination Page 39 of 49

Condition 3.3.68.b has been added to the permit. The condi tion limits the opacity of emissions from Package Boiler 2 to less than 20 percent except for one six minute period per hour of not more than 27 percent when firing fossil fuel. This is a requirement of 40 CFR 60 Subpart Db and Georgia Rule 391

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- .02(2) (d). The unit is now subject to the opacity limit under Subpart Db due to the addition of oil burners.

Condition 3.3.68.c has been added to the permit. The condition limits the emission of CO from Package Boiler 2 to 0.20 pounds per million BTU heat inp ut. The limit is the result of the PSD BACT analysis.

Condition 3.3.68.d has been added to the permit. The condition limits the emission of VOC from Package Boiler 2 to 0.020 pounds per million BTU heat input. The limit is the result of the PSD BACT analysis. The unit was not previously limited for VOC emissions.

Condition 3.3.68.e has been added to the permit. The condition limits the emission of SO 2 from Package Boiler 2 to equal to or less than 110 pounds per hour. The limit is a requirement of PSD Avoidance.

Condition 3.3.69 has been added to the permit. The condition limits the amount of fuel oil fired in Package Boiler 2 to no more than 30 million gallons per any twelve months. This limit is a requirement of PSD Avoidance.

Condition 3.3.7 0 has been added to the permit. The condition requires the new Waste Fuel Boiler to comply with all applicable requirements of 40 CFR 60 Subpart Db.

Condition 3.3.71 has been added to the permit. The condition requires the facility to burn only “very lo w sulfur oil” in the Waste Fuel Boiler. This is a requirement found in 40 CFR 60 Subpart Db and is a requirement of 40 CFR

52.21 Avoidance for SO 2 emissions.

Condition 3.3.72 has been added to the permit. The condition limits the fuel to be burned in th e Waste Fuel Boiler to wood residue, waste wood, No. 2 Fuel oil, used oil, tire derived fuel, waste water sludge, recycle fiber waste, HVLC NCGs, and recovered boiler ash. This is a requirement of 40 CFR 52.21 Avoidance.

Condition 3.3.73.a has been added to the permit. The condition limits the emission of PM from the Waste Fuel Boiler to 0.025 pounds per million BTU heat input. This limit is the result of the PSD BACT analysis. The limit is also equal to the proposed PM limit for future MACT rule 40 CF R 63 Subpart DDDDD.

Condition 3.3.73.b has been added to the permit. The condition limits the emission of NO X from the Waste Fuel Boiler to 0.20 pounds per million BTU heat input. The limit is a requirement of 40 CFR 60 Subpart Db.

Condition 3.3.73.c h as been added to the permit. The condition limits the emission of CO from the Waste Fuel Boiler to 368 ppm corrected to 3 percent oxygen. The condition is a result of the PSD BACT analysis.

Condition 3.3.73.d has been added to the permit. The condition limits the emission of VOC from the Waste Fuel Boiler to 0.05 pounds per million BTU heat input. The condition is a result of the PSD BACT analysis.

Condition 3.3.73.e has been added to the permit. The condition limits the emission of SO 2 from Waste Fu el Boiler WF to equal to or less than 1,170 tons per any twelve month consecutive period. The limit is a requirement of PSD

Avoidance.

Condition 3.3.73.f has been added to the permit. The condition limits the opacity of emissions from the Waste Fuel

Boi ler to 10 percent except for one six minute period per hour of not more than 27 percent when fossil fuel is fired. This is a requirement of 40 CFR 60 Subpart Db, 40 CFR 52.21, and Georgia Rule 391

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- .02(2)(d).

Condition 3.3.74 has been added to the per mit. The condition limits the burning of tire derived fuel in the Waste Fuel Boiler to 80 tons per day and the burning of wastewater sludge to 30 tons per day. This is a requirement of 40

CFR 52.21 Avoidance.

Condition 3.3.75 has been added to the permi t. The condition requires the facility to comply with all applicable provisions of 40 CFR 61 Subpart E for Waste Fuel Boiler WF. The boiler is subject to this rule because it burns wastewater sludge.PSD Preliminary Determination Page 40 of 49

Condition 3.3.76 has been added to the permit. The c ondition limits the emission of mercury from Waste Fuel Boiler WF to equal to or less than 7.1 pounds per 24

- hour period while burning wastewater sludge. The limit is a requirement of 40 CFR 61 Subpart E.

Condition 3.3.77 has been added to the permit. T he condition requires the facility to achieve at least 99% destruction of TRS gases fed to the Waste Fuel Boiler. This is a requirement of the PSD BACT analysis.

Condition 3.3.78 has been added to the permit. The condition limits the emission of VOC fro m Linerboard Machines P1 and P2 to 1.82 pounds per air dried ton pulp. This is a requirement of the PSD BACT analysis.

Condition 3.3.79 has been added to the permit. The facility must comply with the applicable requirements of 40 CFR 63.50 through 63.56 . The facility is potentially subject to 40 CFR 63 Subpart DDDDD, which has not yet been promulgated.

Condition 3.3.80 has been added to the permit. The condition describes the periods of excess emissions that will be

considered violations for the units regulated under 40 CFR 63 Subpart MM.

Conditions 3.4.1 and 3.4.2 have been modified. The conditions had referred to state rule requirements for Lime Kilns 1A, 2A, and 3A. References to Lime Kiln 3A have been deleted because the unit will be decommissio ned.

Condition 3.4.4 has been deleted. The condition referred to requirements for Recovery Furnaces 3 and 4, which will

be decommissioned.

Condition 3.4.5 has been modified. References to Recovery Furnace 3 and 4 have been deleted because the units

wil l be decommissioned.

Conditions 3.4.6 and 3.4.7 have been deleted. The conditions referred to requirements for Recovery Furnaces 3 and 4 and Smelt Tanks 3 and 4, which will be decommissioned.

Conditions 3.4.8 and 3.4.9 have been modified. Reference to Smelt Tanks 3 and 4 has been removed because the

units will be decommissioned.

Condition 3.4.10 has been deleted. The condition referred to requirements for Power Boilers 1, 2, and 3, which will be decommissioned. In addition, the condition referred to Georgia Rule 391

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- .02(2)(d) for PM from Power Boiler 4. This PM limit has been subsumed by the PSD BACT limit, so it is no longer necessary to list it in the permit.

Condition 3.4.11 has been modified. Reference to Power Boilers 1, 2, and 3 has been removed because the units

will be decommissioned.

Conditions 3.4.12 through 3.4.20 have been deleted. The conditions referred to requirements for the Power Island equipment, which will not be built.

Condition 3.4.21 has been modified. Reference to Powe r Boilers 1, 2, and 3, Lime Kiln 3A, and Recovery Furnaces

3 and 4 has been removed because the units will be decommissioned. Reference to Waste Fuel Boiler WF has been

added.

Conditions 3.4.29 and 3.4.30 have been deleted. The conditions referred to st ate rules for opacity and PM for Package Boiler 2. The limits in those rules have been subsumed by PSD and 40 CFR 60 Subpart Db requirements.

Condition 3.4.31 has been added to the permit. The condition limits the emission of NO X from Package Boiler 2 t o 30 ppm corrected to 3 percent oxygen from May 1 st through September 30 th each year and is a requirement of Georgia Rule 391

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- .02(2)(lll). The rule applies to fuel

- burning equipment permitted or brought on site after May 1, 1999. The unit was permitt ed on October 17, 2002.

Condition 3.4.32 has been added to the permit. The condition limits the emission of SO 2 from the Waste Fuel Boiler to 0.80 pounds per million BTU heat input. This is a requirement of Georgia Rule 391

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- .02(2)(g).PSD Preliminary Determination Page 41 of 49

Part 4.0 Req uirements for Testing

Condition 4.1.3 has been modified. Paragraph (k) has been updated to include SO 2 . Paragraph (l) has been deleted because it referred to Combustion Turbines CT1 and CT2, which will not be built. Paragraph (s) has been modified

to i nclude the testing requirements for wastewater sludge for the presence of mercury and to delete the requirement for the sampling of used oil. Paragraphs (t) through (v) have been deleted because they referred to the deleted Standards for the Management of Used Oil condition. Paragraphs (w) through (cc) have been added due to the addition of 40 CFR 63 Subpart MM requirements. Reference to the Bark Boiler has been removed because the unit

will not be built.

Condition 4.2.1 has been modified. Reference to the decommissioned units and the Power Island units have been removed. Ongoing performance testing requirements have been added for Waste Fuel Boiler WF and Package Boiler 2. Condition 4.2.2 has been updated accordingly.

Conditions 4.2.3 and 4.2.4 have been deleted. The conditions referred to performance testing requirements for Power Island equipment, which will not be built.

Condition 4.2.5 has been deleted. The condition referred to performance testing requirements for Recovery Furnaces 3, 4, and 5. The performance testing has been completed.

Conditions 4.2.6 through 4.2.12 have been deleted. The conditions referred to performance testing requirements for Power Island equipment, which will not be built.

Condition 4.2.15 has been modified. The facility is required to conduct a performance test for NO X while burning fuel oil in Package Boiler 2. Performance testing has already been completed for natural gas.

Condition 4.2.16 has been modified. The condition has been updated to reflect performa nce testing requirements for Package Boiler 2. The facility must comply with different testing requirements under 40 CFR 60 Subpart Db with the addition of load bearing oil guns.

Condition 4.2.18 has been added to the permit. The condition requires the facility to conduct the necessary performance testing for SO 2 and TRS for Lime Kilns 1A and 2A at the new lime processing rate.

Condition 4.2.19 has been added to the permit. The condition requires the facility to conduct the necessary performance testin g for TRS, SO 2 , and opacity for Smelt Tank 5 at the new black liquor solids processing rate.

Conditions 4.2.20 through 4.2.23 have been added to the permit. The conditions require the facility to conduct the necessary initial performance testing for Reco very Furnace 5, Power Boiler 4, Package Boiler 2, and Waste Fuel

Boiler WF.

Condition 4.2.24 has been added to the permit. The condition requires the facility to conduct initial performance tests for the presence of mercury from the combustion of wastewa ter sludge in Waste Fuel Boiler WF. This is a requirement of 40 CFR 61 Subpart E.

Condition 4.2.25 has been added to the permit. The condition requires the facility to conduct a performance test for TRS gases burned in Waste Fuel Boiler WF. The test is needed to demonstrate compliance with the 99.0% destruction efficiency requirement under 40 CFR 52.21.

Conditions 4.2.26 through 4.2.30 have been added to the permit. The conditions detail the performance testing requirements under 40 CFR 63 Subpart MM for the lime kilns, recovery furnace, and smelt tank.

Condition 4.2.31 requires the facility to conduct an initial performance test for the emission of VOC from the linerboard machines. The testing is necessary to demonstrate compliance with the VOC PSD limit.

Part 5.0 Requirements for Monitoring

Condition 5.2.1.a has been modified. The condition described the CEMS requirements for the Lime Kilns.

Reference to Lime Kiln 3A has been removed because the unit will be decommissioned.PSD Preliminary Determination Page 42 of 49

Condition 5.2.1.b h as been deleted. The condition described the CEMS requirements for Recovery Furnaces 3 and 4, which will be decommissioned.

Condition 5.2.1.c has been modified. The condition describes the CEMS requirements for Recovery Furnace 5. Continuous monitoring

for furnace oxygen and H 2 S has been added and the citation has been updated to include PSD. The language describing the COMS requirements has been added to include the specific COMS requirements under 40 CFR 63 Subpart MM.

Condition 5.2.1.d has been mod ified. The condition described the CEMS requirements for the Power Boilers. Reference to Power Boilers 1, 2, and 3 has been deleted because they will be decommissioned. NO X and furnace oxygen CEMS have been added for Power Boiler 4. The citation has be en updated to include PSD and PSD

Avoidance.

Conditions 5.2.1.e through 5.2.1.g have been deleted. The condition described the CEMS requirements for the proposed Power Island, which will not be built.

Condition 5.2.1.i has been added to the permit. The condition describes the CEMS requirements for Package Boiler 2. Continuous monitoring systems for opacity and furnace oxygen have been required.

Condition 5.2.1.j has been added to the permit. The condition describes the CEMS requirements for the Waste Fuel Boiler. Continuous monitoring systems for opacity, CO, SO 2 , and NO X

have been required.

Condition 5.2.2.c has been modified. The condition previously referred to fuel monitoring requirements for the Power Boilers. Reference to Power Boilers 1, 2, and 3 has been removed due to decommissioning and the Waste Fuel Boiler has been added to the requirement.

Conditions 5.2.2.d through 5.2.2.g have been deleted. The conditions described monitoring requirements for the Power Island, which will not be bui lt.

Condition 5.2.2.h has been modified. The condition previously referred to monitoring the amount of natural gas burned by Packager Boiler 2. A requirement to monitor the amount of fuel oil burned has been added the condition

as well.

Condition 5.2.2 .i has been added to the permit. The condition requires the facility to monitor the lime kiln and smelt tank scrubbers according to the requirements of 40 CFR 63 Subpart MM. These are also requirements under 40 CFR 60 Subpart BB and Georgia Rule (gg).

C ondition 5.2.2.j has been added to the permit. The condition requires the facility to monitor the Recovery Furnace ESP for the control of PM and opacity.

Condition 5.2.2.k. requires the mill to monitor the amount of fuel fired in Recovery Furnace 5 with and without black liquor solids. This data will be used to ensure SO 2 emissions are below the level set in the permit application.

Condition 5.2.2.l has been added to the permit. The condition requires the facility to monitor the Waste Fuel Boiler

ESP f or the control of PM and opacity.

Condition 5.2.2.m has been added to the permit. The condition requires monitoring the combustion zone temperature of the Waste Fuel Boiler when burning waste gases from the washer systems.

Condition 5.2.2.n has been add ed to the permit. The condition requires the facility to monitor the ESP on Power

Boiler 4 on a continuous basis.

Conditions 5.2.3.a has been modified. The condition specified monitoring requirements for the Recovery Furnaces.

Reference to Furnaces 3 a nd 4 has been removed due to decommissioning.

Condition 5.2.3.b has been deleted. The condition referred to Recovery Furnaces 3 and 4, which will be decommissioned. The requirements for monitoring the Recovery Furnace 5 ESP have been moved to Condition

5.2.2.PSD Preliminary Determination Page 43 of 49

Condition 5.2.3.c has been deleted. The condition specified ESP monitoring requirements for the Power Boilers. The monitoring requirement for Power Boiler 4 has been moved to Condition 5.2.2.n.

Condition 5.2.3.d has been deleted. The condition referred to the scrubber monitoring requirements for the Smelt Tank 5 scrubber. An updated 40 CFR 63 Subpart MM condition has been added to Section 5.2.2 for the monitoring

of this scrubber.

Condition 5.2.3.e has been modified. The condition described t he monitoring requirement for the lime kiln scrubbers. Reference to the scrubbers has been removed. An updated 40 CFR 63 Subpart MM condition has been added to Section 5.2.2 for the monitoring of these scrubbers. A requirement to monitor lime mud solids has been added for the purposes of Subpart MM.

Conditions 5.2.3.f through 5.2.3.i have been deleted. The conditions referred to monitoring requirements for the Power Island, Lime Kiln 3A, and Smelt Tank 3 and 4. These units will not be built or will be decommissioned.

Condition 5.2.3 j has been added to the permit. The condition requires the facility to monitor the number of hours the HVLC gases are fired in Waste Fuel Boiler WF.

Condition 5.2.3.k has been added to the permit. The condition requires the facility to monitor and record the steam production rate for Waste Fuel Boiler WF.

Conditions 5.2.9 through 5.2.14 have been deleted. The conditions referred to monitoring requirements for the Power Island, which will not be built.

Condition 5.2.15

has been deleted. The condition referred to testing requirements for used fuel oil. The condition is no longer necessary because the permit will no longer contain sampling requirements for used fuel oil. Sampling requirements for sulfur content of the oil will remain in Part 6.0 of the permit.

Condition 5.2.18 has been deleted. The condition referred to requirements for the Smelt Tank 3 and 4 Demisters,

which will be decommissioned.

Condition 5.2.19 has been added to the permit. The condition requir es the facility to comply with all applicable monitoring requirements of CAM (40 CFR 64) for the operation of Recovery Furnace 5 and the Waste Fuel Boiler.

Conditions 5.2.20 and 5.2.21 have been added to the permit. The conditions contain the CAM require ments for the operation of Recovery Furnace 5 and Waste Fuel Boiler WF.

Condition 5.3.1 has been modified. The numerical condition references have been updated for Section 5.2 of the permit.

Condition 5.3.2 has been deleted. The condition referred to r equirements for the Power Island, which will not be

built.

Condition 5.3.3 has been deleted. The condition referred to testing requirements for used fuel oil. The condition is no longer necessary because the permit will no longer contain sampling requir ements for used fuel oil. Sampling requirements for sulfur content of the oil will remain in Part 6.0 of the permit.

Condition 5.3.4 has been modified. The condition has been modified to include the requirement for stream

generating records for Waste Fu el Boiler WF. This is a requirement of 40 CFR 60 Subpart Db.

Part 6.0 Other Recordkeeping and Reporting Requirements

Condition 6.1.7.a(i) has been modified. The condition referred to excess emission criteria for Lime Kilns 1A and

3A. Reference to Lime Kiln 3A has been removed from the condition because it will be decommissioned.

Conditions 6.1.7.a(iv) and (v) have been deleted. The conditions referred to excess emission criteria for Recovery Furnaces 3 and 4, which will be decommissioned.

Condition 6.1.7.a(vi) has been modified. The condition refers to the TRS limit for Recovery Furnace 5. The citation has been updated to include 40 CFR 52.21 due to the BACT analysis.PSD Preliminary Determination Page 44 of 49

Condition 6.1.7.a(vii) has been modified. The condition refers to opacity limits for Recovery Furnace 5. The citation for the condition has been updated to include 40 CFR 63 Subpart MM.

Condition 6.1.7.a(ix) has been modified. Reference to Power Boilers 1 through 3 has been removed because the

units will be decommissioned.

Conditi on 6.1.7.a(x) has been modified. The condition referred to the SO 2 PSD limit for the combined power boiler

stack. The excess emission statement has been rewritten to indicate the new short term SO 2 limit of 1,130.0 pounds per hour for Power Boiler 4.

Co nditions 6.1.7.a(xi) through (xx) have been deleted. The conditions referred to excess emissions criteria for the Power Island, which will not be built.

Condition 6.1.7.a(xxi) has been modified. The condition requires the facility to report when various pieces of equipment associated with Cluster Rule are down. The condition has been modified to remove reference to Lime Kiln 3A, which will be decommissioned.

Condition 6.1.7.a(xxii)(A) has been modified. Reference to Lime Kiln 3A has been removed becau se it will be decommissioned. The condition details excess emission requirements for the Cluster Rule.

Condition 6.1.7.a(xxiii) has been modified. The numbering of the condition has been corrected from xiii to xxiii.

Condition 6.1.7.a(xxv) has been del eted. The condition allowed the facility to operate Package Boiler 2 only when a Power Boiler or Recovery Furnace is down. The Package Boiler will now be a full time unit; therefore the condition will not be necessary.

Condition 6.1.7.a(xxvi) has been a dded to the permit. The condition describes as an excess emission any 12

- hour period during which the average H 2 S concentration from Recovery Furnace 5 is in excess of 4 ppm. This is a PSD

limit.

Condition 6.1.7.a(xxvii) has been added to the permit. T he condition describes as an excess emission any 12 month period during which the emissions of SO 2 from Power Boiler 4 exceeds 3,837 tons. This is a PSD Avoidance limit.

Condition 6.1.7.a(xxviii) has been added to the permit. The condition describes as an excess emission any 30

- day rolling period during which the average NO X emission rate from Power Boiler 4 is in excess of 0.50 lb/MMBtu.

This is a PSD Avoidance limit.

Condition 6.1.7.a(xxix) has been added to the permit. The condition describes as an excess emission any six

- minute period during which the opacity from Package Boiler 2 is equal to or in excess of 20%. This is a requirement under 40 CFR 60 Subpart Db.

Condition 6.1.7.a(xxx) has been added to the permit. The condition describes as an e xcess emission any 3

- hour period during which the average NO X emission rate from Package Boiler 2 is equal to or in excess of 30 ppm during May 1 st through September 30 th . This is a requirement of Georgia Rule (lll).

Condition 6.1.7.a(xxxi) has been adde d to the permit. The condition describes as an excess emission any six

- minute period during which the opacity from Waste Fuel Boiler WF is equal to or in excess of 10%. This is a requirement under 40 CFR 60 Subpart Db and 40 CFR 52.21.

Condition 6.1.7.a (xxxii) has been added to the permit. The condition describes as an excess emission any 3

- hour period during which the average CO concentration from Waste Fuel Boiler WF is in excess of 368 ppm. This is a

PSD limit.

Condition 6.1.7.a(xxxiii) has been ad ded to the permit. The condition describes as an excess emission any 30

- day rolling period during which the average NO X concentration from Waste Fuel Boiler WF is in excess of 0.20 pounds per million BTU. This is a requirement under 40 CFR 60 Subpart Db.

Condition 6.1.7.a(xxxiv) has been added to the permit. The condition describes as an excess emission any 3

- hour period during which the average combustion temperature for the HVLC gases combusted in Waste Fuel Boiler WF is lower that the temperature det ermined in accordance with Condition 4.2.25.PSD Preliminary Determination Page 45 of 49

Condition 6.1.7.a(xxxv) has been added to the permit. The condition describes as an excess emission any 12 month rolling period that SO 2 emissions are in excess of 1,170 tons. This is a PSD Avoidance limit.

C ondition 6.1.7.a(xxxvi) has been added to the permit. The condition describes as an excess emission any 3

- hour period during which the average SO 2 emissions from Waste Fuel Boiler WF are in excess of 0.80 pounds per million

BTU. This is a limit under Geo rgia Rule (g).

Condition 6.1.7.b(i) has been deleted. The condition referred to exceedance criteria for Power Boilers 1 and 3,

which will be decommissioned.

Conditions 6.1.7.b(ii) through (x) have been deleted. The conditions referred to exceedance cri teria for the Power Island, which will not be built.

Condition 6.1.7.b(xiii) has been modified. References to deleted conditions have been removed.

Condition 6.1.7.b(xiv) has been deleted. The condition referred to exceedance criteria for the Power Isl and.

Condition 6.1.7.b(xvi) has been modified. The condition describes the exceedance criteria for the total linerboard production at the mill. The allowable total linerboard limit has been revised to 949,000 scaled tons per 12 months.

Condition 6.1.7.

b(xvii) had been modified. The condition referred to exceedance criteria for Package Boiler 2 and the combustion of natural gas. The unit will be permitted to burn very low sulfur fuel oil; therefore the fuel oil has

been added to the exceedance conditio n.

Condition 6.1.7.b(xviii) has been added to the permit. The condition defines as an exceedance any time fuel oil burned in Package Boiler 2 does not meet the definition of “very low sulfur fuel oil” in 40 CFR 60 Subpart Db.

Condition 6.1.7.b(xix) has been added to the permit. The condition defines as an exceedance any 12 month period during which the amount of fuel oil consumed in Package Boiler 2 is in excess of 30 million gallons. This is a PSD

Avoidance limit.

Condition 6.1.7.b(xx) has been added to the permit. The condition defines as an exceedance any operating day during which the amount of black liquor solids processed in Recovery Furnace 5 exceeds 5.3 million pounds. This

is a PSD Avoidance limit.

Condition 6.1.7.b(xxi) has been added to t he permit. The condition defines as an exceedance any 12 month period during which the amount of fuel oil consumed in Recovery Furnace 5, when not co

- firing with black liquor solids, is in excess of 1.3 million gallons. This is a PSD Avoidance limit.

Co ndition 6.1.7.b(xxii) has been added to the permit. The condition defines as an exceedance any period of operation time that the fuel oil combusted in Power Boiler 4 contains more than 0.5 percent sulfur, by weight. This

is a PSD Avoidance limit.

Condit ion 6.1.7.b(xxiii) has been added to the permit. The condition defines as an exceedance any period of operation time that the coal combusted in Power Boiler 4 contains more than 1.29 percent sulfur, by weight. This is

a PSD Avoidance limit.

Condition 6. 1.7.b(xxiv) has been added to the permit. The condition defines as an exceedance any 12 month period during which the amount of fuel oil consumed in Power Boiler 4 is in excess of 35,352,857 gallons. This is a PSD

Avoidance limit.

Condition 6.1.7.b(xxv) has been added to the permit. The condition defines as an exceedance any time fuel oil burned in Waste Fuel Boiler WF does not meet the definition of “very low sulfur fuel oil” in 40 CFR 60 Subpart Db.

Condition 6.1.7.b(xxvi) has been added to the permi t. The condition defines as an exceedance any unit

- operating day that TDF combustion in Waste Fuel Boiler WF exceeds 80 tons. This is a PSD Avoidance limit.

Condition 6.1.7.b(xxvii) has been added to the permit. The condition defines as an exceedance a ny unit operating day that wastewater sludge combustion in Waste Fuel Boiler WF exceeds 30 tons. This is a PSD Avoidance limit.PSD Preliminary Determination Page 46 of 49

Condition 6.1.7.b(xxviii) has been added to the permit. The condition defines as an exceedance any 24

- hour period

for which m

ercury emissions calculated for Waste Fuel Boiler WF are in excess of 7. 1 pounds. This limit is a requirement under 40 CFR 61 Subpart E.

Condition 6.1.7.c(i)(A) and (B) have been modified. The conditions have been updated to allow the facility to

estab lish excursion values for the Lime Kiln 1A and 2A scrubber during performance tests required under Part 4.2 of the permit.

Conditions 6.1.7.c(i)(C) through (E) have been deleted. The conditions referred to excursion limits for the scrubber controlling em

issions from Lime Kiln 3A. The unit will be decommissioned.

Condition 6.1.7.c(ii) has been modified to update numerical references and specify Recovery Furnace 5 as the only remaining furnace. The averaging time has also been updated to reflect continuo us monitoring for the ESP control

device.

Condition 6.1.7.c(iii) has been modified. The condition referred to excursion limits for the Recovery Furnace black liquor solids content. Reference to Recovery Furnaces 3 and 4 has been removed because they wil l be

decommissioned.

Condition 6.1.7.c(iv) has been modified. Reference to excursion limits for the Smelt Tank 3 and 4 control devices has been removed because the units will be decommissioned. The condition has been updated to allow the facility

to est ablish excursion values for the Smelt Tank 5 scrubber during performance tests required under Part 4.2 of the permit.

Condition 6.1.7.c(v) has been modified. The condition referred to excursion limits for the Power Boiler ESPs.

Reference to Power Boiler s 1 through 3 has been removed. The condition has been updated to base the excursion

condition on a 3

- hour basis rather than a once per shift basis.

Conditions 6.1.7.c(vi through xii) have been deleted. The conditions referred to excursion limits for Po wer Island Equipment, which will not be built.

Condition 6.1.7.c(xv)(B) has been modified. The process wastewater column feed temperature excursion value has been reduced from 185 degrees to 167 degrees Fahrenheit. The change is based on Cluster Rule pe rformance test

data.

Condition 6.1.7.c(xvi) has been added to the permit. The condition defines as an excursion any 3 hour period during which the furnace oxygen level for Recovery Furnace 5 is below the value that provides a reasonable assurance of

comp liance with the CO and VOC PSD limits.

Condition 6.1.7.c(xvii) has been added to the permit. The condition defines as an excursion any 3 hour period during which the furnace oxygen level for Power Boiler 4 is below the value that provides a reasonable as urance of compliance with the CO and VOC PSD limits.

Condition 6.1.7.c(xviii) has been added to the permit. The condition defines as an excursion any 3 hour period during which the furnace oxygen level for Package Boiler 2 is below the value that provid es a reasonable assurance of compliance with the CO and VOC PSD limits.

Condition 6.1.7.c(xix) has been added to the permit. The condition sets an excursion for the Waste Fuel Boiler ESP total power based on the performance tests conducted in accordance with Part 4.2 of the permit. ESP monitoring is related to the control of PM and opacity.

Condition 6.1.7.c(xx) has been added to the permit. The condition defines as an excursion any 3

- hour period during which the average combustion temperature and aver age carbon monoxide concentration are not within the ranges that provide a reasonable assurance of compliance with the VOC PSD limit.

Condition 6.1.7.d(i) has been modified. The numerical references in the condition have been updated as necessary.

Condi tion 6.1.7.d(iii) has been modified. The condition requires the facility to provide a signed statement about the “very low sulfur oil” burned at the facility. Reference to Waste Fuel Boiler WF and Package Boiler 2 has been

added to the condition.PSD Preliminary Determination Page 47 of 49

Conditi on 6.1.7.d(iv through vi) have been deleted. The conditions referred to excursion limits for Power Island equipment and used fuel oil analysis requirements.

Condition 6.1.7.d(viii) has been modified to remove reference to deleted Condition 4.2.4.

Condit ion 6.1.7.d(ix) has been added to the permit. The condition requires the Permittee to include violations under 40 CFR 63 Subpart MM as described in Condition 3.3.80 with the periodic report required by Condition 6.1.4.

Condition 6.1.8 has been deleted. The condition referred to Power Island equipment.

Condition 6.2.1 has been modified. The condition specifies record keeping and reporting requirements associated with the linerboard limit in Condition 3.2.1. The condition has been modified to update the linerboard production limit. The record keeping is necessary to determine compliance with the PSD limit. As requested by the Stationary Source Compliance Program, a requirement has been added so that records of linerboard produced from recycle pulp

will be available.

Condition 6.2.2 through 6.2.18 have been deleted. The condition referred to record keeping requirements for the Power Island, which will not be built.

Condition 6.2.19 has been modified. Reference to Lime Kiln 3A has been removed because the unit will be

decommissioned.

Condition 6.2.21 has been modified. Reference to Recovery Furnaces 3 and 4 has been removed because the units will be decommissioned. The condition has also been modified to require that the facility maintain a daily re cord of the total amount of black liquor solids fired in Recovery Furnace 5. These records are necessary to determine compliance with the PSD Avoidance limit in Condition 3.3.62.

Condition 6.2.23 has been modified. The citation has been updated to inclu de PSD Avoidance.

Condition 6.2.24 has been deleted. The condition referred to record keeping requirements for Power Boilers 1 and 3; the units will be decommissioned.

Condition 6.2.25 has been modified. Reference to Power Boilers 1, 2, and 3 have been removed because the units will be decommissioned. Reference to woodwaste has been removed. The condition requires the facility to keep records of quantities and types of fuels burned in Power Boiler 4. The records are necessary to calculate air

emissio ns.

Condition 6.2.26 has been modified. The condition requires the facility to calculate SO 2 emissions from Power Boiler 4 (reference to Power Boilers 1 through 3 has been removed). The calculations are necessary to determine compliance with the SO 2 PSD Avoidance limit in condition 3.3.13.

Condition 6.2.28 has been modified. The condition has been changed to include heat content and sulfur content analysis for used oil. The condition is necessary to determine compliance with the sulfur content limits for fuel found throughout the permit.

Condition 6.2.29 has been modified. A typographical error in paragraph (b) of the condition has been corrected

from “6.2.9.a” to 6.2.29.a.” Condition 6.2.31 has been modified. Reference to Power Boilers 1 through 3 and Recovery Furnaces 3 and 4 have

been removed because the units will be decommissioned.

Condition 6.2.32 has been deleted. The condition referred to record keeping requirements which have been removed from the permit.

Condition 6.2.40 has been deleted . The condition referred to submission requirements for the Power Island, which

will not be built.

Condition 6.2.41 has been deleted. The condition referred to the back

- up status of Package Boiler 2. The unit is no longer a backup boiler.PSD Preliminary Determination Page 48 of 49

Condition 6.

2.44 has been added to the permit. The condition requires the facility to commence construction of the requested modifications within 18 months of the date of issuance of the permit. This is a requirement of 40 CFR 52.21 and provides a reasonable assuran ce that all BACT analyses and modeling results are up to date at the time of
start up.

Condition 6.2.45 has been added to the permit. The condition requires the complete privatization of Mays Bridge Road between State Route 20 and Turner Bend Road prior to the start up of the modified and new equipment. This condition is necessary to ensure compliance with air quality requirements.

Condition 6.2.46 has been added to the permit. The condition specifies the conditions under which the facility must implem ent corrective action for the operation of the lime kilns, smelt tank, and recovery furnace for 40 CFR 63 Subpart MM. Corrective action is necessary to insure on

- going compliance with the limits of Subpart MM.

Condition 6.2.47 has been added to the permi t. The condition specifies that the facility develop and implement an SSM Plan for the lime kiln, smelt tanks, and recovery furnace under the requirements of 40 CFR 63 Subpart MM.

Condition 6.2.48 has been added to the permit. The condition specifies th e general records the facility must maintain in accordance with 40 CFR 63 Subpart MM. The records are necessary to demonstrate on

- going compliance with the Subpart MM emission limits.

Condition 6.2.49 has been added to the permit. The condition requires the facility to submit notifications as required by 40 CFR 63 Subpart MM. These records are necessary to demonstrate initial and on

- going compliance with the requirements of Subpart MM.

Condition 6.2.50 has been added to the permit. The condition requi res the facility to submit 40 CFR 63 Subpart MM bubble limit calculations and supporting data as part of the notification of compliance status required by 40 CFR 63 Subpart A. These records are necessary to demonstrate initial and on

- going compliance with the requirements of Subpart MM.

Condition 6.2.51 has been added to the permit. The condition requires the facility to provide notification to the Division prior to actions that may affect on

- going compliance with the site

- specific 40 CFR 63 Subpart MM b ubble

limits.

Condition 6.2.52 has been added to the permit. The condition requires the facility to recalculate and submit the site

specific 40 CFR 63 Subpart MM bubble limit if actions are taken that may affect compliance. The submissions are

necessary to ensure that proper emission limits are in place at all times.

Condition 6.2.53 has been added to the permit. The condition requires the facility to keep daily and 12

- month rolling totals for the amount of fuel oil burned in Recovery Furnace 5. The r ecords are necessary to determine compliance with the PSD limit for fuel oil.

Condition 6.2.54 has been added to the permit. The condition requires the facility to keep daily and 12

- month rolling totals for the amount of fuel oil burned in Power Boiler 4 . The records are necessary to determine compliance with the PSD limit for fuel oil.

Condition 6.2.55 has been added to the permit. The condition requires the facility to obtain and maintain fuel oil receipts for Package Boiler 2 that show the fuel comp lies with the definition of “very low sulfur oil.” The records are a requirement of 40 CFR 60 Subpart Db.

Condition 6.2.56 has been added to the permit. The condition requires the facility to record and maintain fuel burning records for Package Boiler 2 and calculate the corresponding annual capacity factor for each fuel. The records and calculations are a requirement of 40 CFR 60 Subpart Db.

Condition 6.2.57 has been added to the permit. The condition requires the facility to keep daily and 12

- month rolling totals for the amount of fuel oil burned in Package Boiler 2. The records are necessary to determine compliance with the PSD limit for fuel oil.

Condition 6.2.58 has been added to the permit. The condition requires the facility to submit notific ations for the start up of Waste Fuel Boiler WF as required by 40 CFR 60 Subpart A and 60.49b(a).PSD Preliminary Determination Page 49 of 49

Condition 6.2.59 has been added to the permit. The condition requires the facility to obtain and maintain fuel oil receipts for Waste Fuel Boiler WF that sh ow the fuel complies with the definition of “very low sulfur oil.” The records are a requirement of 40 CFR 60 Subpart Db.

Condition 6.2.60 has been added to the permit. The condition requires the facility to record and maintain fuel burning records for Waste Fuel Boiler WF and calculate the corresponding annual capacity factor for each fuel. The records and calculations are a requirement of 40 CFR 60 Subpart Db.

Condition 6.2.61 has been added to the permit. The condition requires the facility to samp le wastewater sludge burned in Waste Fuel Boiler WF for mercury analysis. The results are required to be submitted with the reports required by Condition 6.1.4. The analyses and records are necessary to determine compliance with the mercury

emission limi t under 40 CFR 61 Subpart E.

Condition 6.2.62 has been added to the permit. The condition requires the facility to maintain records of the 24

- hour mercury emission calculation required to be performed to determine compliance with Condition 3.3.76. The r ecords are necessary to demonstrate ongoing compliance with 40 CFR 61 Subpart E.

Condition 6.2.63 has been added to the permit. The condition requires the facility to maintain daily records that indicate which incineration device is burning HVLC TRS gas streams. This condition is necessary because Waste Fuel Boiler WF may combust Cluster Rule Phase II gases.

Condition 6.2.64 has been added to the permit. The condition requires the facility to use various monitored data in

addition to the SO 2 CEMS to ca

lculate the SO

2 emission rate in pounds per hour from Waste Fuel Boiler WF. The calculations are necessary to demonstrate compliance with the sulfur dioxide PSD Avoidance limit in Condition

3.3.73.

Condition 6.2.65 has been added to the permit. The cond ition requires the facility to submit to the Division a protocol for determining ongoing compliance with the PSD VOC limit for the linerboard machines.

Condition 6.2.66 has been added to the permit. The condition requires the facility to submit informati on as required by 40 CFR 63.50 through 63.56 for Power Boiler 4 and Waste Fuel Boiler WF. The boilers will be subject to 40 CFR 63 Subpart DDDDD

– NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters. The rule has not yet been promulgated.

Part 7.0

– Other Specific Requirements

Condition 7.14.1 through 7.14.4 have been added to the permit. The conditions require the facility to shut down the equipment to be decommissioned upon startup of the new and modified equipment. The conditions also clarify which conditions become effective upon startup of the new and modified equipment and directs the facility to comply with all applicable rules and regulations until units to be decommissioned are permanently shutdown.

Condition 7.3. 1 has been deleted. The condition previously referred to the Power Island units, which will not be

built.

Part 8.0

– General Provisions

Condition 8.14.1 has been updated due to a recent Title V template change.

Attachment B

The Insignificant Activiti es Checklist has been updated for the addition of Diesel Tank FT1. The total under “Storage Tanks and Equipment

– All petroleum liquid storage tanks storing a liquid with a true vapor pressure of equal to or less than 0.50 psia as stored” has been increas ed from 20 to 21.PSD Preliminary Determination

APPENDIX A

Draft Revised Title V Operating Permit Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill Rome (Floyd County), GeorgiaPSD Preliminary Determination

APPENDIX B

Inland Paperboard and Packaging, Inc.

– Rome Linerboard Mill PSD Permit Applicat ion and Supporting Data

Contents Include:

1. PSD Permit Application No. 14756, dated October 3, 2003; Fully updated April 2004.PSD Preliminary Determination

APPENDIX C

EPD’S PSD Dispersion Modeling and Air Toxics Assessment ReviewMichigan Department of En vironmental Quality Files

Mead Corporation – Escanaba Paper Company

Excerpt from Permit Review for Permit No. 40422Oklahoma Department of Environmental Quality Files

Weyerhauser Corporation – Valliant Mill

Excerpt from Permit Review for Permit No. 97-057-C (M4) PSD

James River Corporation – Muskogee Mill

Excerpt from Permit Review for Permit No. 99-113-C (M-3) PSDOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

MEMORANDUM October 12, 2004

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division

THROUGH: David Schutz, P.E., New Source Permits Section

THROUGH: John Howell, E.I., Existing Source Permits Section

THROUGH: Peer Review

FROM: Roya Sharifsoltani, New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 97-057- C (M

- 4) PSD Weyerhaeuser Company Valliant Paper Mill Valliant, McCurtain County, Oklahoma Secs. 26, 27, 28, 33 and 34- T6S -R21E UTM Zone 15,306.50 Km Easting by 3,763.50 Km Northing

Located One Mile West of Valliant on US -70

SECTION I. INTRODUCTION

Weyerhaeuser ope rates a K raft P rocess pa per m ill ( SIC 2631, N AIC 32213) i n s outheas t Oklahoma. Weyerhaeuser Company ( Weyerhaeuser) i s pl anning a s eries of ne w c onstruction and m odification pr ojects t o e nhance i ts e xisting V alliant, O klahoma, pa per pr oducts manufacturing facility (Valliant Mill). Current active permits include Permit Nos . 75 -011- O, 75

- 012- O, 86 -019- O, 91 -093- O, 95 -224- O, 96 -043- C (PSD), 96 -043- C (M

- 1)(PSD), 96 -043- C (M

2)(PSD), 96 -043- C (M

- 3)(PSD), 96 -188-C, 99-134-C, and 97-057- C (M -2).

Weyerhaeuser anticipates the following major components of the proposed project:

**•** Construction of a ne w che mical r ecovery f urnace t o replace the existing chemical recovery furnace (CRF) used in the chemical recovery process.

**•** Construction of a c irculating f luidized be d ( CFB) boi ler t o e nhance t he mill’s steam production capabilities.

**•** The No. 2 Power Boiler, which was permitted under Permit No. 96 -043- C (M

- 3), will not

be constructed.

**•** Construction of a ne w l ime ki ln t o s upplement r egeneration of t he m ill’s c ooking

chemicals.

**•** Installation of new spent liquor mix tanks to replace the existin g spent liquor mix tanks.

**•** Enhancements to the evaporator area.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 2

**•** Installation of new smelt dissolving tanks to replace the existing smelt dissolving tanks. The new smelt dissolving tanks will not be emission points. Rather, airflow from the new

smelt di sso lving t anks w ill be r outed t hrough t he ne w chemical recovery furnace as combustion air make-up.

**•** Decommissioning of the existing Bark Boiler.

**•** Decommissioning of the existing Power Boiler from normal operation. The Power Boiler

will function as a ba ck

- up st eam generating unit. Future operation of the Power Boiler will occur mainly when either the new chemical recovery furnace or the new CFB Boiler are not in operation, but will be available to provide steam on a limited basis when those two units are also in operation.

**•** Decommissioning of t he non

- condensable gas (NCG) thermal ox idizer f rom r egular operation a nd r eroute of N CGs a nd s tripper of f

- gases (SOGs) t o the ne w che mical recovery furnace , with the new CFB Boiler serving as a backup control device for NCG s and SOGs. The N CG T hermal O xidizer w ill f unction a s a s econdary ba ckup c ontrol

device for NCGs and SOGs in the event that the new chemical recovery furnace or CFB

Boiler is unavailable for NCG/SOG control.

**•** Installation of an additional brownstock washin g line.

**•** Enhancements to the existing paper machines a nd O ld C orrugated C ontainer ( OCC) plants.

**•** Enhancements to the existing No. 1 and No. 2 Digester systems

SECTION II. FACILITY DESCRIPTION

Initial construction of the mill began in 1969 a nd was completed in 1971. T he mill produces paper products through the us e of c hemical di gesters, s econdary f iber pr ocessing, a nd pa per machines. T he primary raw materials used in the production of paper products at the mill are fiber source materials such as, but not limited to, wood chips from both softwood and hardwood species a nd ol d c orrugated c ontainers ( OCC). I n a ddition t o t he pul ping a nd paper -making process uni ts, ot her e quipment a t t he m ill a re i nvolved w ith r ecovering the chemicals used to produce virgin pulp. S pent cooking liquor is concentrated, burned to remove organics (recover heat value), and reacted with lime to regenerate the c ooking l iquor. T he s pent l ime us ed f or regeneration is recovered, washed, and calcinated for reuse. Steam requirements at the mill a re supplied by two large boilers (Bark Boiler and Power Boiler), a small package boiler and by a recovery furnace. Steam is also used to drive a t urbine electric generator that supplements the mill’s electric energy needs.

Operations at the mil l can be subdivided into six (6) functional areas. T he functional areas are based on the flow of materials within the mill and on the various steps in the production process. Emissions units within each functional process area are identified.

A. Pulping

The digesters produce pulp by utilizing a chemical pulping process in which fiber sources such as wood c hips a re di gested i n a w ater s olution of pul ping c hemicals. T his solution chemically dissolves the lignin that holds the fibers together.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 3

Repulping operations prepare fiber for the paper machines. Repulping hydromechanically breaks down fiber source materials in water, which allows the fiber stock to be introduced into the paper machine stock preparation equipment. The fiber sources can include but are not limited to virgin fiber as well as pre -consumer and post- consumer secondary (recycled) fiber.

B. Brownstock Washing

The brownstock washing areas include br ownstock w ashers a nd br ownstock w asher f iltrate tanks. B rownstock washing area 1 a nd 2 a lso include a screening process. P ulp from digester surge tanks is screened in brownstock washing areas 1 a nd 2 t o insure uniform fiber size. T he

flow -through tanks in the screening system are vented to the atmosphere.

C. Paper Making

The pa per m ach ine w et e nd f orms a ba se s heet by m eans of the primary headbox, which distributes the dilute stock evenly over a continuously moving wire screen. W ater is removed from the stock by gravity drainage, by vacuum, and by press rolls. Until the fiber sheet ha s dried sufficiently to support its own weight, it is supported f irst by t he w ire s creen a nd t hen by a moving felt sheet. Water removed f rom t he s tock dur ing pr ocessing, c alled w hite w ater, i s collected and reused in various mill processes.

D. Steam Prod uction

Steam producing units currently include:

**•** Bark Boiler

– Emissions Unit D1

**•** Power Boiler

– Emissions Unit D2

**•** Package Boiler

– Emissions Unit D3

In addition to the listed boilers, steam is produced by the Recovery Furnace (Emissions Unit E3) through waste heat recovery. Steam from the Bark Boiler, Power Boiler, and Recovery Furnace feeds a c ommon s team he ader. F rom t he he ader, t he s team may be used to drive the turbine electric generator. Steam extracted from the generator and steam that bypasses the generator is fed i nto t he s team di stribution s ystem f or us e i n va rious pr ocesses. S team f rom t he P ackage Boiler feeds directly into the steam distribution system.

The Bark Boiler burns a variety of fuels in varying combinations and amounts. Fuels include but are not limited to wood residues, OCC rejects, wastewater treatment sludge, oil, coal and natural

gas. Oils s uch a s r esidual f uel oi l, P etroleum r esidual f uel oi l, Decant slurry oil, carbon black feed stock oil, and slurry oil are all recognized as fuel oil. Used oils from mill e quipment may

also be added to the Bark Boiler fuel mixture. Particulate emissions from the Bark Boiler are controlled by a primary dust collector and a wet venturi scrubber. The presence of wood ash and

the wet venturi s crubber also results in a reduction in SO 2 emissions. Exhaust gases are emitted to the atmosphere through a dedicated stack.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 4

E. Chemical Recovery

The Turpentine Recovery System condenses turpentine from vapors collected from equipment in the D igester areas. The t urpentine t hat i s r ecovered is s old as a by

- product. T he non

- condensable fractions of these vapors are combusted in the NCG Thermal Oxidizer or the Lime

Kiln.

Spent pulping liquor collected in the weak black liquor storage tanks is concentr ated before it is processed in the Recovery Furnace. Transfers of spent liquor to or from off

- site locations may be accomplished at any point in these processes. During the evaporation process, a fatty substance called “soap” is removed from the spent liq uor by soap skimmers. The soap is sent to the Tall Oil Plant for conversion into tall oil, which is sold as a product.

The Recovery Furnace is used to r ecover pr ocess c hemicals f rom s pent l iquor f rom t he s pent liquor concentration area or spent liquor obtained from off

- site. Prior to being burned, the spent liquor may pass through a mix tank, where it ma y be mixed with particulate matter captured in the Recovery Furnace’s electrostatic precipitator (ESP). A molten inorganic residue called smelt

forms in the Recovery Furnace as a result of the burning of spent liquor. The smelt is drawn off into Smelt Dissolving Tanks and used to initiate the causticizing process that regenerates cooking chemicals. Smelt from the recovery furnace flows into the Smelt Di ssolving Tanks, where it is dissolved in water or in weak wash, which is water that has been used in the Causticizing System to wash l ime m ud. T he r esulting s olution, c alled g reen l iquor, i s s ent t o t he G reen L iquor Clarifier for fur ther pr ocessing. The Smelt D issolving T anks a re ve nted t o a c ombined s tack after particulate emissions and TRS have been reduced by spray scrubbers.

The Lime Slakers mix lime with green liquor to initiate the causticizing process that regenerates cooking liquor. T he lime is fed from lime bins that are filled either from the Lime Kiln or by lime transported from off

- site. G reen liquor enters the Slakers from the green liquor clarifier, from green liquor storage, or from off

- site sources. The mixture of green liquor and lime flows from t he S lakers t hrough c larifiers, w hich r emove unr eacted l ime a nd ot her de bris, t o the

Causticizers.

In the Causticizing area, cooking liquor is regenerated by reacting green liquor from the Smelt Dissolving T anks w ith calcium ox ide ( quick lime). The l ime i s recovered and re

- used in this process. Green liquor from the Smelt Dissolving Tanks (or from off

- site sources) flows to the Green Liquor Clarifier, where heavy particles such as undissolved smelt are allowed to settle out.

The settled materi al, known as dregs, goes to the process sewer or to the dregs filter. If the filter is used, the filtrate is returned to the Green Liquor Clarifier, and the remaining dregs are sent to the process sewer, disposed of, or transferred off- site.

Lime M ud fro m c austicizing is c alcined in the L ime K iln to regenerate c alcium ox ide ( quick lime). The Lime Kiln is fueled by natural gas and pet coke and is also currently used as a backup to the NCG Thermal Oxidizer if the Thermal Oxidizer is not being used to oxidi ze the collected

NCGs/SOGs.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 5

Particulate emissions from the kiln are controlled by an electrostatic precipitator, which returns collected lime dust to the kiln. The regenerated quick lime is transferred to the lime bins that

feed the Slakers. The Lime Bi ns are vented to the lime kiln combustion air makeup.

F. Miscellaneous Processes

The Woodyard operations include the receipt, storage, and handling of fiber source materials and

Bark Boiler fuels.

Solid fuels f or t he B ark Boiler ar e r eceived by r ailro ad or truck. After r eceipt, the f uels ar e

transferred to the Bark Boiler fuel storage pi le. O versized materials di verted from the f iber source processing/storage area pass through a hogger for size reduction before being stockpiled. Fuel reclaimed from the storage pile is conveyed directly to the Bark Boiler.

Heavy trucks and other vehicles regularly travel on paved and unpaved roads within the Valliant Mill. These vehicles are expected to cause fugitive dust emissions.

The Valliant Mill Wastewater Tr eatment System (WWTS) consists of the Bark Ash Dewatering System, the bar screen, the Primary E ffluent C larifier, a S ludge D ewatering O peration, the perforated plate screen, Aerated Stabilization Basins, and Emergency Storage Ponds. W ith the exception of the Sludge Dewatering Operation, the W WTS c omponents a re ope n t o t he atmosphere. V OCs a nd r educed s ulfur c ompounds c ontained i n m ill w astewater a re emitted from the system components.

A va riety of s olid wastes ar e g enerated as pa rt of t he m anufacturing processes at t he V alliant Mill. Wastes g enerally a re tr ansported by tr ucks f rom the mill to the on

- site S olid Waste Disposal f acility ( landfill) loc ated south of the ma nufacturing c omplex. T he ma jority of the roads in the manufacturing complex are paved while those in the landfill area are unpaved.

SECTION III. PROCESS DESCRIPTIONS

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

areas are based on the flow of materia ls within the Valliant Mill and on the various steps in the production pr ocess. E missions uni ts w ithin e ach f unctional pr ocess a rea a re i dentified. Any particular emissions unit may include more than one significant emission point.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 6

V ALLIANT M IL L F UNCTIONAL A REAS

B1

- No. 1 Brownstock Washing Area

B2

- No. 2 Brownstock Washing Area

B3

- No. 3 Brownstock Washing Area

B4

- No. 4 Brownstock Washing Area (proposed) Functional Area B

– Brownstock Washing A1

- No. 1 Digester System

A2

- No. 2 Digester System

A3

- No. 3 Digester System

A4

- No. 1 OCC Plant

A5

- No. 2 OCC Plant

A6

- Makedown Pulper

A7

- No. 3 OCC Plant

A8

- OCC Lightweight Rejects Baghouse Functional Area A

– Pulping

C1

- No. 1 Paper Machine (Stock Prep)

C2

- No. 1 Paper Machine (Wet End)

C3

- No. 1 Paper Machine (Dry End )

C4

- No. 2 Paper Machine (Stock Prep)

C5

- No. 2 Paper Machine (Wet End)

C6

- No. 2 Paper Machine (Dry End)

C7

- No. 3 Paper Machine (Stock Prep)

C8

- No. 3 Paper Machine (Wet End)

C9

- No. 3 Paper Machine (Dry End) Function al Area C

– Paper Making

D1

- Bark Boiler (decommi ssioned)

D2

- Power Boiler (decommissioned from normal operation)

D3

- Package Boiler

D4

- Power Boiler No. 2 (permitted; will not be constructed)

D5
- CFB Boiler (proposed) Functional Area D

– Steam Production E1

- Turpentine Recovery System

E2a

- Spent Liquor Concentration

E2b

- Evaporator Sump

E3a

- Spent Liquor Mix Tank (decommissioned)

E3b

- Recovery Furnace (decommissioned)

E3c

- Recovery Furnace (pro posed)

E3d

– Spent Liquor Mix Tanks ( proposed )

E4a

- Smelt Dissolving Tanks (decommissioned)

E4b

- Smelt Dissolving Tanks (proposed)

E5
- Lime Slakers

E6

- Causticizing System

E7a
- Lime Kiln No. 1 (formerly EUG E7)

E7b

- Lime Kiln No. 2 (pro posed)

E8

- Tall Oil Plant

E9

- Organic Liquid Storage Vessels

E10

- Volatile Organic Liquid Storage Tank Functional Area E

– Chemical Recovery

F1

– Woodyard

F1a

– Coal Material Handling

– Bark Boiler

F1b

– Coal Material Handling

- New

F2

- Road Emissions

– Plant Traffic

F3a

- Wastewater Treatment System (formerly EUG F3)

F3b

- Wastewater Pipeline

F4

- NCG Collection and Thermal Oxidation (decommissioned from normal operation)

F5
- Landfill Operations

F6

- Diesel Stormwa ter Pump

F7/F9

- Wood Chip Screening & Conditioning (ADS #3 proposed)

F10

– Steam Stripper System

F11

– Misc. Insignificant Activities

F12

– Wood Chipping Operation

F13

– Petcoke Handling System No. 1

F14

– Petcoke Handling System No. 2
( proposed) Functional Area F

– Miscellaneous AreasPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 7

Functional Area A - Pulping

Digester Areas (EUGs A1, A2, A3) The Digesters produce pulp by utilizing a chemical pulping process in which fiber sources are digested in a water solution of pulping chemicals. This solution chemically dissolves the lignin that hol ds t he f ibers t ogether. E ach Digester ar ea ope rates i n a similar manner, as described below. The No. 1 and No. 2 Digesters use a Kraft pulping system, and the No. 3 Di gester uses a
semi

- chemical pulping system.

Fiber source materials are conveyed from “chip silos” to “chip bins”, which are vented to the high volume, low concentration (HVLC) NCG System (EUG F4). From each chip bin, a meter feeds the

material into a ste aming vessel, which heats the material to processing temperature. The steaming vessels are vented to the Turpentine Recovery System (EUG E1).

From the steaming vessels, the fiber source material is introduced into the Digesters, along with heated cooking liquor. The material is digested as it tr avels down the Digesters by gravity flow. The No. 1 Digester area includes a pressurized impregnation vessel between the steaming vessel and the Digester. The fiber source material is steeped in cooking liquor i n the impregnation vessel before its introduction into the Digester.

Vapors produced by the cooking process are vented to the Turpentine Recovery System (EUG E1). The s pent c ooking l iquor, w hich c ontains di ssolved l ignin a nd ot her or ganic a nd inorganic

ma terials, is withdrawn from the Digesters. T his spent liquor is depressurized in flash tanks and sent to the weak liquor storage tanks. V apors from the flash tanks are vented to the Turpentine Recovery System (EUG E1) and/or the steaming vessel.

The digested pulp, also known as brownstock, is withdrawn from the bottom of the Digesters. The brownstock passes through defibrators, which mechanically break apart, the mostly

- digested fibers. The pulp is then sent to a surge tank that is vented to the HVLC NCG System (EUG F4).

Repulping Operations (OCC Plants) (EUGs A4, A5, A6, A7) Repulping operations prepare fiber for the paper machines. Repulping hydromechanically breaks down fiber source materials in water, which allows the fiber stock to be introduced into the paper machine s tock pr eparation e quipment. T he f iber s ources c an i nclude, but a re not l imited to, virgin fiber, as well as preconsumer and postconsumer secondary (recycled) fiber.

The OCC Plants process OCC (old corrugated container) materials, w hich include, but are not limited to, old corrugated containers (e.g., cardboard boxes), old newspapers, rejected materials from paper machines or box m anufacturing f acilities, a nd ot her t ypes of f iber -containing products.

OCC is received at the Valliant Mill by truck and by rail. Once the OCC is repulped, it then goes through a series of steps t o remove he avy and light r ejects and adequately s eparate t he f ibers from each other. Heavy reject materials may be landfilled or transferred off

- site. Light rej ects are pressed to remove water, then may be l andfilled, transferred off

- site, or t ransferred to aPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 8

receiving bi n be fore be ing us ed a s a f uel s ource. T he pr epared f iber i s s tored i n O CC hi gh density storage chests for use in the paper machines.

As part o f the proposed project, changes will be made to the OCC Plants to enable the Valliant Mill to achieve the target production.

The Makedown Pulper performs a function similar to the OCC plants. I t uses box plant trim, which is a r elatively cl ean fiber s our ce ma terial, and cull r olls f rom the Valliant Mill paper machines. Fiber prepared in the Makedown Pulper can be introduced into the stock preparation areas of any of the three paper m achines. There are no significant em ission points as sociated

with the M akedown Pulper.

OCC Lightweight Rejects Baghouse (EUG A8) The O CC L ightweight R ejects B aghouse c ontrols pa rticulate e missions f rom the R ejects Receiving Bin. Currently, OCC reject materials are blown from the OCC Plants to this bin prior to being introdu ced to the Bark Boiler fuel stream. As part of the proposed project, this unit will be r elocated to facilitate int roduction of the O CC r eject ma terials int o the C FB B oiler fuel

stream

.

Functional Area B - Brownstock Washing

Brownstock Washing Areas (EUGs B1, B2, B3, B4) The brownstock washing areas include br ownstock w ashers a nd br ownstock w asher f iltrate tanks. Brownstock washing areas 1 and 2 also include a screening process.

Pulp f rom di gester s urge t anks i s s creened i n br ownstock w ashing a reas 1 a nd 2 t o ensure

uniform fiber size. The flow

- through tanks in the screening system are vented to the atmosphere. Pulp, either from t he s creening s ystems or f rom di gester s urge t anks, i s w ashed ove r r otary vacuum dr ums i n t he br ownstock w ashers t o r emove s pent c ooking c hemicals. After being washed, the pulp is transferred to several high density storage silos. The brownstock washers are hooded and are vented from the pulp mill building to the atmosphere.

Filtrate from the brownstock washers is collected into brownstock washer filtrate tanks. F rom these tanks, filtrate is either reused in the washing process or is returned to the digester areas.

Brownstock washing area 3 pe rforms a similar function to that described above for brownstock washing ar eas 1 a nd 2. However, brownstock washing area 3 w ashes pul p f rom t he N o. 3 Digester, which uses a s emi

- chemical pulping system. Therefore, brownstock washing area 3 is not subject to the maximum achievable control technology (MACT) standard for pulp and paper mills (40 CFR Part 63, Subpart S).

The proposed project i ncludes t he i nstallation of a n a dditional br ownstock w ashing s ystem (brownstock washing area 4). As a new brownstock washing system, the unit will be subject to

the N ew S ource P erformance Standard (NSPS) i n 40 C FR P art 60, S ubpart B B. T herefore, emissions f rom t he ne w br ownstock w ashing s ystem w ill be c ollected a nd r outed t o the NCGPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 9

collection system. The collection and control of this source will also comply with the MACT standard in 40 CFR Part 63, Subpart S.

Functional Area C - Paper Making

Paper Machine Stock Preparation (EUGs C1, C4, C7) Stock preparation is a process of blending the fibers (stock) with water and other additives for consistency control and to prepare the stock for introduction onto the paper machines. In general, the stock is diluted, bl ended, a nd c leaned a s i t pa sses f rom ve ssel t o ve ssel t hrough t he s tock preparation pr ocess. S tock f rom va rious s ources, s uch a s vi rgin f iber f rom t he digester areas, secondary fi ber from t he O CC pl ants, a nd r ecycled f iber f rom t he M akedown P ulper, m ay be blended t ogether i n t his pr ocess. I n a ddition, f iber r ecycled from the wet end or the dry end (known as broke) may be processed and added to the stock during preparation.

The va rious c hes ts (vessels) associated with the s tock preparation process ar e ve nted either directly to the atmosphere or to the interior of the paper machine building.

Paper Machine Wet End (EUGs C2, C5, C8) The pa per m achine w et end forms a ba se s heet by m eans of the primary he adbox, w hich distributes the dilute stock evenly over a continuously moving wire screen. W ater is removed from the stock by gravity drainage, by vacuum, and by press rolls. Product with additional layers can be produced by using additional hea dboxes. Until the fiber sheet has dried sufficiently to support its own weight, it is supported first by the wire screen and then by a moving felt sheet. Water removed from the stock during processing, called white water, is collected and reused in

vario us m ill pr ocesses. V arious s ections of t he pa per m achine w et end are vented to the atmosphere or to the interior of the paper machine building.

Paper Machine Dry End (EUGs C3, C6, C9) The fiber sheet passes f rom t he w et e nd of t he m achine t o t he dr y e nd, w here i t i s he ated on drying cylinders. The sheet is then processed on trimming and winding equipment that produces paper rolls of appropriate width and diameter. P roduct t rimmed f rom r olls a nd c ull r esulting from breaks is reprocessed in the dry end pulper. T he recovered fiber is returned to the stock preparation area.

Emissions from the dryer section of each machine are vented to the atmosphere. T he dry end pulpers a nd ot her i nsignificant e mission poi nts ve nt t o t he i nteriors of t he pa per machine buildings.

Functional Area D - Steam Production

Steam Producing Units The Valliant Mill currently operates three steam

- producing boilers: t he Bark Boiler, the Power Boiler, and the Package Boiler. A second power boiler (Power Boiler No. 2) is permitted under

Permit No. 96 -043- C (M

- 3), but will not be constructed. A s part of the proposed project, the Bark Boiler will be decommissioned, the Power B oiler w ill be de commissioned from nor mal operation, with continued operation as a back

- up steam generating un it, and a CFB Boiler will bePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 10

installed. In addition, steam will be pr oduced by t he pr oposed R ecovery Furnace ( EUG E 3c) through waste heat recovery.

Steam from the boilers and Recovery Furnace feeds a com mon steam header. From the header, the steam may be used to generate electricity. As part of the project, Weyerhaeuser proposes to upgrade the electric generating capacity of the Valliant Mill. Steam extracted from the generator and steam that bypasses the generator is fed into the steam distribution sy stem for use in various processes. Steam from the Package Boiler feeds directly into the steam distribution system.

The CFB Boiler will burn a variety of fuels in varying combinations and amounts. F uels will include, but are not limited to coal, wood and bark residuals, OCC rejects, wastewater treatment sludge, oil, na tural g as, pe troleum c oke ( petcoke), a nd N CGs/SOGs. U sed oi ls f rom m ill equipment may also be added to the CFB Boiler fuel mixture. Exhaust gases will be emitted to the atmosphere throu gh a shared stack with the new Recovery Furnace.

The existing Bark Boiler (to be decommissioned) can burn fuels including, but not limited to, coal, wood and bark residuals, OCC rejects, wastewater treatment sludge, oil, used oil from the mill, natural g a s, pe tcoke, m ethanol, a nd N CGs/SOGs. Its emissions di scharge t hrough a

dedicated stack.

The existing Power Boiler can burn natural gas, oil, and propane. E xhaust gases are emitted to the atmosphere through a shared stack with the Tall Oil Scrubber, ex isting Recovery Furnace and Spent Liquor Mix Tank (existing Main Stack). As part of the proposed project, the Power Boiler will be de commissioned f rom nor mal ope ration, w ith c ontinued operation as a b ack

- up s team generating uni t. The P ower B oiler w ill be used i n t wo di fferent ope rating scenarios: (1) supplemental s team pr oduction a nd ( 2) ba ckup s team pr oduction. During supplemental steam production, the Power Boiler will be ope rated w ith bot h t he C FB B oiler a nd t he R ecovery Furnace in operation. During backup steam production, the Power Boiler will replace the steam

generating capacity of e ither t he C FB B oiler or t he R ecovery F urnace not i n ope ration. T he Package Boiler burns only natural gas. Its emissions discharge through a dedicated stack.

Functi onal Area E - Chemical Recovery

Turpentine Recovery System (EUG E1) The Turpentine Recovery System condenses turpentine from vapors collected from equipment in the Digester areas. T he t urpentine t hat i s r ecovered is s old as a by

- product. T he

non-conden sable fractions of these vapors are currently combusted in the NCG Thermal Oxidizer or in the existing Lime Kiln. A s part of the proposed project, non

- condensable vapors will be rerouted to the proposed Recovery Furnace, with the CFB Boiler serving as the primary back -up control device.

In the Turpentine Recovery System for the No. 1 and 2 Digester areas, vapors are condensed to a water fraction, a turpentine (liquid) fraction, and a vapor fraction. The water fraction is collected in a series of tanks before being sent to the steam stripper or sewer. The turpentine fraction flows through a degasser to a turpentine decanter, which separates the turpentine from the remainingPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 11

water. The water is drawn off and sent to the steam stripper or the sewer. The t urpentine flows to the turpentine receiver and then to a storage tank to await loading into trucks. Low volume, high concentration (LVHC) vapors collected from t he s ystem a re c urrently s ent t o t he N CG Thermal Oxidizer or to the Lime Kiln. As part of the p roposed project, vapors will be rerouted to the proposed Recovery Furnace, w ith t he C FB B oiler s erving a s t he pr imary ba ck

- up c ontrol

device.

Turpentine storage a nd l oading f acilities, t he pum p t ank t hat r eceives l iquid f rom t he c yclone separators, a nd t h e collection tank are i nsignificant em ission sources t hat ar e ve nted to the atmosphere.

Spent Liquor Concentration (EUG E2a and Evaporator Sump Vent E2b) Spent pul ping l iquor c ollected i n t he w eak l iquor s torage t anks i s concentrated before it is

process ed in the Recovery Furnace. Transfers of spent liquor to or from off

- site locations may be accomplished at any point in these processes.

Liquor is concentrated by sending it to a multiple

- effect evaporator system, where non

- contact steam is used to evapo rate water from the liquor. S pent liquor leaving the evaporators may be

sent to on- site storage, transferred off -site, or sent on for further concentration.

During the evaporation process, a fatty substance called soap is removed from the spent liquor by soap skimmers. The soap is sent to t he T all O il P lant ( EUG E 8) f or c onversion i nto t all oi l, which is sold as a product.

As pa rt of t he pr oposed pr oject, c hanges w ill be m ade t o the spent liquor concentration area to

enable the Valliant Mill to achieve the target production.

Recovery Furnace (EUG E3c) As part of the proposed project, t he e xisting R ecovery F urnace ( EUG E 3b) w ill be decommissioned and replaced with a ne w R ecovery F urnace ( EUG E 3c). T he ne w R ecovery Furnace will serve in a similar capaci ty as the decommissioned unit.

The Recovery Furnace is used to r ecover pr ocess c hemicals f rom s pent l iquor f rom t he s pent liquor concentration area (EUGs E2a and E2b) or spent liquor obtained from off

- site. Prior to being burned, the spent liquor may pass through the Spent Liquor Mix Tanks (EUG E3d), where it m ay be m ixed with particulate m atter capt ured in the Recovery Furnace’s electrostatic precipitator (ESP).

A molten inorganic residue called smelt forms in the Recovery Furnace as a result of the b urning of spent liquor. The smelt is drawn off into Smelt Dissolving Tanks (formerly EUG E4) and used to initiate the causticizing process that regenerates cooking chemicals.

As part of t he pr oposed pr oject, t he ne w R ecovery F urnace w ill be come t he pr imary c ontrol

device for NCGs and SOGs, which will be rerouted from the NCG Thermal Oxidizer . T he new CFB Boiler w ill s erve a s t he pr imary ba ckup c ontrol de vice f or N CGs a nd S OGs. The NC G Thermal Oxidizer is proposed to be decommissioned as part of the proj ect; however, it will bePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 12

kept available in the event of extenuating circumstances that prevent either the Recovery Furnace

or the CFB Boiler from co mbusting NCGs/SOGs.

In addition to burning spent liquor and combusting NCGs/SOGs, the Recovery Furnace als o uses natural gas and is capable of burning other materials that may contain spent cooking chemicals, such as soap from the evaporators, brine from the tall oil reactor, and turpentine. Heat produced by the Recovery Furnace is us ed to generate s team. E x haust g ases w ill be e mitted to the atmosphere through a shared stack with the proposed CFB Boiler.

Smelt Dissolving Tank (EUG E4b)
Smelt from the Recovery Furnace flows into the Smelt Dissolving Tanks, where it is dissolved in water
or in weak wash, which is water that has been used in the Causticizing System to wash lime mud. The resulting s olution, c alled g reen l iquor, i s s ent t o t he G reen L iquor C larifier ( EUG E 6) f or further processing. A s part of the proposed project, the existing Smelt Dissolving T anks (EUG E4a (formerly, EUG E4)) will be replaced with new tanks. A irflow from the new Smelt Dissolving Tanks (EUG E4b) will be routed through the new Recovery Furnace as combustion air make

- up. Therefore, the new Smelt Dissolving Tanks will not be emis sions units.

Lime Slakers (EUG E5) The Lime Slakers mix lime with green liquor to initiate the causticizing process that regenerates cooking liquor. The lime is fed from lime bins that are filled either from the Lime Kilns or by lime transported from of f- site. G reen liquor enters the Slakers from the green liquor clarifier, from green liquor storage, or from off

- site sources. The mixture of green liquor and lime flows from the Slakers through classifiers, which remove unr eacted l ime a nd ot her de bris, t o t he

Causticizers.

Causticizing Area (EUG E6) In the Causticizing area, cooking liquor is regenerated by reacting green liquor from the Smelt Dissolving T anks w ith c alcium ox ide ( quick l ime). T he lime is recovered and re

- used in this

process.

Green li quor f rom t he S melt D issolving T anks ( or f rom off

- site s ources) f lows t o the G reen Liquor Clarifier, where heavy particles, such as undissolved smelt, are allowed to settle out. The settled material, known as dregs, goes to the dregs filter. The filtrate is returned to the Green Liquor Clarifier, and the remaining dregs are sent to the process sewer, disposed, or transferred

off

- site.

Clarified green liquor can be s ent t o s torage, t he D igesters, t he L ime S lakers, or of f

- site destinations. After being mixed with lime in the Slakers, the green liquor goes through a series of Causticizers that provide the residence time needed for the lime to react with the green liquor to regenerate the cooking liquor.

The cooking liquor from the Causticizers flows into clarifiers. T he clarified cooking liquor (or cooking liquor from off

- site sources) is stored, used in the Digesters, or transferred off

- site. The material tha t s ettles to the bot tom of the c ooking liquor c larifiers is lime mud (principallyPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 13

calcium carbona te). The lime mud is washed with water in a Lime Mud Washer. The overflow from the Lime M ud W asher g oes t o w eak w ash s torage f or l ater us e i n t he S melt D issolving Tanks and other areas. The washed lime mud is sent to storage tanks and from there to a Li me Mud Filter. The filtered lime mud will be calcined in either of the Lime Kilns (EUGs E7a and E7b), c onverting i t ba ck t o c alcium ox ide. T his Lime K iln pr oduct i s t ransported to the lime bins. If the Lime Kilns are not operating, the lime mud is landf illed or transferred off

- site.

Lime Kilns (EUGs E7a and E7b) Weyerhaeuser is proposing to construct a new Lime Kiln (EUG E7b) to supplement the function of the existing Lime Kiln (EUG E7a [formerly, EUG E7]). Both Lime Kilns will serve a similar

functio n in the chemical recovery process.

Lime mud from causticizing is calcined in the Lime Kilns to regenerate quick lime. The existing Lime Kiln’s burner m odification a llows t he ki ln t o c ombust a c ombination of na tural gas a nd petcoke as fuel (as documented in a Tier I Construction Permit application submitted April 15, 2004). T he proposed Lime Kiln will also combust a combination of natural gas and petcoke as

fuel.

The regenerated quick lime is transferred to the Lime Bins, which feed the Slakers (EUG E5)

. The Lime Bins are vented to the Lime Kiln combustion air make -up.

Tall Oil Plant (EUG E8) Tall oil is a heavy organic oil recovered and sold for various commercial uses. It is produced by the Tall Oil Plant from the soap collected during spent liquor evaporation (EUGs E2a and E2b). Tall oil is produced by charging the Tall Oil Reactor with soap, water, and sulfuric acid. T he reactor and mixture are then heated to produce a batch of tall oil.

After the reaction, the contents of the tall oil reactor settle into three layers. The tall oil itself rises to the top of the r eactor, from w here it is w ithdrawn to wet ta ll oi l s torage ta nks. T he middle layer is a sludge that contains lignin and other organic materials. This sludge is drawn off into a sludge storage tank. A predominantly sodium sulfate brine solution collects at the bottom

of the reactor.

The tall oil is transferred from the storage tanks directly to transport vessels or to another storage tank. T all oi l c an be l oaded into transport vess els f rom t his s torage t ank. T he s ludge i s transferred back to the t all oi l r eactor, caustic i s adde d, and the r eactor i s he ated again in a process know n a s l ignin c ook. T he r esulting m aterial i s r eturned t o t he e vaporator a rea and mixed with spent liquor for chemical recovery.

A packed bed scrubber controls emissions of total reduced sulfur (TRS) from the tall oil reactor, the wet tall oil tanks, and the brine tank. This scrubber is vented to a shared stack with the Power Boiler, existing Recovery Furnace and Spent Liquor Mix Tank (existing Main Stack).PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 14

Storage Vessels (EUGs E9 and E10) Various lower vapor pressure organic liquids, such as black liquors, tall oil, soaps, and fuel oil, are stored in tanks and other ve ssels a t the V alliant M ill ( EUG E 9 ). O ther vol atile or ganic liquids, such as tur pentines a nd gasoline f uel, are s tored in smaller ta nks a t the V alliant Mill (EUG E10).

Functional Area F - Miscellaneous Processes

Woodyard (EUG F1) Woodyard operations include the r eceipt, s torage, a nd ha ndling of f iber s ource m aterials a nd

solid fuels.

Fiber Source Materials Fiber source materials, such as wood chips, are received by railroad or truck. R ailcar rollovers and truck lift dumpers are used to unload the material into receiving pits. The rec eived materials can be stored for later retrieval or conveyed directly to the screening operation.

Material to be stored is stockpiled into storage piles by stackers. Material can be removed from the storage piles by reclaimers. Reclaimed material is tr ansferred to chip screening/conditioning (EUGs F7 and F9) and then to chip silos. Undersized (fine) rejects from the scalping screens are conveyed to the Bark Boiler fuel storage pile feed conveyor. Oversized rejects from the scalping

screens ar e ei ther landfilled or added to t he Bark Boiler f uel s torage pi le. T his f uel ha ndling system w ill s upply the C FB Boiler after it ha s been constructed. T he f iber source material is transferred as needed from the chip silos to the chip bins in the Digester areas (E UGs A1, A2, and A3).

Conveyors and transfer points in the fiber source material handling system are partially covered and/or e nclosed. T his s erves t o r educe t he pot ential for fugitive particulate emissions from material handling operations.

Solid Fuels Solid fuels ar e r eceived by r ailroad or t ruck. A fter r eceipt, the fuels are conveyed to the fuel storage pile. Oversized materials diverted from t he f iber s ource pr ocessing/storage ar ea pa ss through a hogger for size reduction before being stockpiled. F uel reclaimed from the storage pile is conveyed directly to the Bark Boiler (or after construction, the CFB Boiler.)

Conveyors and transfer points in the fuel handling system are partially covered and/or enclosed. This s erves t o r educe t he pot ential f or fugitive pa rticulate e missions f rom ma terial ha ndling operations.

Coal Material Handling (EUG F1a & F1b) Coal is received by railroad or truck. After receipt, the fuels are transferred to the bark boiler conveyor or to the fuel storage pilePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 15

Facility T raffic (EUG F2) Heavy trucks and other vehicles regularly travel on paved and unpaved roads within the Valliant Mill. These vehicles are expected to cause fugitive dust emissions by the action of their tires on

the surface of the roads.

Any airborne dus t generated by vehicle traffic is emitted directly to the atmosphere. The roads on w hich t hese ve hicles t ravel a re i n good r epair, a nd pa ved r oads a re cleaned periodically to minimize the extent of fugitive dust emissions. Unpaved roads are periodically treated to reduce fugitive dust emissions.

Facility vehicles are typically fueled onsite from a gasoline fuel tank (EUG E10). Vehicle traffic occurs in part because of the receipt of raw materials, the shipping of finished products, and the receipt of ma terials used in the various processes at the Valliant Mill.

Wastewater Treatment System (EUG F3a) The Valliant Mill Wastewater Treatment System consists of the Bark Ash Dewatering System, the Primary Effluent Clarifier, a Sludge Dewatering Operation, Aer ated Stabilization Basins, and Emergency S torage P onds. W ith t he e xception of t he S ludge D ewatering O peration, t he Wastewater Treatment System components are open to the atmosphere. The Sludge Dewatering Operation is housed in a building with openings (e .g., windows) to the atmosphere. Mainly VOC and r educed s ulfur c ompounds c ontained i n m ill w astewater a re e mitted f rom t he system components. A por table di esel s tormwater pum p ( EUG F 6) f or s tormwater m anagement i s

utilized as needed.

The Bark Ash Dewate ring System receives liquids from the bark ash sand tank. Solids that settle in the Dewatering Ponds are landfilled. The liquid overflow from the Dewatering Ponds is sent to the Runoff Pond. From the Runoff Pond, water overflows to an Aerated Stabilization Basin,

while some is recirculated to the bark ash sand tank. The No. 1 Aerated Stabilization Basin can be bypassed, either to another basin or to the National Pollutant Discharge Elimination System (NPDES)

- permitted outfall.

Other mill w astewater s tr eams are conve yed to the w astewater t reatment ar ea by t he pr ocess sewer s ystem. T hese s treams pa ss t hrough a ba r s creen to the Primary Effluent Clarifier, or bypass the clarifier and mix directly with the overflow from the Runoff Pond. S olids from the

pr imary clarifier go to the Sludge Dewatering Operation. Solids from this operation will either be used as fuel in the CFB Boiler or landfilled. The liquid from sludge dewatering is returned to the Primary Effluent Clarifier. Liquid from the clarifier com bines with water from the Runoff Pond. Microbial nutrients may be added to the clarifier effluent to aid biodegradation of organic materials i n t he l iquid. I f ne cessary, c larifier e ffluent a nd r unoff pond effluent can be sent to emergency holding ponds. Chemical may be used to control WWTS H 2 S.

From the No. 1 A erated Stabilization Basin, wastewater is either discharged or enters the No. 2 Aerated Stabilization Basin for final settling, biodegradation, and clarifying. T he effluent from

the N o. 2 Aerated Stabilization Basin is di scharged via the N PDES

- permitted outfall. T hePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 16

Aerated Stabilization Basins also r eceive s torm w ater r unoff f rom va rious poi nts w ithin t he Valliant Mill, including the Landfill Collection Pond and the Chip Pile Collection Pond.

W astewater Pipeline (EUG F3b) A wastewater pipeline transfers wastewater effluent f rom the V alliant M ill to the R ed River. Under normal operating conditions, effluent from the Valliant Mill treatment ponds flows to a

48- inch diameter pipeline. The effluen t then typically flows by gravity approximately six miles to a collection box. T he collection box is open to the atmosphere and is the emission point for any hydrogen sulfide (H 2 S) formed in the pipeline. From the collection box, the effluent flows to

a 200- foot diffuser at the bottom of the Red River. During periods of heavy rainfall, pumps can be operated to accommodate the increased flow rates.

NCG Collection and Thermal Oxidation (EUG F4) Many sources of NCGs are ve nted t o one of t wo c ollection s ystems f or bur ning. T he LVHC streams ar e r elatively l ow

- flow

- rate, high

- concentration s ources of N CGs, w hereas t he HVLC streams produce more total gas flow but much lower concentrations of NCGs. The following

sources of concentrated NCGs are vented to the LVHC system:

**•** Turpentine recovery condensers

**•** Turpentine decanters

**•** Turpentine recovery underflow tanks

**•** Turpentine degassers

**•** Turpentine receiver tank

**•** No. 3 Digester Area flash steam condensers

**•** Evaporator hotwells

**•** Steam stripper system

The steam stripper fee d tank (EUG F10) collects and routes condensates from various processes at the facility to the LVHC system. The stripper off

- gas (SOG) from the steam stripper is routed directly to the NCG Thermal Oxidizer via an individual line.

The chip bins and digester surge tanks are vented to the HVLC system (EUG F4b). NCGs from the No. 1 Digester chip bin is routed directly to the NCG Thermal oxidizer through an individual

line.

Currently, the primary control device f or t he c ollected N CGs i s t he N CG/SOGs T herma l Oxidizer. H owever, a s pa rt of t he pr oposed pr oject, N CGs/SOGs w ill be rerouted to the proposed Recovery Furnace, with the CFB Boiler serving as the primary back

- up control device. The NCG Thermal Oxidizer is proposed to be decommissioned as part of the project; however, it will be kept available in the e vent of e xtenuating c ircumstances tha t pr event e ither the Recovery Furnace or the CFB Boiler from combusting NCGs/SOGs.

During certain start

- up operations and upset conditions, the NCG streams may be re leased to the atmosphere f or a r elatively s hort t ime f or s afety r easons. These ar e r ecognized technological limitations for purposes of excess emissions reporting (OAC 252:100-9- 1).PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 17

Landfill Operations (EUG F5) A va riety of s olid wastes ar e g enerated as part of the manufacturing pr ocesses at t he V alliant Mill. Wastes g enerally a re tr ansported via tr ucks f rom the V alliant M ill to the on

- site S olid Waste Disposal facility (landfill) located south of t he m anufacturing c omplex. T he t rucks regularly travel ba ck and forth between the landfill and manufacturing areas. The majority of the roads in the manufacturing complex are paved, while those in the landfill area are unpaved.

Vehicle traffic related to landfill operations may cause fugitive dust emissions by the action of tires on the surface of the roads. In addition, the unloading of waste materials from trucks into the landfill and other associated waste handling ope rations m ay g enerate s mall a mounts of fugitive dust emissions. To limit fugitive emission s, paved roads are periodically cleaned and unpaved roads are periodically treated.

Wood Chip Screening & Conditioning (EUGs F7 and F9) The Valliant Mill operates wood chip screening and conditioning equipment for processing wood chips prior to being pulp ed. This area currently consists of bar screens, chip conditioners, and two air density separators. A third air density separator will be installed as part of the proposed project. E missions from the bar screens and chip conditioners are fugitive in nat ure. The three air density separators will vent directly to the atmosphere.

Steam Stripper System (EUG F10) The steam stripper feed tank (EUG F10) collects and routes condensates from various processes at the facility to the LVHC system. The stripper of f- gas (SOG) from the steam stripper is routed directly to the NCG Thermal Oxidizer via an individual line.

Miscellaneous Insignificant Activities (EUG F11) The Valliant Mill has several activities that are insignificant in nature such as storage tanks a nd emergency engines.

Wood Chipping Operation (EUG F12) The V alliant M ill i s c urrently c onstructing a w ood c hipping ope ration c onsisting of unloading and conveying equipment, a debarker, and a chipper. A log crane system will unload logs from incoming tr ucks and place them on a pile or on the system in feed conveyor. A debarking drum will be fed by a conveyor from the log crane system to remove the outer layer of bark from the incoming logs. Bark removed from the logs will be sent from the enclosed bark chutes under the drum, and will then be conveyed to the bark handling and storage system. A chipper driven by an e lectric m otor w ill pr oduce w ood c hips w ith a uni form s ize f rom t he de barked l ogs. A conveyor w ill tr ansport c hips to the V alliant M ill’s ch ip out stacking a nd r ecovery s ystems. Emissions from this operation will be fugitive in nature.

Petcoke Handling Systems (EUGs F13 and F14) The Valliant Mill submitted a Tier I Construction Permit Application (dated April 15, 2004) to DEQ for the construction of a petcoke handling system (No. 1) to supply fuel for the existing Lime Kiln. A second petcoke handling system for the new Lime Kiln is planned as part of the proposed project. Both systems operate in a similar manner, as described on the followin g page.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 18

Petcoke will be delivered to the mill via trucks. T he petcoke will be transferred from the truck trailer to a storage silo using pneumatic conveyance. T he silo will be equipped with a bin vent that allows for air displacement when the silo is bei ng filled with petcoke. The bin vent will be equipped with a filter to aid in product recovery. F rom t he s torage s ilo, t he pe tcoke w ill be pneumatically conveyed to the kiln burners.

SECTION IV. EQUIPMENT

The numbering of emission points is repeated here from the permit application, e.g. “E -A4,C.” The applicant has requested that heat input capacity for several units be kept confidential.

EUG A1

– No. 1 Digester System

Emission Point EU Name/Model Construction Date

E3c (Recovery Furnace), or D5 (C FB Boiler), or F4 (NCG thermal oxidizer) #1 Pre

- Steaming Chip Bin

Pre -1972/1998/2005 ( Planned) #1 Steaming Vessel #1 Digester #1 Surge Tank 1A Stage Flash Tank 1B Stage Flash Tank Second Stage Flash Tank

Secondary Flash Tank

EUG A2

– No. 2 Digester System

Emission Point EU Name/Model Construction Date

E3c (Recovery Furnace), or D5 (CFB Boiler), or F4 (NCG thermal oxidizer) #2 Chip Bin Pre

- 1972/1998/2005 (Planned) #2 Steaming Vessel #2 Digester #2 Surge Tank Primary F lash Tank Parallel Primary Flash Tank Secondary Flash Tank

EUG A3

– No. 3 Digester System

Emission Point EU Name/Model Construction Date

E3c (Recovery Furnace), or D5 (CFB Boiler), or F4 (NCG thermal oxidizer) #3 Chip Bin Pre -1972/1998/2005 (P lanned) #3 Steaming Vessel #3 Digester #3 Surge Tank Primary Flash Tank Secondary Flash TankPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 19

EUG A4

– 1 OCC Plant

Emission Point EU Name/Model Construction Date

A4 No. 1 OCC Plant 1981/ 2005 ( planned )

The O CC P lants ar e de fined by the Pulp & P aper I ndustry M ACT a s “ secondary f iber operations,” subject to the MACT only if bleaching were to occur. No bleaching is conducted at this plant.

EUG A5

– No. 2 OCC Plant

Emission Point EU Name/Model Construction Date

A5 No. 2 OCC Plant 199 0/2005 (planned)

EUG A6

– Makedown Pulper

Emission Point EU Name/Model Construction Date

A6 Makedown Pulper Pre

- 1972

EUG A7

– No. 3 OCC Plant

Emission Point EU Name/Model Construction Date

A7 No. 3 OCC Plant 2000/2005 (planned)

EUG A8

– OCC Light weight Rejects Handling System

Emission Point EU Name/Model Construction Date

A8 (baghouse stack) OCC Lightweight Rejects Handling System 1990/2001/2005 (planned) OCC Lightweight Rejects Receiving Bin

EUG B1

– No. 1 Brownstock Washing Area

Emissio n Point EU Name/Model Construction Date

B1 Brownstock Washer 1 Pre

- 1972

EUG B2

– No. 2 Brownstock Washing Area

Emission Point EU Name/Model Construction Date

B2 Brownstock Washer 2 Pre

- 1972/1981

EUG B3

– No. 3 Brownstock Washing Area

Emission Poin t EU Name/Model Construction Date

B3 Brownstock Washer 3 Pre

- 1972/1974

EUG B4

– No. 4 Brownstock Washing Area

Emission Point EU Name/Model Construction Date

B4 Brownstock Washer 4 2005 (Planned)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 20

This unit is a “semi

- chemical” operation. It is theref ore not subject to the MACT for the Pulp and Paper I ndustry. 40 C FR 63.443( b) s pecifies s tandards onl y f or t he L VHC s ystems i n a semi

chemical operation, but pulp washing is defined in 40 CFR 63.441 to be a HVLC operation.

EUG C1

– No. 1 Paper Machine (S tock Preparation)

Emission Point EU Name/Model Construction Date

C1 No. 1 Paper Machine (stock preparation) Pre

- 1972/1990/ 1996/2005 (planned)

EUG C2

– No. 1 Paper Machine (Wet End)

EUG C3

– No. 1 Paper Machine (Dry End)

Emission Point EU Name/Model C onstruction Date C2,A Fourdrinier Pre

- 1972 /1990 / 1996/2005 (planned) C2,B Vacuum Pumps/ Vacuum Flume
C2,D Press Section
C3,A Dryer Section

The “Fourdrinier” operation refers to a rotating cylindrical wire mesh screen used for draining water from p ulp.

EUG C4

– No. 2 Paper Machine (Stock Preparation)

Emission Point EU Name/Model Construction Date

C4 No. 2 Paper Machine (stock preparation) Pre

- 1972 / 2000 /2005 (planned)

EUG C5

– No. 2 Paper Machine (Wet End)

EUG C6

– No. 2 Paper Machine (Dry End)

Emission Point EU Name/Model Construction Date C5,A Fourdrinier Pre

- 1972 / 2000 /2005 (planned) C5,B Press Section
C5,D Vacuum Pumps/ Vacuum Flume
C6,A Dryer Section

EUG C7

– No. 3 Paper Machine (Stock Preparation)

Emission Point EU Name/Mo del Construction Date

C7 No. 3 Paper Machine (stock preparation) 1981 / 2002 /2005 (planned)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 21

EUG C8

– No. 3 Paper Machine (Wet End)

EUG C9

– No. 3 Paper Machine (Dry End)

Emission Point EU Name/Model Construction Date C8,A Fourdrinier 1981 / 2002 /2005 (planned) C8,B Press Section
C8,D Vacuum Pumps/ Vacuum Flume
C9,A Dryer Section

EUG D1

– Bark Boiler

- Decommissioned

EUG D2

– No. 1 Power Boiler

Emission Point EU Name/Model MMBTUH Construction Date

Main Stack No. 1 Power Boiler Confiden tial Pre -1972

This boiler ha s be en de commissioned f rom nor mal ope ration, w ith c ontinued ope ration a s a supplemental steam source and a backup steam generating unit. The facility has taken limits on this previously grandfathered boiler.

EUG D3

– Packag e Boiler

Emission Point EU Name/Model MMBTUH Construction Date

D3 Package (gas

- fired) Boiler Confidential Pre

- 1972/1985

This unit was constructed in Michigan in 1969, then relocated to Valliant in 1985.

EUG D4

– No. 2 Power Boiler

Emission Point EU Name/Model MMBTUH Construction Date

D4 No. 2 Power Boiler Confidential Permitted; will not be

constructed

EUG D5

– CFB Boiler

Emission Point EU Name/Model MMBTUH Construction Date

D5 CFB Boiler Confidential 2005 (planned)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 22

EUG E1

– Turpenti ne Recovery System

Emission Point EU Name/Model Construction Date

E3c (Recovery Furnace), or D5 (CFB Boiler), or F4 (NCG thermal oxidizer) 2

- Stage Condenser (No. 1 Fiber Line) Pre

- 1972/1989

Trim Condenser Degasser No. 1 Turpentine Decanter No. 1

Underflow Tank No. 1

Mixed Underflow tank

Primary Condenser Secondary Condenser (No. 2 Fiber Line) Degasser No. 2 Turpentine Decanter No. 2

Underflow Tank No. 2 Turpentine Receiving Tank Flash Steam Condenser (No. 3 Fiber Line )

EUG E2a

– Spent Liquor Concentration

Emission Point EU Name/Model Construction Date E3c (Recovery Furnace), or D5 (CFB Boiler), or F4 (NCG thermal oxidizer) No. 1 Evaporator Hotwell Pre

- 1972/1974/1981

/ 2000 No. 2 Evaporator Hotwell

Evaporators are defined by 40 CFR Part 63, Subpart S to be an “LVHC” system.

EUG E2b

– Evaporator Sewer Sump

Emission Point EU Name/Model Construction Date E2b,A Evaporator Sewer Sump Pre

- 1972

The evaporator sump is part of the wastewater collection system. As such, it does not meet the definitions i n the P ulp & P aper M ACT f or ei ther “evaporator system” or “process wastewater treatment system.”

EUG E3a

– Spent Liquor Mix Tank

- Decommissioned

Emission Point EU Name/Model Construction Date

Main Stack Spent Liq uor Mix Tank/Spent Liquor Day Tank Pre

- 1972/1991

EUG E3b

– Recovery Furnace

- Decommissioned

EUG E3c

– Recovery Furnace

Emission Point EU Name/Model Construction Date

E3c Recovery Furnace 2005 (planned)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 23

EUG E3d

– Spent Liquor Mix Tank

Emission Point EU Name/Model Construction Date

E3d Spent Liquor Mix Tank 2005 (planned)

EUG E4a

– Smelt Dissolving Tanks

- Decommissioned

Emission Point EU Name/Model Construction Date E4a ( Smelt Dissolving Tanks Stack) Smelt Dissolving Tank “A” Pre

- 1972

Smelt Diss olving Tank “B”

EUG E4b

– Smelt Dissolving Tanks

Emission Point EU Name/Model Construction Date

E3c Smelt Dissolving Tank “A” 2005 (planned) Smelt Dissolving Tank “B” 2005 (planned)

EUG E5

– Lime Slakers

Emission Point EU Name/Model Constructio n Date

E

- E5, A (Lime Slaker Scrubber Stack) No. 1 Lime Slaker Pre

- 1972/1997

E

- E5, B (Lime Slaker Scrubber Stack) No. 2 Lime Slaker

Permit N o. 96 -043- C ( PSD) r equired t hat t he s tacks be e xtended or control devices added to reduce ambient PM impacts. This has been achieved.

EUG E6

– Causticizing System

Emission Point EU Name/Model Construction Date

E6 (2 Stacks) No. 1a Causticizer Pre

- 1972/2001

No. 2 Causticizer

No. 1b Causticizer

No. 3 Causticizer

EUG E7a

– Lime Kiln No. 1

Emission Poi nt EU Name/Model Construction Date E7,A (Lime Kiln)

Stack Lime Kiln No. 1 Pre

- 1972/1998

No. 1 Lime Bin

No. 2 Lime Bin

No. 3 Lime Bin

The Lime Kiln is subject to 40 CFR Part 63, Subpart S as a back

- up air pollution control device. Subpart M M w as pr omulgated on J anuary 12, 2001, t o r egulate l ime ki lns di rectly, a nd t hePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 24

compliance date was March 13, 2004. Once the new CFB is built, the lime kiln will no longer be

used as a back -up device.

EUG E7b

– Lime Kiln No. 2

Emission Point EU Name/Model C onstruction Date E7b,B (Lime Kiln)

Stack Lime Kiln No. 2 2005 (planned)

No. 4 Lime Bin

No. 5 Lime Bin

EUG E8

– Tall Oil Plant

Emission Point EU Name/Model Construction Date

Main Stack Tall Oil Plant Pre

- 1972/1989

A scrubber was added to this unit in 1989. T hat addition reduced VOC emissions, therefore it was not defined as a “ modification” r equiring pe rmitting. T his E UG i s a H VLC s ystem, f or which no standards are specified for existing equipment under the Pulp & Paper Industry MACT.

EUG E9

– Organic Liquid Storage Vessels

Emission

Point EU Name/Model Capacity,

Gallons Construction

Date

164100010 No. 1 Weak Black Liquor Tank 793,090 1995

164100110 No. 2 Weak Black Liquor Tank 793,090 1995

164100210 Boilout Tank 426,263 1991

164101310 51 % Black Liquor Tank 793,090 1994

164101710 No. 2 Fuel Oil Storage Tank 1,523,381 1990

164101810 Neutral

- Sulfite Semi

- Chemical (NSSC) Weak Liquor Tank 842,428 1990

164102511 68% Black Liquor Storage Tank 603,400 1995

E-E2,L “Super Bowl” Temporary Storage Area 10,000,000 1990

164110110 Foul Condensate Storage Tank 350,000 2000

174102010 No. 2 Green Liquor Storage Tank >20,000 1997

-- Spent Liquor Mix Tank 13,736 1997 (to be decommissioned)

40 CFR Part 63, Subpart S affects only “new” liquor storage t anks; the black liquor storage tanks in this EUG are considered “existing” by the definitions in Subpart S.

EUG E10

– Small Volatile Organic Liquids Storage Tanks

Emission

Point EU Name/Model Capacity,

Gallons Construction

Date

GAS

- 01 Gasoline Fuel Tank 1,950 1987

034120510 Turpentine Storage Tank 28,000 1971

Main Stack Tall Oil Tank 153,000 1970PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 25

EUG F1

– Woodyard

Emission Point EU Name/Model Construction Date F1 (fugitive emissions) Woodyard Pre

- 1972

EUG F1a

– Coal Material Handling (Bark Boiler )

Emission Point EU Name/Model Construction Date

--- Coal Material Handling (Bark Boiler) 2004

EUG F1b

– Coal Material Handling (New)

Emission Point EU Name/Model Construction Date

F1b Coal Material Handling (New) 2005 (planned)

EUG F2

– Plant Traf fic Road Emissions

Emission Point EU Name/Model Construction Date F2 (fugitive emissions) Plant Traffic on Roads Pre

- 1972

EUG F3a

– Evaporator Sewer Sump

Emission Point EU Name/Model Construction Date F3a,A Evaporator Sewer Sump Pre -1972

The evapor ator sump is part of the wastewater collection system. As such, it does not meet the definitions i n the P ulp & P aper M ACT f or ei ther “evaporator system” or “process wastewater treatment system.”

EUG F3b

– Wastewater Treatment System

Emission Point EU Na me/Model Construction Date

F3b (fugitive

emissions) Landfill Collection Pond 1991 Chip Pile Stormwater Runoff Collection Pond 1991

Process Sewer Pre

- 1972 Primary Effluent Clarifier Pre

- 1972

No. 1 Aerated Stabilization Basin Pre

- 1972

No. 2 Ae rated Stabilization Basin Pre

- 1972 No. 1 Liquor Pond 1983 No. 2 Liquor Pond 1983 No. 3 Liquor Pond 1983 No. 6 Liquor Pond 1983
F3,H Sludge Press 1991
F3,I Sludge Press 1991PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 26

EUG F4a

– NCG Collection and Thermal Oxidation System

– LVHC

EUG F4b

– NCG Collection and Thermal Oxidation System

– HVLC

Emission Point EU Name/Model Construction Date

E3c (Recovery Furnace), or D5 (CFB Boiler),

or F4 (NCG thermal oxidizer) Thermal Oxidation System LVHC Collection System HVLC Collection System

1989/

2000 No. 1 Digester System No. 2 Digester System No. 3 Digester System Turpentine Recovery System Spent Liquor Concentration Steam Stripper System Atmosphere No. 1 Brownstock Washing Area No. 2 Brownstock Washing Area

The t her mal oxidizer w ill be de commissioned from nor mal ope ration, but it w ill be ke pt available as a backup control device.

EUG F5

– Landfill Operations

Emission Point EU Name/Model Construction Date F5 (fugitive emissions) Landfill Pre

- 1972

EUG F6

– Diesel Stormwater Pump

Emission Point EU Name/Model Construction Date

F6 166 HP Diesel Engine Driving a Water Pump 1995

EUG F7

– Wood Chip Screening and Conditioning Unit

– No. 3 Line

Emission Point EU Name/Model Construction Date

F7 Chip Screen 1996

ADS

- 1 Air Density Separator 1996

F7 Chip Conditioner 1996 There is a gap in the sequence for F8, a unit which has been retired.

EUG F9

– Wood Chip Screening and Conditioning Unit

– No. 1 Line

Emission Point EU Name/Model Construction Date

F9 Chip Screen 1 998

ADS

- 2 Air Density Separator 1998

F9 Chip Conditioner 1998PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 27

EUG F10

– Steam Stripper System

Emission Point EU Name/Model Construction Date E3c (Recovery Furnace), or D5 (CFB Boiler),

F4 (NCG Thermal Oxidizer) Steam Stripper 1999

Foul Condensa te Storage Tank

EUG F11

– Miscellaneous Insignificant Activates

Emission Point EU Name/Model Construction Date

F11 -1 100 KW Caterpillar D100PI Emergency

Generator 1971

F11

- 2 150 KW Caterpillar D336 Emergency Generator 1990

F11

- 3 700 KW Pipeline B asin Emergency Generator 2003

F11

- 4 25 KW Pipeline Valve House 2003

EUG F12

– Wood Chip Operation

Emission Point EU Name/Model Construction Date

F12 Debarking Drum 2003 Chipper Log Truck Road Fugitives

On

- Site Vehicles*

*The increase in on

- site vehicle emissions is conservatively set at 10% of the total emissions from log truck road fugitives.

The Valliant Mill is currently constructing a wood chipping operation consisting of unloading and conveying equipment, a debarker, and a chipper.

EUG F13

– Petcoke Handling System No. 1

EUG F14

– Petcoke Handling System No. 2

Emission Point EU Name/Model Construction Date

F13 Petcoke Handling System No. 1 2004 or later Petcoke Handling System No. 2

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100

- 8, Appendix I, are listed below. Recordkeeping for activities indicated with an asterisk, “*”, is listed in the Specific Conditions.

- * Stationary reciprocat ing engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which a re e ither us ed e xclusively f or e mergency pow er g enerations or f or peaking power service not exceeding 500 hour s pe r y ear. T he f acility i ncludes t wo di esel -powered

emergency ge nerators totaling 250 kW (310 HP) located at the facility.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 28

- Space heaters, boilers, process he aters, and emergency f lares l ess t han or equa l t o 5 MMBTUH heat input (commercial natural gas). None listed but may be used in the future.

- * E missions f rom f ue l storage/dispensing e quipment ope rated s olely f or f acility ow ned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30 -day period. The facility includes a vehicle gasoline fueling tank (GAS -01).

- Gasoline and aircraft f uel ha ndling f acilities, e quipment, a nd s torage t anks e xcept t hose subject to New Source Performance Standards and standards in OAC 252:100 -37- 15, 39 -30, 39-41, and 39-48. The facility includes a diesel fuel dispensing operation.

- * Emissions from storage tanks constructed with a capacity less than 39,894 g allons which store VOC with a va por pr essure l ess t han 1.5 ps ia a t m aximum s torage t emperature. T he facility includes a 28,000-gallon turpentine storage tank (EUG 10).

- Site restoration and/or bioremediation activities of <5 years ex pected duration. None listed but may be conducted in the future.

- Hydrocarbon- contaminated soil aeration pads utilized for soils excavated at the facility only. None listed but may be conducted in the future.

- * Non

- commercial wa ter washing operations and drum crushing operations (less than 2,250 barrels/year) of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material. The facility includes a drum reclamation operation.

- Hazardo us waste and hazardous materials drum staging areas. The facility includes a waste

accumulation area.

- Sanitary s ewage c ollection and treatment f acilities ot her than incinerators and Publicly Owned Treatment Works (POTW). Stacks or vents for sanitary sewe r plumbing traps are also included (i.e., lift station).

- Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation. The facility operates a non -hazardous landfill (EUG F5).

- Exhaust s ystems f or che mi cal, pa int, a nd/or s olvent s torage r ooms or c abinets, including hazardous w aste s atellite ( accumulation) ar eas. The facility includes additional chemical storage for maintenance purposes.

- Hand wiping and spraying of solvents from containers with less tha n 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. These operations are conducted as part of routine maintenance.

- * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant. The app lication listed a tot al of 241 insignificant activities. The ins ignificant a ctivitiesPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 29

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

site.

SECTION VI. EMISSIONS

Valliant Mill has examined aspects of all major production areas at the plant to determine the maximum material process rates in order to calculate emission rates. Two distinct process rates for each production area or emissions unit have been determined:

**•** Maximum Short- Term Process Rate

**•** Maximum Sustainable Process Rate

The maximum short

- term process rate is the maximum production rate achievable in one hour. The maximum sustainable process rate is the annual average of the estimated production rate at which a source c an ope rate w ithin i ts physical a nd ope rational de sign. I n g eneral, s hort

- term (less than or equal to daily averaging periods) emissions are based on t he maximum short

- term process r ates a nd l ong

- term (greater than daily) average em issions are based on the m aximum sustainable process rates.

The Valliant Mill ha s exa mined various sour ces t o determine appr opriate em ission factors, including
stack tests, mass balances, U.S. EPA A P

- 42, N CASI t echnical bul letins, v endor da ta, a nd r egulatory limits. In all cases, engineering judgment is applied to determine the most suitable emission factor for a particular source. For most sources and pollutants, the selected “base emission factor” is then multiplied by a “safety factor” to obtain an “adjusted emission factor.” A safety factor is applie d to account for

short- term fluctuations in emissions or anomalous stack test conditions that may have affected a given set of testing results. The adjusted emission factor can then be multiplied by a proc ess rate to calculate an

emission rate. It should be noted, however, that not all emission factors incorporate a safety factor.

When a safety factor is employed, the following methodology is used to determine the factor. First, the sample st andard deviation for a set of t esting da ta i s cal culated. T he percentage t hat r epresents one standard deviation divided by the base factor is then calculated. If one standard deviation represents less than a 20% cushion over the highest measured testing da tum, t hen a de fault 20% s afety f actor i s assigned. I f one standard deviation represents greater t han a 20% cus hion over t he hi ghest measured testing datum, then the calculated percentage is used as the safety factor. In cases where a safety factor is employed, but a standard deviation is not calculated, a defau lt factor of 20% is assigned. The Valliant Mill uses this minimum safety factor of 20%, based on the principle that permit limits must account for

short- term fluctuations in actual emission rates.

The application has requested that all emission factors be kept confidential since they were the product of a lengthy and expensive research project.PERMIT MEMORANDUM 97 -057- TV 30

PROJECT CRITERIA POLLUTANT EMISSIONS SUMMARY AFTER THE MODIFICATIONS
Discharge

Point Operation PM 10 CO SO 2 NOx VOC TRS Lead H 2 SO 4

lb/hr TPY lb/hr TPY lb/hr T PY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

A4

- A6 No. 1,2,3 OCC Plant Fugitives -- -- -- -- -- -- -- -- 9.28 36.89

-- -- -- -- -- --

A8 OCC Lightweight Rejects Baghouse 0.43 1.90

-- -- -- -- -- -- -- -- -- -- -- -- -- --

B1 No. 1 Brownstock

Was hing Area -- -- -- -- -- -- -- -- 30.0 122.64 8.03 32.81

-- -- -- --

B2 No. 2 Brownstock Washing Area -- -- -- -- -- -- -- -- 21.67 87.60 5.80 23.43

-- -- -- --

C1

- C3 No. 1 Paper Machine

-- -- -- -- -- -- -- -- 115.05 419.93

-- -- -- -- -- -- C4

- C6 No. 2 Paper Machine

-- -- -- -- -- -- -- -- 54.33 202.97

-- -- -- -- -- -- C7

- C9 No. 3 Paper Machine

-- -- -- -- -- -- -- -- 62.32 209.97

-- -- -- -- -- --

D2 Power Boiler (Supplemental Only) B 171.0 299.26 92.99 407.29 1,486.8 933.18 623.7 622.07 6.14 9.36

-- -- 0.02 0.10 23.25 35.43

D5 CFB Boiler 47.29 207.12 378.30 1,657.0 378.3 952.75 283.73 828.48 9.46 41.42

-- -- 0.19 0.83 4.05 10.21

E2b Evaporator Sump Vent

-- -- -- -- -- -- -- -- 18.81 74.40 15.51 61.35

-- -- E3c Recovery Furnace 46.34 179.54 1,3 51.7 1,047.4 507.85 523.67 353.37 912.69 30.90 119.70 5.79 22.44 0.01 0.06 3.86 14.96

E3d Spent Liquor Mix Tank

-- -- -- -- -- -- -- -- 0.65 2.52 3.58 13.85

-- -- -- -- E5 Lime Slakers No. 1 1.62 4.85

-- -- -- -- -- -- 8.15 24.36 0.06 0.17

-- -- -- -- E 5 Lime Slakers No. 2 1.62 4.85

-- -- -- -- -- -- 8.15 24.36 0.06 0.17

-- -- -- -- E6 Causticizer Vents (combined) -- -- -- -- -- -- -- -- 15.12 45.18 0.11 0.33

-- -- -- --PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 31

PROJECT CRITERIA POLLUTANT EMISSIONS SUMMARY AFTER THE MODIFICATIONS

– CONTINUED
Discharge

Point Operation PM 10 CO SO 2 NOx VOC TRS Lead H 2 SO 4

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

E7b Lime Kiln 3.18 13.91 24.26 106.25 74.04 72.87 79.76 203.59 4.13 18.08 1.52 6.68 0.07 0.32 1.13 1.12

E8 Ta ll Oil Scrubber

-- -- -- -- -- -- -- -- 43.2 189.22 5.60 24.51

-- -- -- -- F1 Woodyard 2.70 2.28

-- -- -- -- -- -- 0.33 1.44

-- -- -- -- -- -- F1 Coal Material Storage 0.44 0.53

-- -- -- -- -- -- -- -- -- -- -- -- -- -- F2 Plant Trucks 4.63 25.91

-- -- -- -- -- -- -- -- -- -- -- -- -- -- F2 Landfill Trucks 1.08 0.50

-- -- -- -- -- -- -- -- -- -- -- -- -- -- F3a Wastewater Treatment System -- -- -- -- -- -- -- -- 111.71 441.82 27.30 119.58

-- -- -- --

F5 Landfill Operations 6.70 0.10

-- -- -- -- -- -- -- -- -- -- -- -- -- -- F5 Unloading Dumps 0.88 1.85

-- -- -- -- -- -- -- -- -- -- -- -- -- -- F7/F9 Chip Thickness Screening and Conditioning System 1.23 4.85

-- -- -- -- -- -- 3.90 15.41

-- -- -- -- -- --

F14 Petcoke Silo Bin Vent

No. 2 0.10 0.45

-- - - -- -- -- -- -- -- -- -- -- -- -- --

FW Plant

- Wide Fugitives C

-- -- -- -- -- -- -- -- 55.03 207.39 7.17 29.79

-- -- -- -- D2, D5,

E3c CFB Boiler, Recovery Furnace, and Power

Boiler Annual

Summation D 386.7 2,704 1,476 1,741 161.1 22.44 0.89 25. 17

TOTALS 289.2 448.6 1,847 2,811 2,44 7 1,549 134 1 1,945 608.3 2,285 80.53 335.1 0.29 1.21 32.29 26.29

A. The CFB Boiler, the new Recovery Furnace, and the new Lime Kiln will each be equipped with a particulate matter control devic e (e.g., baghouse, electrostatic precipitator) capable of meeting applicable MACT requirements.

B. The emission rates presented for the Power Boiler are for the supplemental steam production scenario only. Emission rates of the backup steam production scenario are tracked part of the summation of the allowable emission rates of the CFB Boiler and the Recovery Furnace.

C. Plant

- Wide VOC and TRS fugitive emissions are assumed to be 10% of primary, non

- combustion source emissions.

D. On an annual basis for any given pollutant, Weyerhaeuser will ensure that the combined annual emissions of the Power Boiler in backup steam production only, the CFB Boiler, and the Recovery Furnace do not exceed the summation of the allowable annual emission rates of the CFB Boiler and the Recovery

FurnacePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 32

The post

- project emissions of Subchapter 41 compounds for each primary source at the Valliant Mill were determined using emission factors taken from National Council of the Paper Industry for Air and Stream Improvement (NCASI) Technical Bulletins, United States Environmental Protection Agency (U.S. EPA) AP

- 42 reference documents, or mill data

. 2 The following sections discuss each data source.

The following NCASI reports were used to determine the post- project emissions for the Valliant Mill:

**•** Tech nical Bulletin 650

– dated June 7, 1993

**•** Technical Bulletin 676

– dated September 9, 1994

**•** Technical Bulletin 677

– dated September 23, 1994

**•** Technical Bulletin 678

– dated October 5, 1994

**•** Technical Bulletin 680

– dated October 24, 1994

**•** Technical Bulletin 681

– dat ed October 31, 1994

**•** Technical Bulletin 701

– dated October 20, 1995

**•** NCASI Handbook of Chemical

- Specific Information for SARA 313 Form R Reporting

The U.S. EPA AP

- 42 emission factors used in this report are located in Chapter 1.1 (September 1998), Chapter 1.3(September 1998), Chapter 1.4 (July 1998), Chapter 1.6 (September 2003), and Chapter 3.3 (October 1996) of the U.S. EPA AP

- 42 reference documents.

M ILL D ATA Since every pulp and paper product manufacturing facility is unique, the NCASI bulletins and

U.S . EPA AP

- 42 reference doc uments do not al ways cont ain sufficient da ta t o accurately estimate emissions of a ll S ubchapter 41 c ompound e missions. W hen a ppropriate, e ngineering judgment was used to apply mill data, which may or may not be specific to the Vall iant Mill, to estimate pos t

- project e missions of S ubchapter 41 c ompounds. F or example, NCASI technical bulletin emission factors for acrolein were reviewed and adjusted for this analysis. The factors provided in NCASI Technical Bulletin 681 for acrolein we re developed based on stack test data from mills w ithout de noting if a dditives c ontaining a crolein (a c ommon slimacide) w as us ed. Further, the testing program could not verify us ing G C/MS t hat a crolein w as pr esent i n ve nt gases. Since the Valliant Mill doe s not use acrolein

- based slimacides, it would be inaccurate to estimate acrolein emissions based on this data. Using these data sources, the most conservative (i.e., highest) e mission factor w as s elected to estimate pos t

- project f acility

- wide e missions,

ex cept where engineering judgment was used to select an alternative emission factor. Emissions of HAPs from each unit exempt under OAC 252:100-41-43(a)(3) was excluded.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 33

TOXIC AIR POLLUTANT EMISSIONS SUBJECT TO SUBCHAPTER 41

Toxic CAS

Number Cate gory Emissions De Minimis > De

Minimis lb/hr TPY lb/hr TPY 1,1,1

- Trichloroethane 71556 C 6.15E

- 01 2.22E+00 5.6 6.0 No
1,1,2

- Trichloroethane 79005 A 7.26E

- 01 2.62E+00 0.57 0.6 Yes
1,2,4

- Trichlorobenzene 120821 C 3.66E+00 1.32E+01 5.6 6.0 Yes
1,2

- Di bromoethene 540498 A 1.04E

- 01 4.56E

- 01 0.57 0.6 No
1,2

- Dichloroethane 107062 A 1.14E+00 4.12E+00 0.57 0.6 Yes
1,2

- Dichloroethylene 540590 C 4.34E+00 1.56E+01 5.6 6.0 Yes
1,2

- Dichloropropane 78875 A 6.24E

- 02 2.73E

- 01 0.57 0.6 No
1,3

- Butadiene 106990 A 4 .54E

- 05 1.99E

- 04 0.57 0.6 No
2,3,7,8

- Tetrachlorodibenzo

- p

dioxin 1746016 A

0.00E+00 0.00E+00 0.57 0.6 No

2,4,6

- Trichlorophenol 88062 A 0.00E+00 0.00E+00 0.57 0.6 No
2,4

- Dinitrophenol 51285 A 0.00E+00 0.00E+00 0.57 0.6 No

2

- Chloronaphthalene 91587 C 4.5 4E

- 06 1.99E

- 05 5.6 6.0 No

2

- Chlorophenol 26982036 B 4.54E

- 05 1.99E

- 04 1.1 1.2 No

2

- Methylnaphthalene 91576 A 3.03E

- 04 1.33E

- 03 0.57 0.6 No

2

- Nitrophenol 88755 B 4.54E

- 04 1.99E

- 03 1.1 1.2 No

4

- Nitrophenol 88755 B 0.00E+00 0.00E+00 1.1 1.2 No

5

- Methyl c hrysene A 1.49E

- 06 6.51E

- 06 0.57 0.6 No Acenaphthene 83329 A 1.29E

- 04 5.64E

- 04 0.57 0.6 No Acenaphthylene 208968 A 1.46E

- 05 6.40E

- 05 0.57 0.6 No Acetaldehyde 75070 B 1.77E+01 6.51E+01 1.1 1.2 Yes

Acetone 67641 NS 2.43E+01 8.84E+01

-- -- No Acetopheno ne 98862 C 0.00E+00 0.00E+00 5.6 6.0 No

Acrolein 107028 A 1.19E

- 02 4.73E

- 02 0.57 0.6 No Acrylamide 79061 A 6.68E

- 03 2.40E

- 02 0.57 0.6 No alpha

- Pinene 80568 C 1.20E+00 2.43E

- 01 5.6 6.0 No alpha

- Terpineol 8006391 C 8.89E

- 03 3.89E

- 02 5.6 6.0 No

Ammonia 7 664417 C 1.27E+01 5.26E+01 5.6 6.0 Yes

Anthracene 1201217 A 1.56E

- 05 6.85E

- 05 0.57 0.6 No Antimony 7440360 B 4.14E

- 02 1.81E

- 01 1.1 1.2 No

Arsenic 7440382 A 1.03E

- 01 4.50E

- 01 0.57 0.6 No

Barium 7440393 B 6.28E

- 01 2.73E+00 1.1 1.2 Yes Benzaldehyde 10052 7 B 5.70E

- 01 1.22E

- 01 1.1 1.2 No

Benzene 71432 A 1.77E

- 01 6.69E

- 01 0.57 0.6 Yes Benzo(a)anthracene 56553 A 9.42E

- 05 4.13E

- 04 0.57 0.6 No Benzo(a)pyrene 50328 A 8.94E

- 06 3.91E

- 05 0.57 0.6 No Benzo(b)fluoranthene 205992 A 3.34E

- 05 1.46E

- 04 0.57 0.6 No

B enzo(e)Pyrene 192972 A 0.00E+00 0.00E+00 0.57 0.6 No Benzo(g,h,i)perylene 191242 B 6.35E

- 05 2.78E

- 04 1.1 1.2 No Benzo(j)fluoranthene 205992 A 0.00E+00 0.00E+00 0.57 0.6 No Benzo(k)fluoranthene 207089 A 3.35E

- 05 1.47E

- 04 0.57 0.6 No

Benzoic Acid 65850 C 7.00E

- 02 3.07E

- 01 5.6 6.0 No Benzyl Chloride 100447 B 0.00E+00 0.00E+00 1.1 1.2 NoPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 34

FACILITY WIDE TOXIC AIR POLLUTANT EMISSIONS

– CONTINUED

Toxic CAS

Number Category Emissions De Minimis > De

Minimis lb/hr TPY lb/hr TPY Beryllium 7440417 A 3.9 6E

- 03 1.74E

- 02 0.57 0.6 No Biphenyl 92524 C 0.00E+00 0.00E+00 5.6 6.0 No bis(2

- ethylhexyl)Phthalate 117817 A 0.00E+00 0.00E+00 0.57 0.6 No

Bromoform 75252 C 0.00E+00 0.00E+00 5.6 6.0 No

Bromomethane 74839 A 0.00E+00 0.00E+00 0.57 0.6 No

Cadmium 744043 9 A 1.90E

- 01 8.33E

- 01 0.57 0.6 Yes

Carbazole 86748 B 3.40E

- 03 1.49E

- 02 1.1 1.2 No

Carbon disulfide 75150 B 4.47E

- 02 1.92E

- 01 1.1 1.2 No

Carbon Tetrachloride 56235 A 5.39E+00 1.94E+01 0.57 0.6 Yes

Chlorine 7782505 A 0.00E+00 0.00E+00 0.57 0.6 No

Chloro benzene 108907 C 2.60E

- 01 9.37E

- 01 5.6 0.6 No

Chloroform 67663 A 4.98E+00 1.86E+01 0.57 0.6 Yes

Chloromethane 74873 A 0.00E+00 0.00E+00 0.57 0.6 No

Chromium 7440473 A 1.16E

- 01 5.06E

- 01 0.57 0.6 No

Chromium+6 7738945 A 1.49E

- 03 6.52E

- 03 0.57 0.6 No

Chr ysene 218019 A 1.66E

- 05 7.27E

- 05 0.57 0.6 No

Cobalt 7440484 A 1.09E

- 01 4.77E

- 01 0.57 0.6 No Copper 7440508 B 1.88E

- 01 4.85E

- 01 1.1 1.2 No Crotonaldehyde 4170303 A 1.87E

- 02 8.20E

- 02 0.57 0.6 No

Cumene 98828 C 1.29E+00 5.64E+00 5.6 6.0 No Cyanide 57125 A 0.00E+00 0.00E+00 0.57 0.6 No Decachlorobiphenyl 2051243 A 5.11E

- 07 2.24E

- 06 0.57 0.6 No Dibenzo[a,h]anthracene 53703 A 7.00E

- 05 3.07E

- 04 0.57 0.6 No Dichlorobiphenyl 2050682 A 1.40E

- 06 6.13E

- 06 0.57 0.6 No Dimethyl sulfate 77781 A 0.00E+00 0.00E+00 0.57 0.6 No

Di

- n

- Butyl phthalate 84742 C 0.00E+00 0.00E+00 5.6 6.0 No

Ethanol 64175 B 2.29E+00 9.65E+00 1.1 1.2 Yes Ethyl chloride 75003 B 0.00E+00 0.00E+00 1.1 1.2 No Ethylbenzene 100414 C 3.37E

- 02 1.47E

- 01 5.6 6.0 No Ethylene dibromide 106934 A 0.00 E+00 0.00E+00 0.57 0.6 No Ethylene dichloride 107062 A 0.00E+00 0.00E+00 0.57 0.6 No Ethylene Glycol 107211 C 3.02E

- 01 1.09E+00 5.6 6.0 No

Fluoranthene 206440 C 8.83E

- 06 3.87E

- 05 5.6 6.0 No

Fluorene 86737 A 6.29E

- 05 2.76E

- 04 0.57 0.6 No Formaldehyde 5 0000 A 8.08E+00 2.95E+01 0.57 0.6 Yes Heptachlorobiphenyl 28655712 A 1.25E

- 07 5.47E

- 07 0.57 0.6 No Heptachlorodibenzo

- p

- dioxins 35822469 A 3.78E

- 06 1.66E

- 05 0.57 0.6 No Heptachlorodibenzo

- p

- furans 67562394 A 4.54E

- 07 1.99E

- 06 0.57 0.6 No Hexachlorobiph enyl 26601

- 64

- 9 A 1.04E

- 06 4.56E

- 06 0.57 0.6 No

Hexachlorodibenzo

- p

- dioxins 39227286 B 3.03E

- 03 1.33E

- 02 1.1 1.2 No

Hexachlorodibenzo

- p

- furans 70648269 A 5.30E

- 07 2.32E

- 06 0.57 0.6 No

Hexanal 66251 C 1.32E

- 02 5.80E

- 02 5.6 6.0 No

Hexane 110543 C 0.00E+0 0 0.00E+00 5.6 6.0 NoPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 35

TOXIC AIR POLLUTANT EMISSIONS

– CONTINUED

Toxic CAS

Number Category Emissions De Minimis <De

Minimis

lb/hr TPY lb/hr TPY Hydrogen chloride 7647010 C 0.00E+00 0.00E+00 5.6 6.0 No Indeno(1,2,3,c,d)pyrene 193395 A 5.71E

- 0 5 2.50E

- 04 0.57 0.6 No

Iron 7439896 C 1.87E+00 8.20E+00 5.6 6.0 Yes Isobutyraldehyde 78842 C 2.27E

- 02 9.94E

- 02 5.6 6.0 No Isophorone 78591 C 0.00E+00 0.00E+00 5.6 6.0 No Isopropanol 67630 C 3.39E+00 1.43E+01 5.6 6.0 Yes

Lead 7439921 NS 1.75E

- 01 7.65E

- 01

-- -- No Magnesium 7439954 C 7.43E

- 01 3.25E+00 5.6 6.0 No Manganese 7439965 C 6.67E

- 02 2.92E

- 01 5.6 6.0 No Mercury 7439976 A 5.54E

- 02 2.43E

- 01 0.57 0.6 No

Methane 74828 NS 3.97E+01 1.74E+02

-- -- No

Methanol 67561 C 7.55E+02 2.81E+03 5.6 6.0 Yes

M ethyl bromide 74839 A 0.00E+00 0.00E+00 0.57 0.6 No Methyl chloride 74873 A 0.00E+00 0.00E+00 0.57 0.6 No Methyl ethyl ketone 78933 C 1.02E+01 3.93E+01 5.6 6.0 Yes Methyl hydrazine 60344 A 0.00E+00 0.00E+00 0.57 0.6 No Methyl isobutyl ketone 108101 C 4 .26E+00 1.68E+01 5.6 6.0 Yes Methyl methacrylate 80626 B 0.00E+00 0.00E+00 1.1 1.2 No Methyl tertiary butyl ether 1634044 B 0.00E+00 0.00E+00 1.1 1.2 No Methylene chloride 75092 A 1.87E+00 6.86E+00 0.57 0.6 Yes Molybdenum 7439987 C 5.00E

- 03 2.19E

- 02 5. 6 6.0 No Monochlorobiphenyl

-- A 4.16E

- 07 1.82E

- 06 0.57 0.6 No

m

- p

- Xylene 108383 C 2.89E

- 01 1.07E+00 5.6 6.0 No Naphthalene 91203 B 1.11E

- 02 4.84E

- 02 1.1 1.2 No

n

- Hexane 110543 C 7.28E

- 01 3.05E+00 5.6 6.0 No

Nickel 7440020 A 2.10E+00 9.19E+00 0.57 0.6 Yes

Octachlorodibenzo

- p

- dioxins 3268879 A 1.25E

- 04 5.47E

- 04 0.57 0.6 No

Octachlorodibenzo

- p

- furans 39001020 A 1.66E

- 07 7.29E

- 07 0.57 0.6 No

o

- Tolualdehyde 529204 A 1.36E

- 02 5.97E

- 02 0.57 0.6 No

o

- Xylene 95476 C 2.02E+00 7.95E+00 5.6 6.0 Yes

PAHs vari es A 4.78E

- 02 2.09E

- 01 0.57 0.6 No

p

- Cymene 99876 C 6.32E

- 01 1.28E

- 01 5.6 6.0 No Pentachlorobiphenyl 25429

- 29

- 2 A 2.27E

- 06 9.94E

- 06 0.57 0.6 No

Pentachlorodibenzo

- p

- dioxins 36088

- 22

- 9 A 2.84E

- 06 1.24E

- 05 0.57 0.6 No

Pentachlorodibenzo

- p

- furans 67517480 A 7.94E

- 07 3.48E

- 06 0.57 0.6 No Pentachlorophenol 87865 A 0.00E+00 0.00E+00 0.57 0.6 No Perylene 198550 B 9.84E

- 07 4.31E

- 06 1.1 1.2 No

Phenanthrene 85018 A 1.36E

- 04 5.94E

- 04 0.57 0.6 No

Phenol 108952 B 5.45E

- 01 2.15E+00 1.1 1.2 Yes Phosphorus 7723140 A 5.68E

- 02 2.49E

- 01 0.57 0.6 No

Potassium 7440097

-- 7.38E+01 3.23E+02

-- -- No Propanal 123386 A 6.05E

- 03 2.65E

- 02 0.57 0.6 NoPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 36

TOXIC AIR POLLUTANT EMISSIONS

– CONTINUED

Toxic CAS Number Category Emissions De Minimis > De

Minimis lb/hr TPY lb/hr TPY Propionaldehyde 123386 C 0.00E+00 0.00E+00 5.6 6.0 No Propylene 115071 NS 2.99E

- 03 1.31E

- 02

-- -- No

p

- Tolualdehyde 104870 A 2.08E

- 02 9.11E

- 02 0.57 0.6 No Pyrene 129000 A 3.53E

- 05 1.55E

- 04 0.57 0.6 No

Selenium 7782492 C 3.51E

- 02 1.54E

- 01 5. 6 6.0 No

Silver 7440224 B 3.22E+00 1.41E+01 1.1 1.2 Yes

Sodium 7440235

-- 6.81E

- 01 2.98E+00

-- -- No

Strontium 7440246 C 1.89E

- 02 8.28E

- 02 5.6 6.0 No Styrene 100425 B 7.19E

- 01 2.62E+00 1.1 1.2 Yes

Sulfuric acid mist 7664939 A 3.36E+01 1.15E+02 0.57 0. 6 Yes Terpenes 68956569 B 9.19E+01 3.31E+02 1.1 1.2 Yes Tetrachlorobiphenyl 26914330 A 4.73E

- 06 2.07E

- 05 0.57 0.6 No

Tetrachlorodibenzo

- p

dioxins 1746016 A

0.00E+00 0.00E+00 0.57 0.6 No

Tetrachlorodibenzo

- p

furans 51207319 A

1.42E

- 06 6.21E

- 06 0.57 0.6 No

Tetrachloroethylene 127184 A 2.06E+00 7.41E+00 0.57 0.6 Yes

Tin 7440315 C 4.35E

- 02 1.91E

- 01 5.6 6.0 No

Titanium 7440326 B 3.78E

- 02 1.66E

- 01 1.1 1.2 No

Toluene 108883 C 2.44E

- 01 9.39E

- 01 5.6 6.0 No Trichlorobiphenyl

-- A 4.92E

- 06 2.15E

- 05 0.57 0.6 N o Trichloroethylene 79016 A 1.11E+00 4.01E+00 0.57 0.6 Yes

Trichlorofluoromethane 75694 C 7.76E

- 02 3.40E

- 01 5.6 6.0 No

Vanadium 7440622 A 5.92E

- 01 2.59E+00 0.57 0.6 Yes Vinyl Acetate 108054 C 0.00E+00 0.00E+00 5.6 6.0 No Vinyl Chloride 75014 A 1.03E

- 0 1 4.07E

- 01 0.57 0.6 No Xylenes 1330207 C 3.31E

- 04 1.45E

- 03 5.6 6.0 No

Yttrium 7440655 A 5.67E

- 04 2.49E

- 03 0.57 0.6 No

Zinc 7440666 C 1.29E+00 4.34E+00 5.6 6.0 No

Total HAP emissions: 1,125 lb/hr and 4,245 TPY

PSD Evaluation Methodology

A P SD net ti ng analysis is pe rformed i n t wo m ajor s teps: ( 1) e valuating t he pr oposed modification by i tself a nd, i f ne cessary, ( 2) c onducting e missions ne tting ove r the contemporaneous period.

1. Compare emissions increases associated with only the proposed modifica tion to the PSD

SER thresholds. Emissions increases associated with the proposed modification include increases at new and modified units, as w ell as “as sociated emissions i ncreases” at existing, unm odified uni ts. F or ne w, m odified, a nd a ffected uni ts, e missions i ncreases are determined by subtracting actual emission rates from the proposed potential emission rates for that unit. In accordance with federal [40 CFR 52.21(b)(21)(iii)] and state (OAC 252:100-8-31) regulations, two methods are available to c ompute past actual emissions:PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 37

**•** Average t he em issions from t he t wo years pr eceding the change or from a two

year period representative of normal operations, or,

**•** The D EQ m ay pr esume t hat s ource

- specific al lowable em issions f or a unit are equivalent to the “ actual emissions” of a unit.

If emissions increases from the proposed modification alone (without considering any decreases) are below all applicable PSD SERs, then the modification is not significant and is not required to undergo PSD review. I f emissio ns i ncreases from t he m odification alone are greater t han any SER, then the modification must undergo PSD netting to determine PSD applicability for that pollutant. The comparison is conducted on a pollutant -by- pollutant basis, so PSD netting may be requi red for some pollutants and not for others. Since the Valliant Mill qualifies as one of the 28 PSD source c ategories f or w hich t he 100 T PY m ajor s ource t hresholds a pplies, e missions increases from fugitive sources, such as roads, must also be included in the PSD netting analysis.

2. If t he m odification a lone i s s ignificant, c onduct P SD ne tting. The ne tting a nalysis is conducted in three steps: ( A) de fining t he c ontemporaneous pe riod, ( B) i dentifying contemporaneous em issions i ncreases and decreases, and (C) calculating t he ne t emissions change.

A. Define c ontemporaneous pe riod. In O klahoma, t he c ontemporaneous pe riod be gins with the date three years prior to the date construction commences on the proposed project and ends with the date the net emissions change from the modification occurs (i.e., when construction i s c omplete a nd nor mal ope rations ha ve be gun f or t he proposed/modified units).

B. Identify emissions increases/decreases. All creditable emissions increases and decreases

that occurred at th e plant site during the contemporaneous period are summed together. In general, these contemporaneous emissions increases and d ecreases ar e cal culated as t he difference between the average of the last two years of actual emissions prior to the change

and the allowable emissions after t he c hange f or e ach i ndividual e missions uni t. A ny

“double

- counted” emissions are removed.

C. Calculate ne t em issions i ncrease. The em issions cha nges as sociated with the ne w modification are added to the contemporaneous in creases and decreases to determine the net emissions change. In addition, emission rates previously relied upon i n the issuance of a PSD permit are removed from this summation. I f the net emissions change of any pollutant exceeds a corresponding PSD SER, then that pollutant is subject to PSD review.

PSD Evaluation for the Proposed Project

A P SD e valuation of t he pr oposed pr oject i s di scussed i n t he f ollowing s ubsections f or the following c riteria pol lutants: tot al pa rticulate ma tter ( PM), particulate m atter with an aerodynamic diameter less than 10 microns (PM 10 ), carbon monoxide (CO), sulfur dioxide (SO 2 ), oxides of nitrogen (NO

x ), VOC, TRS, lead (Pb), and SAM (H 2 SO 4 ).PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 38

Project Emissions Increase

For all ne w, m odified, a nd a ffected uni ts, e missions i nc reases ar e cal culated by subt racting t he pa st actual e mission r ate f rom t he pr oposed pot ential e mission r ate. Using this methodology, the project emissions increases attributable to the proposed project are presented for comparison to PSD SERs in

table be low.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 39

Total Emission Increases and Decreases Operation PM 10 CO SO 2 NOx VOC TRS Lead H 2 SO 4

* AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC

TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY
No. 1,2,3 OCC Plant Fugitives - - - - - - - - - - - - 17.26 36.89 19.63

- - - - - - - - -

OCC Lightweight Rejects Baghouse 080 1.90 1.10

- - - - - - - - - - - - - - - - - - - - -

No. 1 Brownstock

Washing Area - - - - - - - - - - - - 64.5 122.6 5 8.1 31.52 32.81 1.30

- - - - - -

No. 2 Brownstock

Washing Area - - - - - - - - - - - - 36.1 87.6 51.5 17.65 23.43 5.79

- - - - - -

No. 1 Paper Machine

- - - - - - - - - - - - 346.2 419.9 73.8

- - - - - - - - - No. 2 Paper Machine

- - - - - - - - - - - - 175.3 202.9 27.7

- - - - - - - - - No. 3 Paper Machine

- - - - - - - - - - - - 143.1 209.9 66.9

- - - - - - - - - Power Boiler (Supplemental Only) B 131.5 299.2 167.7 167.9 407.3 239.4 1,189 933.2

- 255 1,026 622

- 404 4.46 9.36 4.89

- - - 0.02 0.10 0.08 4.60 35.43 30.83

CFB Boiler 0.00 207.1 207.1 0.00 1,657 1,657 0.00 953 953 0.00 829 829 0.00 41.4 41.4

- - - 0.00 0.83 0.83 0.00 10.21 10.21 Evaporator Sump Vent

- - - - - - - - - - - - 35.55 74.40 38.85 29.20 61.35 32.15

- - - - - - Spent Liquor Mix Ta nk

- - - - - - - - - - - - 1.41 2.52 1.11 7.15 13.85 6.70

- - - - - - Recovery Furnace 0.00 179.5 179.5 0.0 1,047 1,047 0.00 524 524 0.00 913 913 0.00 119.7 119.7 0.00 22.44 22.44 0.00 0.06 0.06 0.0 14.96 14.96

Lime Slakers No. 1 4.29 4.85 0.56

- - - - - - - - - 7.94 24.36 16.42 0.10 0.17 0.07

- - - - - - Lime Slakers No. 2 4.29 4.85 0.56

- - - - - - - - - 7.94 24.36 16.42 0.10 0.17 0.07

- - - - - - Causticizer Vents (combined) - - - - - - - - - - - - 37.35 45.18 7.83 0.30 0.33 0.03

- - - - - -

Lime K iln 0.00 10.57 10.57 0.00 106 106 0.00 72.87 72.87 0.00 204 204 0.00 18.08 18.08 0.00 6.68 6.68 0.00 0.32 0.32 0.00 1.12 1.12

Tall Oil Scrubber

- - - - - - - - - - - - 38.95 189.2 150.3 6.05 24.51 18.46

- - - - - - Fiber Source Storage 1.30 1.87 0.57

- - - - - - - - - 0.80 1.19 0.39

- - - - - - - - -

Hog Fuel Storage 0.30 0.41 0.11

- - - - - - - - - 0.20 0.25 0.05

- - - - - - - - -

Coal Material Storage 0.00 0.53 0.53

- - - - - - - - - - - - - - - - - - - - -

Plant Trucks 10.19 17.85 7.66

- - - - - - - - - - - - - - - - - - - - -

* AE: actual emissions, Pt: Potential emissions, PC: Project changePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 40

Total Emission Increases and Decreases Continued
Operation PM 10 CO SO 2 NOx VOC TRS Lead H 2 SO 4

* AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC AE Pt PC

TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY TPY

Landfill Trucks 0.29 0.50 0.21

- - - - - - - - - - - - - - - - - - - -

Wastewater Treatment System - - - - - - - - - - - - 103.3 441.8 33 8.5 119.6 119.6 0.00

- - - - - -

Landfill Operations 0.04 0.10 0.06

- - - - - - - - - - - - - - - - - - - - - Unloading Dumps 1.00 1.85 0.85

- - - - - - - - - - - - - - - - - - - - -

Chip Thickness Screening and Conditioning System 2.78 4.85 2.07

- - - - - - - - - 8.84 15.41 6.58

- - - - - - - - -

Petcoke Silo Bin

Vent No. 2 0.00 0.45 0.45

- - - - - - - - - - - - - - - - - - - - -

Plant

- Wide Fugitives C - - - - - - - - - - - - 112.6 207.4 94.78 24.20 29.79 5.59

- - - - - -

Bark Boiler (Decommissioned) 104.3 0.00

- 104 2,952 0.00

- 2,952 101.1 0.00

- 101.1 700 0.00

- 700 71.3 0.00

- 71.3

- - 0.0 1.40 0.00

- 1.40 0.1 0.00

- 0.1

Recovery Furnace (old)

Decommissioned 278.8 0.00

- 278.8 1,631 0.00

- 1,631 1,111 0.00

- 1,111 614.1 0.00

- 614.1 42.27 0.00

- 42.27 147.6 0.00

- 147.6

- - - 9.54 0.00

- 9.54

Smelt Dissolving Tank

Decommissioned 231.7 0.00

- 231.7 119.3 0.00

- 119.3 6.35 0.00

- 6.35 13.15 0.00

- 13.15 65.19 0.00

- 65.19 12.7 0.00

- 12.7 0.01 0.00

- 0.01

- - -

NCG Thermal Oxidizer

Decommissioned from normal operati on 16.85 0.00

- 16.85 1.11 0.00

- 1.11 112.3 0.00

- 112 246.8 0.00

- 246.8 1.19 0.00

- 1.19 1.41 0.00

- 1.41

- - - - - -

Emission Increases 583.0 3,049 1,550 1,944 1,153 99.28 1.2 9 57.12

Emission Decreases

- 631.4

- 4,703

- 1,585

- 1,978

- 180

- 161.7

- 1.41

- 9.64 Total Project Changes

- 48.8

- 1,654

- 35

- 34 973

- 62.4

- 0.12 47.48 * AE: actual emissions, Pt: Potential emissions, PC: Project change
`PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 41

Emissions Increases from the Proposed Project

PM 10 CO SO 2 NO

x VOC (as carbon) TRS Pb SAM

TPY TPY TPY TPY TPY TPY TPY TPY Project Increase 583 3,049 1,550 1,944 1,153 99.28 1.29 57.12

PSD SER 15 100 40 40 40 10 0.6 7

Greater than SER? YES YES YES YE S YES YES YES YES

The emissions increases from the proposed project ex ceed the r espective P SD S ER f or t he following pollutants: P M

, PM 10 , CO

, SO 2 , NO

x , VOC

, TRS

, Pb , and SAM. Therefore, a PSD netting analysis is conducted for each of these pollutants.

Project Contemporaneous Period

The Valliant Mill is proposing to begin construction of the proposed project in October 2004, with pha sed c onstruction c ontinuing t hereafter f or a n e xtended pe riod of t ime. Since the proposed changes identified for this pr oject include all foreseeable changes to the Valliant Mill, Weyerhaeuser doe s not ant icipate any ot her cr editable em issions i ncreases or decreases which require consideration during the portion of t he c ontemporaneous w indow a fter t he commencement of operation. Thus, the only creditable emissions increases and decreases are for projects conducted in the time period of October 2001 through October 2004.

Creditable Emissions Increases And Decreases

During t he c ontemporaneous pe riod de fined a bove, the follow ing four projects with creditable

emission increases were conducted at the Valliant Mill:

**•** The installation of a wastewater pipeline and associated equipment under Permit No. 97

- 057- C.

**•** The installation of a wood chipping operation under Permit No. 97-057-C (M

- 2).

**•** The i nstallation of c oal ha ndling e quipment, a s di scussed i n a n a pplicability determination letter submitted to the DEQ on March 25, 2004.

**•** A lime ki ln burner modi fication project, as s ubmitted in a Tier I Construction Permit application on April 15, 2004.

In addition, Weyerhaeuser is proposing to decommission the following emissions sources as part of the proposed project: t he B ark B oiler, t he e xisting R ecovery F urnace, t he e xisting S pent Liquor Mix Tanks, the existing Smelt Dissolving Tanks, and the NCG Thermal Oxidizer (from normal ope ration). T herefore, t he pa st a ctual e mission rates from these units are considered

creditable em issions de creases. T he P ower B oiler w ill be de commissioned from normal operation, with continued operation as a backu p steam generating unit. Therefore, the past actual emission rates f or the P ower B oiler a re s ubtracted from the f uture pot ential emission rates to

determine the creditable increase or decrease.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 42

Project Net Emissions Change

In order to determine the tot al creditable emissions change, the project emissions increases are summed w ith t he c ontemporaneous i ncreases a nd de creases. Emission rates previously relied upon in t he i ssuance of a P SD pe rmit i s e xcluded f rom t his c alculation, s ince t hey a re not

consid ered creditable changes.

Net Emissions Change from the Proposed Project

PM 10 CO SO 2 NO

x VOC (as carbon) TRS Pb SAM

TPY TPY TPY TPY TPY TPY TPY TPY

Emissions Increase 583 3,049 1,550 1,944 1,153 99.28 1.29 57.12

Emissions Decrease

- 631.4

- 4,703

- 1, 585

- 1,978

- 180

- 161.7

- 1.41

- 9.64 Contemporaneous

Emissions 19.12 42.87 36.75 33.83 12.24 9.47 0.12 0.28 Net Emissions Change

- 29.28

- 1,611 1.75

- 0.17 985

- 52.95 0 47.76

PSD SER 15 100 40 40 40 10 0.6 7

Greater than SER? NO NO NO NO YES NO NO YES

Th e net emissions changes from the proposed project exceed the respective PSD SER for VOC

and SAM. Therefore, a PSD review f or e ach of t hese pol lutants i s pr esented. A s t he ne t emissions change for PM

, PM 10 , CO, SO 2 , NO

x , TRS , and Pb do not exceed their re spective PSD SERs, no further PSD review f or t hese pol lutants i s r equired. I t s hould be not ed t hat t he ne t emissions change is based on the Power Boiler in supplemental steam production. As discussed, annual emission rates from the Power Boiler during ba ckup steam production will be less than or equal to the combined associated decrease in annual emission rates of the CFB Boiler and the Recovery Furnace resulting from the experienced downtime.

SECTION VII. BEST AVAILABLE CONTROL TECHNOLOGY

Any major stationary source or major modification subject to federal PSD review must conduct an a nalysis t o e nsure t he i mplementation of B ACT. T he r equirement t o c onduct a BACT analysis can be found in the Clean Air Act itself, in the federal regulations implementin g the PSD program, in the regulations governing federal approval of state PSD programs, and in Oklahoma regulations. The State of Oklahoma defines BACT in OAC 252:100-8-1.1, as follows:

“...the control technology to be applied for a major source or modif ication is the best that is available as determined by the Director on a case -by- case basis taking into account energy, environmental, and economic impacts and other costs of alternate control systems.”

Although B ACT i s de termined by e valuating c ontrol te chnologies t o de termine w hich a re technically and economically feasible, BACT is a n emission limit, not the us e of a s pecific technology. A BACT analysis is required to assess the appropriate level of control for each new or physically modi fied emissions unit for each pollutant that exceeds an applicable PSD SER. As discussed in Section VI , the proposed project requires a BACT analysis for VOC and SAM.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 43

BACT A PPLICABILITY BY P OLLUTANT AND E MISSIONS U NIT
Unit Des cription VOC SAM

CFB Boiler Yes Yes

Lime Kiln Yes Yes Chemical Recovery Furnace Yes Yes Paper Machine Yes No

OCC Plants Yes No

In a memorandum dated December 1, 1987, U .S. E PA s tated i ts pr eference f or a “ top -down” analysis (U.S. EPA, Office of Air and Radiation, Memorandum from J.C. Potter to the Regional Administrators. Washington, D.C. December 1, 1987). After determining whether any NSPS is applicable, the first step in this approach is to determine for the emissions unit in question, the

most stringent control available for a s imilar or identical source or source category. If it can be shown that this level of control is technically or economically infeasible for the unit in question, the next most s tringent le vel of c ontrol is de termined and similarly e valuated. T his pr ocess continues until the BACT level under consideration cannot be eliminated by any substantial or unique t echnical, e nvironmental, or e conomic c oncerns. T he five basic steps of a top -down BACT r eview pr ocedure as i dentified by U.S. EPA i n t he M arch 15, 1990, D raft B ACT Guidelines are as follows (U.S. EPA, Draft BACT Guidelines. (Research Triangle Park, NC). March 15, 1990):

Step 1. Identify all control technologies Step 2. Eliminate technically infeasible options Step 3 . Rank remaining control technologies by control effectiveness Step 4. Evaluate most effective controls and document results Step 5. Select BACT

U.S. EPA has consistently interpreted statutory and regulatory BACT definitions as containing two c ore r equi rements t hat t he ag ency be lieves m ust be met by any BACT determination, regardless of whether it is conducted in a “top

- down” manner. F irst, the BACT analysis must include c onsideration of t he m ost s tringent a vailable c ontrol t echnologies ( i.e., those whi ch provide the “maximum degree of emissions reduction”). Second, any decision to require a lesser degree of emissions reduction must be j ustified by a n obj ective a nalysis of “ energy, environmental, a nd e conomic i mpacts ( U.S. E PA, O ffice of Air and Radiati on, M emorandum from J.C. Potter to the Regional Administrators. Washington, D.C. December 1, 1987)

.

Potentially applicable emission control technologies were identified by researching the U.S. EPA control technology database, technical literature, and control equipment vendor information and by us ing pr ocess know ledge a nd e ngineering e xperience. The Reasonably Available Control Technology (RACT)/BACT/Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC), a database made available to the public thr ough the U.S. EPA’s Office of Air Quality Planning and Standards (OAQPS) Technology Transfer Network (TTN), lists technologies that have been approved in PSD permits as BACT for numerous types of process units.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 44

CFB Boiler BACT Analysis

S UMMARY OF A NTICIPATED M AJOR CFB B OILER D ESIGN P ARAMETERS

Parameter Value Notes Heat Input (TSI) Steam Output (TSI) 2,350 psig, 1,000°F superheat Primary Fuel Coal Also will burn a variety of other

fuels

Pollutant Formation Processes

SAM i s f ormed i n the boiler’s combustion c hamber by t he ox idation of S O 2 to S O 3 and i ts subsequent reaction with water; less than 3% of the SO 2 is oxidized to SO 3 . In the boiler stack,

all of the S O 3 formed i s e xpected t o c onvert t o s ulfuric acid mist. SO 2 and S O 3 form as t he organic and pyritic sulfurs in the coal are oxidized in the combustion process.

Emissions of VOC result from incomplete combustion of fuel from either insufficient residence time at a sufficiently high temperature or insufficient oxygen levels to complete the final step in

the oxidation of fuel.

CFB Boiler Control Technology Evaluations The table below shows the control technologies identified as being commercially available for control of the listed pollutants from a CFB Boiler. The potential control technol ogies listed were evaluated for each pollutant, based on e nergy, environmental, and/or economic considerations. Consistent with U.S. EPA’s top

- down approach, the control technologies for each pollutant were considered in order of decreasing emissions redu ction potential.

P OTENTIAL C ONTROL T ECHNOLOGIES FOR THE CFB B OILER

Pollutant Listed Control Technologies Potential Add -on Control Efficiency (%)*

SAM Dry Scrubbing in CFB Bed 90

- 95

Wet Scrubber 80

- 95 Spray Dryer Absorber 60-90

Low Sulfur Coal Base Case

VOC Catalytic Oxidation 60

- 80

GCP in a CFB Boiler Base Case

*Control efficiencies obtained from AP

- 42 (9/98), Section 1.1, Tables 1.1

- 1 and 1.1

- 2, NCASI Special

Report 03

- 04, and vendor data.

Sulfuric Acid Mist

SAM is formed by the hydration o f SO 2 in free (i.e., liquid phase) water. Therefore, in order to control emissions of SAM, emissions of SO 2 must be controlled. The remainder of this analysis focuses on controlling emissions of SO 2

.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 45

Because of the acidic nature of SO 2 , existing sulfur dioxide control technology is primarily based on a lkaline s crubbing s ystems. S crubbers r emove S O 2 formed dur ing c ombustion by us ing various alkaline agents to absorb SO 2 in the flue gas. Flue gases can be treated using wet, dry, or

semi

- dry desulfurization agents that are either disposable (byproducts are discarded or sold) or regenerable (absorbent is regenerated and reused).

Dry Scrubbing in CFB Boiler Bed CFB boilers frequently use a dry scrubbing technique by adding finely ground limestone to the

fl uidized bed. The mechanism for this is nearly identical to a spray dryer. I n the CFB Boiler, limestone is calcined into lime (CaO) by driving off CO 2 . The lime then reacts with SO 2 to form calcium s ulfate, a s olid (CaSO 4 ). T he cal cium s ulfate particles are r emoved f rom t he boi ler media recirculation system by the particulate control s ystem. T he C FB B oiler dr y s crubbing

mechanism results in SO 2 reductions of approximately 90 t o 95% (F. Belin et. al , “Babcock &

Wilcox CFB Boilers

— Design and Experience”, Presented to the 16th International Conference on FBC, May 2001, Reno, NV ). R emoval efficiencies of up t o 98% are possible under certain conditions, but are not achievable with all coals.

Wet Scrubber Lime/limestone, s odium hy droxide, a nd dua l a lkali s cr ubbers ar e am ong t he com mercially proven w et f lue g as de sulfurization ( WFGD or “ wet s crubber”) t echnologies. The lime/limestone processes uses a slurry of calcium oxide or limestone to absorb SO 2 from the flue gas. S odium hy droxide s ystems us e a c austic solution, while dua l a lkali s ystems us e a combination of limestone and caustic solution. Control efficiencies up to 95% can be sustained over extended periods. However, the efficiency of the wet scrubber will be dependent on many factors, i ncluding t he S O 2 inlet concentration; low er inl et c oncentrations y ield lower c ontrol efficiencies. In the case of the CFB Boiler, a wet scrubber is expected to offer approximately

50% control because of the low SO 2 inlet concentrations (because of the inherent SO 2 cont rol in the CFB Boiler).

A s implistic econom ic ana lysis w as pe rformed to determine t he cos t ef fectiveness of a wet

scrubber on t he CFB Boiler. C ost information was obtained from recent U.S. EPA fact sheets used to calculate costs for controlling SO 2 (U.S. EPA, “Air Pollution Control Technology Fact Sheet; Flue Gas Desulfurization”, EPA -452/F-03- 034, p. 2) . The SO 2 control efficiencies were assumed to be the same as SAM efficiencies and were applied to the uncontrolled SAM emission

rates. Since the U.S. EP A data give a range of costs, low, medium, and high cost values were chosen. This information is shown in table on the following page. As the table shows, the use of a wet scrubber is not economically feasible, even when burning higher (up to 4%) sulfur coal.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 46

U.S. EPA C OST D ATA FOR W ET S CRUBBERS ON S MALL B OILERS (<2,000 MMB TU / HR ) Cost Range

Parameter Low Medium High Capital Cost, $/MMBtu $25,000 $75,000 $150,000 O&M Cost, $/MMBtu

- yr $800 $1,200 $1,800 Annualized Capital Cost, $/yr $7,095,000 $21,285 ,000 $42,570,000 O&M Cost, $/yr $1,513,600 $2,270,400 $3,405,600 Total Annual Cost, $/yr $8,608,600 $23,555,400 $45,975,600 Cost Effectiveness, $/ton SAM, 4% Sulfur Coal $989,346 $2,707,110 $5,283,757

Spray Dryer Absorber A s pray dr yer a bsorber s yste m ut ilizes a lkaline a gent s lurry in conjunction with a pa rticulate collection system, such as a baghouse, fabric filter, or ESP. Similar to a WFGD system, the flue gas stream is contacted with an alkaline slurry spray after leaving the boiler combustion c hamber. Unlike a W FGD, w hich r elies on f lue g as c ontact w ith t he s lurry as the primary method of pollutant removal, this stage represents the first of two removal steps for a spray dryer absorber. Once the slurry spray is introduced into the flue gas stre am, the alkali droplets are allowed to

react w ith the S O 2 contaminants be fore dr ying i nto a f ine pow der. This fine powder is then carried over into the particulate collection system and removed. T his col lector s erves as t he second stage of the removal sy stem and provides additional contact between the dried reactants

and SO 2 contaminants.

The combination of s pray s ystem and particulate r emoval i s abl e t o achieve S O 2 removal efficiencies of 60 to 90% when implemented aggressively. However, the efficiency of the spray dryer s ystem w ill be de pendent on m any f actors, i ncluding t he S O 2 inlet concentration; lower inlet concentrations yield lower control efficiencies. In the case of the CFB Boiler, a spray dryer is expected to offer approximately 50% control (the 50% control was provided by CFB boiler vendor) because of the low SO 2 inlet concentrations (because of the inherent SO 2 control in the CFB Boiler).

A s implistic econom ic ana lysis w as pe rformed to determine t he cost effectiveness of a spray dryer absor ber on t he CFB Boiler. C ost information was obtained from recent U.S. EPA data used to calculate costs for controlling SO 2 ( U.S. EPA, “Air Pollution Control Technology Fact Sheet; Flue Gas Desulfurization”, EPA -452/F-03- 034, p. 2) . T he SO 2 control effic iencies were assumed to be the same as SAM efficiencies and were applied to the uncontrolled SAM emission

rates. Since the U.S. EPA data give a range of costs, low, medium, and high cost values were chosen. This information is shown following page . As the table shows, the use of a spray dryer is not economically feasible, even when burning higher (up to 4%) sulfur coal.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 47

U.S. EPA C OST D ATA FOR S PRAY D RYERS ON S MALL B OILERS (<2,000 MMB TU / HR ) Cost Range

Parameter L ow Medium High Capital Cost, $/MMBtu $30,000 $75,000 $150,000 O&M Cost, $/MMBtu

- yr $1,000 $5,000 $30,000 Annualized Capital Cost, $/yr $4,257,000 $7,095,000 $11,352,000 O&M Cost, $/yr $1,892,000 $2,838,000 $5,676,000 Total Annual Cost, $/yr $6,149,000 $9,933,000 $17,028,000 Cost Effectiveness, $/ton SAM,

4% Sulfur Coal $706,675 $1,141,553 $1,956,947

Low Sulfur Coal Usage Sulfur di oxide e missions a re di rectly r elated t o t he s ulfur c ontent of t he coal fuel fired in the boiler. As a result, the use of lower sulfur coal can have a dramatic effect on SO 2 emissions. A survey of com mercially

- available coal types i ndicates a va riation of s ulfur c ontent f rom 0.25 weight pe rcent ( wt%) f or s ome a nthracite c oals t o a s hi gh a s 5.4 wt% for certain bituminous

var ieties.

While t he us e of low

- sulfur c oal is a ttractive f rom the pe rspective of mini mizing e missions, Weyerhaeuser anticipates using c oal m ined i n O klahoma f or a por tion of t he c oal f ired i n t he

CFB Boiler. L ow

- sulfur coal is not available from mines in Oklahoma and surrounding states and must be imported from Wyoming or its neighboring states, resulting in additional cost and transportation- related emissions.

SAM BACT Determination As m entioned a bove, t he ope ration of a C FB boi ler r esults i n i nherently low S O 2 and S AM emissions. The economic analyses for a wet scrubber and a spray dryer presented above indicate that the additional installation of these devices is not economical. T herefore, the use of a CFB boiler is determined a s B ACT f or S AM. A n a pp ropriate B ACT limit f or S AM is 0.0012

lb/MMBtu averaged on a W eyerhaeuser f iscal m onth basis, which is cons istent with recent BACT analyses listed in the RBLC database. To account for short

- term spikes in SAM emission rates f rom t he C FB B oiler, Weyerhaeuser al so anticipates a short

- term S AM limit of 0.0021

lb/MMBtu averaged on a daily basis.

Volatile Organic Compounds The control technologies reviewed for VOC e missions w ere c atalytic ox idation a nd g ood combustion practices.

Catalytic Oxidation The mechanism of catalytic oxidation is where combustion products are passed over a catalyst at temperatures between 400 and 800°F. However, oxidation catalysts are readily poisoned by even

moderate concentrations of SO 2 , such as those in the boiler. T herefore, the use of an oxidation catalyst on a CFB boiler is not feasible. I n addition, no entries of a CFB boiler using catalytic

oxidation were found in the RBLC database.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 48

Good Combustion Practices Good c ombustion pr actices i nvolve pa rametric monitoring and contr olling t he ope rating parameters of the boiler to ensure continual operation as close to optimum conditions as possible. VOC emissions are minimized when the boiler temperature and excess ox ygen availability are adequate for complete combustion. This is en sured by the use of stack oxygen sensors, the long residence time of the combustion products in the boiler and routine tuning of the burners.

VOC BACT Determination The use of catalytic ox idation on a CFB boiler is not technically feasible. Therefore, th e best feasible control option for VOC from the boiler is the use of GCP. An appropriate BACT limit for V OC (a s c arbon) from t he boi ler i s 0.005 l b/MMBtu averaged on a W eyerhaeuser f iscal month basis, which is consistent with data from multiple CFB boiler vendors.

Summary

BACT S UMMARY FOR THE CFB B OILER

Pollutant Emission Limit Control Technology

SAM 0.0012 lb/MMBtu (Weyerhaeuser fiscal month average) 0.0021 lb/MMBtu (Weyerhaeuser daily average) CFB Boiler with

Limestone Injection

VOC (as carbon) 0.00 5 lb/MMBtu (Weyerhaeuser fiscal month average) GCP

Lime Kiln BACT Analysis

S UMMARY OF A NTICIPATED M AJOR L IME K ILN D ESIGN P ARAMETERS

Parameter Value Heat Input (TSI) Primary Fuel Petcoke/Natural Gas Average Petcoke Sulfur

Content 5%

Lime Kiln C ontrol Technology Evaluations The Lime Kiln will burn a mixture of natural gas and petcoke. The potential control technologies listed in table below were evaluated for each pollutant, based on energy, environmental, and/or

economic c onsiderations. Consis tent w ith U .S. E PA’s t op

- down a pproach, t he c ontrol technologies f or e ach pol lutant a re c onsidered i n or der of de creasing e mission r eduction potential.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 49

P OTENTIAL C ONTROL T ECHNOLOGIES FOR THE L IME K ILN

Pollutant Listed Control Technologies Potential Add

- on Control Efficiency (%) *

SAM Lime Kiln Scrubbing 75

- 98

Wet Scrubber 80

- 95 Spray Dryer Absorber 60

- 90

Low Sulfur Fuel Base Case

VOC Catalytic Oxidation 60-80

GCP Base Case

*Control efficiencies obtained from AP

- 42 (9/98), Section 1.1, Tables 1.1

- 1 and 1.1

- 2.

Sulfuric Acid Mist The formation of S AM i n t he L ime K iln i s t he s ame a s i n ot her c ombustion de vices; S O 2 is

oxidized to SO 3 and hydrated to form H 2 SO 4 . The removal mechanisms for SAM are the same

as for SO 2 , with each control technology providing similar efficiencies for both SO 2 and SAM. Therefore, the remainder of this analysis is focused on SO 2 control technologies.

Lime Kiln Scrubbing The ability of lime and/or limestone to scrub SO 2 from the exhaust gas. Since the Lime Kiln

conta ins a large quantity of lime , significant a mounts of S O 2 are s crubbed f rom t he e xhaust

stream. The effectiveness of the SO 2 removal is estimated at up to 98% (NCASI, “Technical Bulletin 646, E mission F actors f or N O

x , S O 2 and V OC f rom B oilers, K raft P ulp Mills a nd Bleach P lants”, 1993 a nd pr ivate c ommunications w ith R obert Crawford, NCASI, containing draft updates to emissions data in NCASI Technical Bulletin 646).

Wet Scrubber Wet scrubbing was discussed previously. C ontrol efficiencies up t o 95% can be sustained over extended periods.

Spray Dryer Absorber Spray dr ying w as di scussed pr eviously. T he c ombination of a s pray s ystem and particulate

removal i s abl e t o achieve S O 2 removal efficiencies of 60 t o 90% w hen i mplemented aggressively.

Low Sulfur Fuel Usage In boilers and other units that do not contain lime as part of the process, sulfur dioxide emissions are directly related to the sulfur content of the fuel fired. As a result, the use of lower sulfur fuel

can have a dr amatic effect on SO 2 emiss ions. H owever, the presence of lime in the Lime Kiln

means that SO 2 emissions are relatively insensitive to fuel sulfur content. Therefore, the use of low sulfur fuel is likely to have minimal effect on SO 2 emissions.

SAM BACT Determination

As mentioned above, a lime kiln inherently incorporates aspects of the wet scrubbing and spray dryer systems in its operation. As a result, the inherent scrubbing present in the Lime Kiln is determined as BACT for SAM. This is equivalent to 0.002 lb/MMBtu for SAM av eraged on aPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 50

Weyerhaeuser fiscal month basis. To account for short

- term spikes in SAM emission rates from the L ime K iln, Weyerhaeuser al so anticipates a short

- term S AM limit of 0.0089 lb/MMBtu averaged on a daily basis.

Volatile Organic Compounds

The con trol technologies reviewed for VOC e missions w ere c atalytic ox idation a nd g ood combustion practices.

Catalytic Oxidation The mechanism of catalytic oxidation was discussed previously. Oxidation catalysts are readily poisoned by e ven m oderate concentratio ns of S O 2 , s uch a s t hose e xiting t he L ime K iln. I n addition, catalytic oxidation has not been successfully demonstrated in practice on a lime kiln. Weyerhaeuser concludes that the use of catalytic oxidation on the Lime Kiln is not technically

feasible.

Good Combustion Practice Good combustion practices involve parametric m onitoring a nd c ontrolling t he ope rating parameters of t he L ime K iln t o e nsure c ontinual ope ration a s c lose to optimum conditions as possible. V OC e missions a re m inimized when the kiln temperature and excess ox ygen availability are adequate for complete combustion. This is ensured by the use of oxygen sensors and routine tuning of the kiln burners.

VOC BACT Determination The us e of c atalytic ox idation on a lime ki ln is not te chnically feasible. T herefore, the be st feasible control option for VOC f rom t he ki ln i s t he us e of g ood c ombustion pr actices, appropriate BACT limit for VOC (as carbon) from the Lime Kiln is 0.26 l b/ton CaO

, averaged on a Weyerhaeuser fiscal month basis, which is consistent with recent BACT determinations in the RBLC database (Recent BACT entries listed in the RBLC include levels of 0.073 lb/ton CaO, 0.234 lb/ton C aO, 0.69 l b/ton C aO, a nd 1 l b/ton C aO. T he l owest l evel i n t he l ist i s f or t he Apple Grove, WV, facil ity that was never built. Therefore, the proposed BACT limit is at the low end of the remaining BACT entries in the RBLC).

Summary

BACT S UMMARY FOR THE L IME K ILN

Pollutant Emission Limit Control Technology

SAM 0.002 lb/MMBtu (Weyerhaeuser fiscal month a verage) 0.0089 lb/MMBtu (daily average) Lime Kiln (Inherent Scrubbing)

VOC (as carbon) 0.26 lb/ton CaO (Weyerhaeuser fiscal month average) GCPPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 51

Pollutant Formation Processes

The formation of SO 2 and SAM in the Recovery Furnace is somewhat different from the CFB Boiler. In addition to sulfur contained in the fuel combusted by the Recovery Furnace (including black liquor solids), sulfur is contained in the non

- condensable gases that are fed to the Recovery Furnace for emission control. The Recovery F urnace also differs from other combustion sources, as t he R ecovery F urnace c ontains a r educing z one i n t he bot tom of t he f urnace, be low the primary bur ners. T he f ormation of V OC i n t he R ecovery F urnace i s t he s ame a s i n t he C FB

Boiler.

Chemical Recovery F urnace Control Technology Evaluations

Table below lists the control technologies identified as being commercially available for control of t he l isted pol lutants f rom a R ecovery F urnace. T he pot ential c ontrol t echnologies were evaluated f or e ach pol lutant based on e nergy, e nvironmental, a nd/or economic considerations. Consistent with U.S. EPA’s top

- down approach, the control technologies for each pollutant were considered in order of decreasing emission reduction potential.

P OTENTIAL CONTROL TEC HNOLOGIES FOR THE R ECOVERY F URNACE

Pollutant Listed Control Technologies Potential Add

- on Control Efficiency (%)

SAM Wet Scrubber 80

- 95 Spray Dryer Absorber 70-90 High Solids Firing 0.5 ppm

Low Sulfur Fuels 30

- 70

GCP Base Case

VOC Catalytic Oxidation 60

- 80 Staged Combustion 40

- 60

Non

- Direct Contact Evaporators Varies

GCP Base Case

* Control efficiencies obtained from AP

- 42 (9/98), Section 1.1, Tables 1.1

- 1 and 1.1

- 2.

Sulfuric Acid Mist In or der t o c ontrol e missions of S AM, e missions of S O 2 must be c ontrolled. T herefore, t he remainder of this analysis focuses on controlling emissions of SO 2

.

Wet Scrubber A review of U.S. EPA and state BACT analyses indicates that the use of wet scrubbers has not been successfully de monstrated on a commercial Re covery F urnace. W eyerhaeuser conc ludes that the use of a wet scrubber on the Recovery Furnace is not technically feasible.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 52

Spray Dryer Absorber A review of U.S. EPA and state BACT analyses indicates that the use of spray dryers has not

been successful ly demonstrated on a com mercial R ecovery F urnace. W eyerhaeuser conc ludes that the use of a spray dryer on the Recovery Furnace is not technically feasible.

High Solids Firing The hi gh s olids f iring t echnique i nvolves f iring bl ack l iquor w ith a hi gh s ol ids content i n t he Recovery Furnace. T he solids content of the black liquor is increased to over 65% before it is fed to the Recovery Furnace. This r esults i n t he e vaporation of l ess w ater f rom t he s olids, increasing the furnace bed temperature. The hig her bed temperature improves reduction of sulfur in the Recovery Furnace and, thus, lowers SO 2 emissions.

Low Sulfur Fuels The majority of the fuel burned in the Recovery Furnace is black liquor solids. Since this is how the R ecovery F urnace s erves i ts p urpose in the Kraft pulping c ycle, t his c annot be c hanged. Therefore, the use of low sulfur fuels i s not a t echnically f easible opt ion f or t he R ecovery

Furnace.

Good Combustion Practices and Furnace Design

GCP is the ba se cas e cont rol f or S AM on a R eco very Furnace a nd i ncorporates no a dditional controls. T he c hemical r ecovery f urnace ( CRF) ope rates w ith three combustion zone. The concentrated bl ack l iquor i s i ntroduced i nto t he m iddle z one of t he f urnace w here water and volatile or ganics ar e eva porated from the liquor a s i t f alls t o t he bot tom. T he bot tom of t he furnace is operated with reduced oxygen where the black liquor solids are pyrolyzed. Volatilized organic material rises up the furnace and molten organic salts (including NaS) are removed from the bottom of the furnace. The top of the furnace is operated as an oxidizing zone, where the combustion of organics is completed. The new CRF will have better capture of sulfur (lower SO 2 emissions) due to improved furnace design and higher black liquor solids firing. H igher black liquor s olids e ntering t he f urnace pr oduces i ncreased be d t emperatures i n t he bot tom of the furnace a nd t hus m ore s odium f ume pr oduction. S O 2 capture in the CRF is understood to be facilitated by sodium fume reacting with the sulfur compounds to form sulfate that is collected as particulate. The overall sulfur capture rate of the new furnace will be over 99%.

SAM BACT Determination High solids firing is the highest performing control option that has been demonstrated in pr actice and is selected as the control technology for SAM from the Recovery Furnace. The appropriate BACT limit for SAM from the Recovery Furnace is 0.5 ppm (corrected to 8% oxygen) averaged on a Weyerhaeuser fiscal month basis.

Volatile Organic Compounds

The control technologies reviewed for VOC e missions w ere c atalytic ox idation, s taged combustion, non-direct contact evaporator (NDCE) design, and good combustion practices.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 53

Catalytic Oxidation Catalytic ox idation w as di scussed pr eviously i n Section. C atalytic ox idation ha s not be en successfully demonstrated in practice on a Recovery Furnace. Weyerhaeuser concludes that the use of catalytic oxidation on the Recovery Furnace is not technically feasible.

Staged Combustion Staged c ombustion i s f requently i ncorporated i nto ne w R ecovery F urnace de signs to enhance capacity and control over the combustion process. S taged combustion can achieve VOC outlet concentrations of 40 ppm (corrected to 8% oxygen) w hen c ombined w ith t he us e of a N DCE design.

Non- Di rect Contact Evaporator Design The use of a NDCE design for the black liquor evaporation section of the Recovery Furnace is a technically feasible control technology and is frequently applied to modified and new Recovery Furnaces. Recent BACT analyses ind icate that the use of the NDCE design, in conjunction with staged combustion, can result in VOC emissions of 40 ppm (corrected to 8% oxygen).

Good Combustion Practice GCP i s t he ba se c ase c ontrol f or V OC on a Recovery Furnace and incorporates no additiona l

controls.

VOC BACT Determination The use of staged combustion and the NDCE design is the highest performing control option that has been demonstrated in practice and is selected as the control technology for VOC from the Recovery F urnace. T he a ppropria te BACT limit f or V OC ( as car bon) f rom t he R ecovery Furnace i s 40 ppm ( corrected t o 8% ox ygen) a veraged on a W eyerhaeuser f iscal m onth basis,

which is consistent with recent BACT determinations in the RBLC database.

Summary

BACT S UMMARY FOR THE R ECOVERY F URNACE

Pollutant Emission Limit Control Technology

SAM 0.5 ppm @ 8% O 2 (Weyerhaeuser fiscal month average) GCP

VOC (as carbon) 40 ppm @ 8% O 2 (Weyerhaeuser fiscal month average) Staged Combustion /

NDCEPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 54

Paper Machines BACT Analysis

Pollutan t Formation Processes

VOC is the only pollutant emitted by the paper machines subject to PSD review for this project. Emissions of V OC f rom t he pa per m achines a re a ttributed t o pa per machine additives and recycled process water. VOC are present in the w ater portion of the pulp stock that is fed to the paper machines. This VOC is volatilized during the drying process.

Various additives, including but not limited to, starch, alum, caustic, sulfuric acid, defoamer, felt cleaner, retention and drainage aid s, and strength and size additives, may be added to the pulp slurry upstream of the paper machines to improve the final product quality and to maximize raw material utilization. VOC generated by these additives cannot be reasonably controlled, nor can

sub stitute additives always be employed. T herefore, t he B ACT f or V OC doe s not a ddress control technologies relative to the use of different additives.

Paper Machine Control Technology Evaluations

The table below, lists the potentially feasible control tech nologies for VOC emissions from the paper machines.

P OTENTIAL C ONTROL T ECHNOLOGIES FOR THE P APER M ACHINES

Pollutant Listed Control Technologies Potential Add

- on Control Efficiency (%)

VOC Thermal Oxidation 95+ Catalytic Oxidation 95+ Carbon Adsorption 95

Biofiltration 60

- 90

Wet Scrubber Varies Good Operating Practices Base Case

* Control efficiencies obtained from AP

- 42 (9/98), Section 1.1, Tables 1.1

- 1 and 1.1

- 2.

Thermal Oxidation Thermal oxidation involves heat recovery with regenerative be ds or recuperative heat exchanges by further combusting VOC

- laden gases. Although no installations of thermal oxidizers for the control of paper machine exhausts have been r equired, t his c ontrol opt ion i s c onsidered technically f easible. Thermal ox idizers can achieve a V OC de struction efficiency of approximately 95%.

However, the volumetric flow rates of the paper machines are significantly large, and the VOC concentrations a re ve ry l ow, s uch t hat t he i nstallation a nd ope ration of a thermal oxidizer is

ec onomically i nfeasible. U .S. EPA ha s es timated annualized costs for regenerative thermal oxidizers at between $8 and $33 pe r scfm (U.S. EPA, “Air Pollution Control Technology Fact Sheet; R egenerative I ncinerator”, EPA -452/F-03- 021, p. 3.) . T his w ould y ield “an or der of magnitude” annualized cost of greater than $20,500,000 ( using $20.5/ scfm, t he m iddle of t hePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 55

range). Since the uncontrolled amount of VOC emitted by the paper machines is approximately 830 ton/yr, and the thermal oxidizer can control approximately 95% of all VOC, the annualized cost effectiveness is greater than $26,000 per ton of VOC removed. I n addition to the cost, a thermal ox idizer of t his s ize w ould e mit be tween 309 a nd 926 t on/yr N O

x . V OC f rom paper machines are al so difficult t o captu re, because of the large size of the paper machines and the fugitive na ture of t he e missions, c reating a n e normous pr oblem ( and e xpense) i n simply capturing the emissions.

Weyerhaeuser concludes that the use of thermal oxidation on paper machines is not e conomically feasible and has adverse e nvironmental i mpacts, ba sed on t he a dditional g eneration of N O

x emissions.

Catalytic Oxidation Catalytic ox idation is s imilar to thermal ox idation for control of VOC emissions from paper

machines and can achieve sim ilar control efficiency. However, catalytic oxidation uses catalysts to l ower t he r equired e nergy l evels, s uch t hat ox idation c an be accomplished at a lower temperature. As a result, the necessity for auxiliary fuel will be lower than a thermal oxidizer. Although no installations of catalytic oxidizers for the control of paper machine exhausts have been required, this control option is considered technically feasible. Based on the characteristics of the paper machine ex haust s treams, there ar e no specif ic is sues s uggesting tha t a c atalytic oxidizer is not technically feasible.

The capital cost of a catalytic ox idizer is ty pically hi gher tha n the c apital c ost of a the rmal oxidizer. B ased on t he c onservative ( i.e., l ess t han a ctual c ost) c ost e valuation for a t hermal oxidizer, the cost effectiveness of catalytic oxidation is at least $26,000 per ton of VOC removed. In addition, since catalytic oxidation systems are very sensitive to particulates (especially wood fiber), some form of additional particulat e control to address emissions during a process upset would be required to ensure r eliable ope ration, f urther i ncreasing t he c apital c osts. T hus, catalytic oxidation is considered economically infeasible.

Carbon Adsorption Carbon adsorption is a VOC control technique that uses activated carbon as an adsorbent. VOC has a strong affinity for the surface of activated carbon; this affinity is higher as the temperature of the gas stream is reduced.

In the carbon adsorption process, VOC

- laden gases are passed through a bed of activated carbon.

The V OC a dsorbs ont o t he s urface of t he c arbon unt il t he a mount of VOC adsorbed on the carbon i s i n e quilibrium w ith t he V OC c oncentration i n t he g as s tream. P rior t o r eaching equilibrium, the VOC on t he carbon is strip ped off using steam or hot air and then condensed. Carbon adsorption c an a chieve V OC c ontrol e fficiencies of a pproximately 95% ; how ever, t he efficiency of c arbon a dsorption i s hi ghly de pendent on t he V OC be ing a dsorbed, the concentration of the VOC, and the conditions of the gas stream.

Carbon adsorption is most efficient when VOC inlet concentrations are between 100 a nd 5,000 ppm, and the gas stream is cool and at moderate or low relative humidity. The gas stream fromPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 56

the paper machines is at or near sa turation with water vapor at a temperature of approximately 165 °F . I n a ddition, t he V OC c oncentration i n t he pa per m achine exhaust is lower than the optimum carbon adsorption operating range. Therefore, the performance of the carbon adsorber under these conditions will be very poor.

The primary VOC emitted by paper machines is methanol. C arbon adsorption is a poor choice for controlling methanol be cause of t he poor a dsorption i sotherm f or m ethanol. C arbon a nd zeolite can be used in series to improve t he control efficiency, but overall control is still poor (Frank Hussey and Ajay Gupta, , “Using Carbon and Zeolite For VOC Removal,” from ESD

- The Engineering Society, Proceedings of the Advanced Coatings Technology Conference, April 7 -10, 1997, D etroit, M I). T he c ombination of a ll of t hese factors make it unlikely that carbon adsorption will produce any significant VOC reductions on t he paper machines without chilling the entire inlet stream, which is likely to be extremely expensive. VOC from paper machi nes are also difficult to capture, because of the large size of the paper machines and the fugitive nature of the emissions, creating an enormous problem (and expense) in simply capturing the emissions.

Additionally, a r eview of U .S. E PA a nd s tate BACT a n alyses indicates t hat t he us e of carbon absorbers has not been successfully demonstrated on paper machines. Additionally, spent carbon from the adsorber must be regenerated either at an on

- site regeneration facility or by an off

- site activated carbon supplier. W eyerhaeuser concludes that the use of carbon adsorption on paper machines is not technically feasible.

Biofiltration Biofiltration is the us e of ba cteria a nd ot her m icrobes t o r emove V OC f rom a g as s tream. Biofiltration is a r elatively ne w te ch nology w here V OC

- laden gas i s pus hed t hrough a be d containing a fixed media with microorganisms attached to the media. T he organisms consume the VOC as part of their metabolism, creating CO 2 and organism mass.

Since bi ofiltration is a bi ological

– not ph ysical

– technology, it is highly sensitive to process conditions. Biofilters work best with saturated gas streams at approximately 90 to 100 °F, with a consistent flowrate and organic concentration. Since the gas stream from the paper machines is

approx imately 165 °F , the gas stream would have to be cooled before being fed to the biofilter, which would release a r elatively l arge am ount of heat energy and result in the generation of a large amount of water. A dditionally, based on t he large exhaust gas fl ow rates from the paper machines, a substantial amount of space would be needed to locate a biofilter.

As mentioned previously, the engineering problems associated with cooling the paper machine exhaust stream to an acceptable temperature for the biofilte r are significant. Biofiltration is an unproven technology with regard to applications for the exhaust from paper machines, and no installations in paper machines are known. Weyerhaeuser concludes that the use of biofiltration on the paper machines is no t technically feasible.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 57

Wet Scrubber Wet s crubbing i nvolves t he us e of a pa cked t ower, s pray tower, or venturi to remove

water

- soluble VOC from the gas stream by contacting the gas stream with water droplets. The

VOC

- laden water is then treated to r emove the VOC and returned to the scrubber.

Methanol is a primary VOC compound in the exhaust from the No. 2 and No. 3 Paper Machines. Conventional packed wet scrubbers recirculate a large flow of the scrubbing liquid. According to a scrubber vendor (Sly Incorporated), such a scrubbing system is ineffective to control methanol, based on i ts high Henry’s law constant. A once

- through water scrubber can achieve reasonable methanol control efficiency. H owever, performance of a once

- through scrubber with res pect to control of pinenes and terpenes, which are also important VOC constituents in paper machine exhausts, are unknown, and t his t ype of s crubber i s e xpected t o be i neffective f or t hese compounds based on their chemical properties. There are many other types of VOC in the stream that a lso ne ed t o be c ontrolled. D esigning a s crubbing s ystem and formulating a scrubbing reagent for all of these VOC are infeasible. T herefore, t he w et s crubber c ontrol opt ion i s considered to be technically infeasible and w ill not be considered further in this analysis.

VOC BACT Determination There are no t echnically and/or economically feasible control technologies for controlling VOC from the paper machines. S everal t echnically f easible opt ions ar e econom ically i nfeasibl e, primarily based on t he high exhaust gas flow and the low pollutant loadings. Therefore, good operating practices are determined as BACT for the paper machines.

OCC Plant BACT Analysis

Pollutant Formation Process

VOC is the onl y pol lutant e mitted by the OCC P lants tha t is s ubject to PSD r eview f or thi s project. The OCC Plants take in used containers, re

- pulp them, and separate foreign particles from t he pul p. T his pul p i s t hen us ed i n t he pa per m achines t o pr oduce ne w product. VOC

emissions from th e OCC Plants are released from fugitive emission sources.

OCC Plant Control Technology Evaluations

Because no c ontrol t echnology i nformation i s a vailable i n t he R BLC da tabase for VOC emissions f rom O CC pl ants, a s et of pot ential c ontrol t echnologies a re identified, based on commonly a vailable V OC c ontrol te chnologies. Table be low, lists the potential technically feasible control technologies for controlling VOC f rom t he O CC P lants. T hese c ontrol technologies were described in the previous section and will not be discussed here.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 58

P OTENTIAL C ONTROL T ECHNOLOGIES FOR OCC P LANTS

Pollutant Listed Control Technologies Potential Add

- on Control Efficiency (%)

VOC Thermal Oxidation 95+ Catalytic Oxidation 95+ Carbon Adsorption 95+

Biofiltration 60

- 90

Wet Sc rubber Varies Good Operating Practices Base case

* Control efficiencies obtained from AP

- 42 (9/98), Section 1.1, Tables 1.1

- 1 and 1.1

- 2.

Thermal Oxidation The m echanism of t hermal ox idation of V OC i n t he O CC P lants i s t he s ame as for the paper

machines . Although no installations of thermal oxidizers for the control of OCC plant exhausts have been required, this control option is considered technically feasible.

However, the vol umetric f low r ates of t he O CC P lants ar e significantly large, and the VOC

c oncentrations a re ve ry l ow, s uch t hat t he i nstallation a nd ope ration of a thermal oxidizer is economically i nfeasible. U .S. EPA ha s es timated annualized costs for regenerative thermal oxidizers at between $8 and $33 pe r scfm (U.S. EPA, “Air Pollution Control Technology Fact Sheet; R egenerative I ncinerator”, EPA -452/F-03- 021, p. 3) . T his w ould y ield “ an or der of magnitude” a nnualized c ost of g reater t han $8,200,000 ( using $20.5/scfm, the middle of the range). Since the uncontrolled amount of VOC emitted by the OCC Plants is approximately 37 ton/yr, and the thermal oxidizer can control approximately 95% of all VOC, the annualized cost effectiveness i s g reater t han $220,000 pe r t on of V OC r emoved. In addition to the cost, a

thermal oxidizer of this size woul d emit between approximately 123 a nd 370 t on/yr NO

x . VOC from OCC plants are also difficult to capture, because of the fugitive nature of the emissions, creating an enormous problem (and expense) in simply capturing the emissions.

Weyerhaeuser conc ludes t hat the use of thermal ox idation on O CC plants is not economically feasible and has adverse e nvironmental i mpacts, ba sed on t he a dditional g eneration of N O

x emissions.

Catalytic Oxidation The mechanism of catalytic oxidation of VOC in the OCC Plants is the same as for the paper machines. Although no installations of catalytic oxidizers for the control of OCC plant exhausts have been required, this control option is considered technically feasible. However, the capital cost of a catalytic oxidizer is ty pically higher than the capital cost of a t hermal oxidizer. Based on the conservative (i.e., less than actual cost) cost evaluation for a thermal ox idizer, the cost effectiveness of catalytic oxidation is at least $220,000 pe r ton of VOC removed. I n addi tion, since catalytic oxidation systems are very sensitive to particulates (especially wood fiber), some form of additional particulate control t o a ddress e missions dur ing a pr ocess ups et w ould be required t o e nsure r eliable ope ration, further increasing t he capi tal cos ts. T hus, catalytic oxidation is considered economically infeasible.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 59

Carbon Adsorption Carbon a dsorption w as de termined t o be not t echnically f easible f or paper machines as it was discussed before. The mechanism of carbon adsorption of VOC in the OCC Plants is the same as for the paper machines. Therefore, carbon adsorption is also not technically feasible for the OCC

Plants.

Biofiltration Biofiltration was determined to be not technically feasible for paper machines as it was discussed

be fore. T he mechanism of biofiltration of VOC in the OCC Plants is the same as for the paper machines. Therefore, biofiltration is also not technically feasible for the OCC Plants.

Wet Scrubber Wet s crubbing w as de termined to be not t echnically f easible f or paper machines as i t w as discussed before. The mechanism of wet scrubbing of VOC in the OCC Plants is the same as for the paper machines. Therefore, wet scrubbing is also not technically feasible for the OCC Plants.

VOC BACT Determination

There are n o technically and/or economically feasible control technologies for controlling VOC from the OCC Plants. Several technically feasible options are economically infeasible, primarily based on the high exhaust gas flow and the low pollutant loadings. T herefore, good operating practices are determined as BACT for the OCC Plants.

SECTION VIII. AIR QUALITY IMPACTS

For any pollutant exceeding its PSD SER as part of a new construction or modification, a PSD air impa cts a nalysis is r equired to demonstrate c ompl iance with any appl icable am bient ai r quality standards established for that pollutant. As ide ntified in Section VI of thi s pe rmit application, the creditable emissions increases from the proposed project exceed the PSD SER for V OC a nd S AM. T herefore, a n ambient i mpacts r eview f or V OC i s c onducted us ing t he Scheffe Method. A PSD air quality analysis is not conducted for SAM, since no NAAQS or PSD Increments for this pollutant have been established. H owever, compliance with the state toxics standard (OAC 252:100-41) for sulfuric acid mist was conducted and is in compliance.

U.S. EPA regulates VOC as precursors to t ropospheric oz one f ormation. O zone i s uni que because U.S. EPA has not es tablished a P SD m odeling s ignificance l evel ( an ambient

concentrati on expressed in either m icrograms pe r cubi c m eter [ **μ** g/m 3 ] or pa rts pe r m illion by volume [ppm

v ]) for ozone. U .S. EPA has established an ambient monitoring de minimis level, which is different from other criteria pollutants, because it is based on a mass emission rate (100 tpy) instead of an ambient concentration (in units of **μ** g/m 3 or ppm v ). In addition, U.S. EPA has established primary and s econd N AAQS f or oz one. S ince t he pr oposed pr oject ne t V OC emissions ex ceed the appl icable P SD S ER, the S cheffe Meth od i s e mployed t o de termine whether the proposed project will cause or contribute to a violation of the currently enforced 1

- hour ozone NAAQS (Scheffe, Richard D., VOC/NOx Point Source Screening Tables, U.S. EPA OAQPS Technical Support Division, Draft Document, September 1988).PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 60

The Scheffe Method is a s creening procedure used to calculate the ambient ozone concentration resulting from a s ource. A series of lookup tables, based on the Reactive Plume Model

- II, are used t o c onservatively e stimate the ozone concentration increase. U se of t he S cheffe M ethod requires know ledge of t he r atio of m aximum a nnual non

- methane vol atile or ganic c ompounds (NMVOC) t o NO

x emissions f rom t he f acility. T he l ookup tables have been validated for

NMVOC/NO

x values ranging from 1 to 30. The user is cautioned against interpolating from the tables for values outside this range. In addition, it is generally accepted that NMVOC/NO

x ratios less than 2:1 result in no significant i ncrease i n oz one ( Texas C ommission on E nvironmental Q uality (formerly T exas N atural R esource C onservation C ommission), Air Quality Modeling

Guidelines , Draft Document, February 1999).

The pos t

- project f acility

- wide VOC /NO

x ratio is 1.17: 1. S ince t he pos t

- project f acility

- wide VOC emissions total includes methane emissions, it follows that the NMVOC/NO

x ratio will be

less t han 1.17: 1. A s t he N MVOC/NO

x ratio is less tha n 2:1, the V alliant M ill is c onsidered

NO

x - dominated, a nd t he N MVOC/NO

x ratio is not conducive to oz one f ormation, a nd no significant increase in ozone can be expected.

SECTION IX. Additional Impacts Analysis

The PSD additional impacts analysis depends on e xisting air quality, the quantity of emissions, and the s ensitivity of loc al s oils, vegetation, and visibility in the source’s impact are a. T he analysis is presented in four parts:

**•** Growth analysis

**•** Soils and vegetation analysis

**•** Visibility impairment analysis

**•** Class I Area impact analysis

Growth Analysis The elements of the growth analysis include a projection of the associated industrial, commercial, and residential growth that will occur in the area of impact attributable to the source, including the potential impact on ambient air resulting from this growth. The Valliant Mill is an existing facility, and therefore is not expected to caus e a significant shift of population or an increase in industrial, commercial, and residential growth i n t he a rea. S ince no s ignificant a ssociated commercial, industrial, or r esidential g rowth is e xpected as a r esult of the project, negligible growth

- related ambient air impacts are expected.

Soil and Vegetation Analysis A soil and vegetation analysis examines the characteristics of soils and vegetation in the impact area and determines i f t he ai r em issions f rom pr oposed project will create significant harm ful effects. The secondary NAAQS are intended to protect the public welfare from adverse effects of airborne pollutants. This protection extends to agricultural soil and vegetation.

McCurtain C ounty ha s a n a rea of 1,825 s quare m iles. A ccording t o t he S oil C onservation Service, most of the soils are fine sandy loams with a pH in the acidic range (4.5 to 6.5). ThePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 61

vegetation is primarily forest and pasture. T he Oklahoma Department of Agriculture reported that less than 6% of the county land area is crop land. T he surrounding counties in Oklahoma, Texas, and Arkansas have similar c onditions, but t he pr oportion of c ropland i ncreases upon crossing the Red River into Texas, 7 miles south of the Valliant Mill. The majority of the land surrounding the Vallian t Mill is commercial timber production, most of it owned or managed by Weyerhaeuser.

As discussed before, the ambient air impacts from the proposed project are not expected to cause or contribute to an exceedance of the primary or secondary NAAQS. Theref ore, no s ignificant adverse impact on soil and vegetation is anticipated.

Visibility Impairment Analysis A visibility impairment analysis examines the visual quality in the impact area of the proposed project and determines i f t he af fected emission source s w ill c ontribute to significant vi sibility impairment. The proposed project will not result in a net emissions increase of NO

x , SO 2 , PM,

or PM 10 . Since there is no net emissions increase in visibility impairing pollutants, the maximum potential impa cts from the proposed project a re not e xpected t o i mpact visibility in the surrounding area.

SECTION X. Class I Area Impact Analysis

Class I Areas are defined by the U.S. EPA’s New Source Review Manual as those areas of the nation that ar e of s pecial na tural , s cenic, r ecreational, or hi storic i nterest t o the public. The closest Class I Area to the Valliant Mill is the Caney Creek Wilderness Area, which is located approximately 97 kilometers (km) northeast of the facility. This Class I Area is managed by the

U.S. Forest Service (FS).

Class I Area analyses examine two separate items: ( 1) Class I Increments and (2) A ir Quality Related Values (AQRVs) . Class I Increment modeling is explicitly required by U.S. EPA under the PSD program and is reviewed for appro val by the state permitting agency. Class I Areas have a s eparate s et of P SD I ncrements f or P M 10 , S O 2 , a nd N O

x that a re mor e s tringent tha n the typically considered Class II Increments. The proposed project will not result in a net emissions

increase of PM 10 , S O 2 , a nd N O

x . T herefore, a C lass I I ncrement m odeling a nalysis is not

warranted.

In a ddition t o t he Increment a nalysis r equired f or t he pr otection of hum an health and welfare, additional air quality analyses can be requested to ensure that the natural and cultural resources of certain designated national pa rks and wilderness ar eas ( i.e., Class I A reas) are not adversely impacted by ai r pol lution. Federal Land Managers (FLMs) are tasked with protecting specific Class I Areas and have defined AQRVs t o assess the impacts of new and existing facilities on these areas. These AQRVs include visibility, regional haze, and the deposition of nitrates and sulfates in soil a nd surface w aters. T he ma ximum pot ential air quality impacts from the proposed pr oject are not expected to significantly impa ct a ny A QRVs in the C aney C reek

Wilderness AreaPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 62

SECTION XI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory require ments.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Primary Standards are in Appendix E a nd S econdary S tandards a re i n A ppendix F of t he A ir Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100- 4 (New Source Performance Standards) [Applicable] Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2003, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, a nd 60.16), Subpart B, Subpa rt C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. NSPS regulations are covered in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]

Subc hapter 5 requires sources of a ir c ontaminants to register w ith Air Q uality, file e mission inventories annually, and pay annual operating fees ba sed upon t otal a nnual e missions of regulated pol lutants. W eyerhaeuser w ill s ubmit r equired a nnual e missions i nfo rmation ( Turn Around Document) and emission fees to the Air Quality Division.

OAC 252:100- 8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes t he g eneral a dministrative r equirements f or P art 70 pe rmits. A ny planned changes in the operation of t he facility which result in emissions not authorized in the permit and which exceed the “ Insignificant A ctivities” or “ Trivial A ctivities” thr esholds r equire prior notification to AQD and may require a pe rmit modi fication. I nsignificant a ctivities me an

in dividual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:

**•** 5 TPY of any one criteria pollutant

**•** 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

**•** 0.6 TPY of any one Category A toxic substance

**•** 1.2 TPY of any one Category B toxic substance

**•** 6.0 TPY of any one Category C toxic substance

Part 7 includes the r equirements for PSD projects in attainment areas. This project is classified as a significant modification to a major facility. Since this is a physical change that requires a significant modification, a construction permit is required. The Title V permit application for this facility will be updated as required to reflect the modifications associated with this project.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable] In the eve nt of any r elease w hich results i n excess emissions, the owner or ope rator of s uch facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 63

working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/ Title V s ources m ust r eport a ny e xceedance t hat pos es a n i mminent and substantial danger to public health, safety, or t he e nvironment a s s oon a s i s pr acticable. U nder no

circumstances shall notification be more than 24 hours after the exceedance.

OAC 252:100-13 (Prohibition of Open Burning) [Applicable] Open burning of refuse and other com bustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.

OAC 252:100-17 (Incinerators) [Not Applicable]

Part 9 of S ubchapter 17 r egulates commercial a nd industrial s olid waste inc ine ration uni ts constructed on or before November 30, 1999. C onstruction of all sources as part of the project will take place after this date.

OAC 252:100- 19 (Particulate Matter (PM)) [Applicable] Subchapter 19 specifies a P M e mission limitation from f uel

- burning e quipment a nd i ndustrial processes. S ubchapter 19 s pecifies P M e missions l imitations ba sed on heat input capacity. Weyerhaeuser considers the heat input capacity of the new equipment to be confidential. For the new C FB B oiler, Recovery Furnace, and Lime K iln applicable pe rmit limita tions a re mor e stringent than Subchapter 19, therefore they are in compliance with Subchapter 19.

Subchapter 19 s pecifies a limit of PM emissions from wood

- waste burning equipment of 0.35

lb/MMBTU. The CFB Boiler is subject to this standard. E missions from the CFB Boiler are limited to 0.025 lb/MMBTU, which is in compliance with Subchapter 19.

This subchapter limits emissions of particulate ma tter f rom pr ocesses ot her tha n fuel -burning equipment based on their proce ss weight rate. All the new equipment’s emissions rates of PM are in compliance with the allowable PM emissions under Subchapter 19.

OAC 252:100- 25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opa city i s al lowed excep t for s hort

- term oc currences w hich

consist of not m ore t han one s ix

- minute pe riod i n a ny c onsecutive 60 m inutes, not t o e xceed three such periods in any consecutive 24 hour s. In no c ase shall the average of any six

- minute period exceed 60% opacity. Emissio n units subject to an NSPS opacity limit are exempt from this section. T he new boiler, kilns and other emission units are subject to opacity limits under NSPS and are exempt from this subchapter.

OAC 252:100-29 (Fugitive Dust) [Applicable] Subchapter 2 9 pr ohibits t he ha ndling, t ransportation, or di sposition of a ny s ubstance l ikely t o

become airborne or wind

- borne without taking “reasonable precautions” to minimize emissions of f ugitive dus t. N o pe rson s hall c ause or pe rmit t he di scharge of a ny visible f ugitive dus t emissions be yond t he pr operty l ine on w hich t he e missions or iginate i n s uch a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or t o interfere w ith the m aintenance of ai r q uality s tandards. Most of the ma terialsPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 64

handled a re w ood/wood w aste, therefore non

- brittle a nd not ve ry s usceptible t o be coming fugitive dust. Haul roads and the landfill are watered to minimize emissions of fugitive dust. The permit will require reasonable precautions to minimize fugitive dust.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 2 limits the ambient air impact of sulfur dioxide (SO 2 ) emissions from any existing facility or any new petroleum and natural gas process facility subject to OAC 252:100 -31- 26(a)(1). The ambient air quality modeling summarized in the following table demonstrates compliance with

the SO 2 standards.

COMPLIANCE WITH SO 2 AMBIENT IMPACTS LIMITATIONS

Averaging Period Ambient SO 2 Impacts Limitation, ug/m 3 Modeled SO 2 Impacts, ug/m 3

3

- Hours 650 299

24

- Hours 130 104

Part 2 also limits H 2 S impacts to 0.2 ppm (24 hour average). Compliance with this standard is the subject of Consent Order 99-026 and will be discussed in Section XI: “Compliance Plans.”

Part 3 specifie s l imitations on t otal r educed s ulfur c ompounds e missions. T he f ollowing table lists the standards of Subchapter 31 for existing Kraft paper mills

COMPLIANCE WITH TRS EMISSIONS LIMITATIONS

Emission Unit TRS Emission Limitation of OAC 252:100-31 (12- hour

average as H 2 S on a dry basis) TRS Emission Rate Test

Results

Recovery Furnace 40 ppm @ 8% O 2 24.6 ppm @8% O 2 (1989)

Lime Kiln 40 ppm @ 10% O 2 31.3 ppm @10% O 2 (1989) Smelt Dissolving Tanks 0.016 g TRS per kilogram (0.033 lb/ton) black liquor

solids 0 .013 g TRS per kg black liquor solids (0.02 lb/ton BLS)(1989) NCG Thermal Oxidizer, when incinerating NCGs from the evaporators and digesters 5 ppm by volume 0.9 ppm (4/5 -6/02 stack test)

Part 5 limits sulfur dioxide emissions from new equipment (constr ucted after July 1, 1972). For gaseous fuels, the limit is 0.2 lbs/MMbtu heat input; for liquid fuels, the limit is 0.8 lb/MMBTU; and for solid fuels, t he l imit i s 1.2 l b/MMBTU. T he pe rmitted S O 2 emission rates ar e m uch more stringent than Subchapter 31 limits.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 65

Part 5, S ection 27 addresses sulfur oxide emission limits from blow pits, washer vents, storage tanks, di gester r elief, a nd r ecovery f urnace of a ny ne w pul p m ill. The Valliant Mill began operation in 1971; therefore, this section does not apply.

OAC 252:100-33 (Nitrogen Oxides) [Applicable] Subchapter 33 affects new fuel

- burning equipment with a rated heat input of 50 M MBTUH or more. The C FB B oiler and the R ecovery F urnace em ission rates are in compliance with the applicable limitations of Subcha pter 33. The Lime Kiln burns a combination of solid and gaseous fuels for which there is no applicable limitation.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable] None of the following affected processes are part of this project: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic reforming unit or petroleum catalytic cracking unit.

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

Part 3

Part 5 limits the V OC c ontent of pa ints a nd coatings. T he V alliant M ill doe s not nor mally conduct coating or painting operations except for routine maintenance, which is exempt requires storage tanks constructed after December 28, 1974, with a capacity of 400 gal lons or more and containing a VOC with a vapor pressure greater than 1.5 ps ia at maximum storage temperature to be equipped with a permanent submerged f ill pi pe or w ith a n or ganic va por recovery system. No new storage tanks within these thresholds are proposed for this project.

Part 7 also requires f uel

- burning e quipment t o be ope ra ted and maintained so as to minimize emissions. T emperature a nd available a ir mus t be s ufficient to provide e ssentially c omplete combustion. The equipment at this location is subject to this requirement.

OAC 252:100-41 (Hazardous Air Pollutants and Toxi c Air Contaminants) [Applicable]

Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on July 1, 2003, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found i n 40 C FR P art 63, S ubpart A , a nd t he M aximum A chievable C ontrol T echnology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, GGGG, HHHH, JJJJ, NNNN, OOOO, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted by r eference a s t hey e xist on J uly 1, 2003. These standards apply to bot h e xisting a nd ne w

sources of HAPs. These requirements are covered in the “Federal Regulations” section.

Part 5 is a s tate

- only r equirement governing t oxic a ir c ontaminants. N ew s ources ( constructed after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform a B ACT ana lysis. All s ources ar e r equired t o de monstrate t hat e missions of any toxic air

contaminant which exceeds the de minimis level do not cause or contribute to a violation of the MAAC. T he a pplicant c onducted m odeling f or e ach pol lutant w ith e missions a bove a de

minimis level. The ISCST3 model was used using a full year of meteorological data with the predicted impacts shown in the following table.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 66

COMPLIANCE WITH OAC 252:100 -41

Toxic Ambient Impacts A ug/m 3 MAAC B
ug/m 3 Refined Modeling Required? 1,1,2

- Trichloroethane 1.69 545 No
1,2,4

- Trichlorobenzene 8.62 4000 No
1,2

- Dichloroethane 2.70 40 No
1,2

- Dichloroethylene 10.22 79296 No Acetaldehyde 245.85 3600 No

Ammonia 35.96 1742 No

Barium 0.02 10 No

Benzene 0.34 32 No

Cadmium 0.00 0.5 No

Carbon Tetrachloride 12.72 125 No

Chlo roform 10.23 97 No

Ethanol 81.99 38000 No Formaldehyde 18.44 12 Yes

Iron 0.05 10 No Isopropanol 120.48 98339 No

Methanol 11,344.24 26216 No Methyl ethyl ketone 409.38 59000 No Methyl isobutyl ketone 257.74 20486 No Methylene chloride 4.51 1736 No

Nickel 0.03 0.15 No

o

- Xylene 6.00 43427 No

Phenol 1.67 384 No

Silver 0.08 2 No Styrene 1.75 4260 No

Sulfuric acid mist 1.45 10 No Terpenes 220.32 11120 No Tetrachloroethylene 4.82 3350 No Trichloroethylene 2.63 1343 No

Vanadium 0.01 0.5 No

A Maxi mum Modeled Concentration represents the sum of the highest modeled impacts over the five meteorological years for each pollutant from each modeled mill sources (independent of space and time).

B All screening standards are MAACs pursuant to the Partial Li sting of Air Toxics Subject to OAC 252:100

- 41, except the screening standard for iron is a PEL established under 29 CFR 1910.1000.

As presented in the table above, refined air quality dispersion modeling was only required for formaldehyde. Therefore, the post- project source emissions for formaldehyde were modeled for all five meteorological years to obtain a more realistic assessment of impacts. The following table presents the results of the refined air quality dispersion modeling analysis for formaldehyd e.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 67

R EFINED D ISPERSION M ODELING R ESULTS FOR

F ORMALDEHYDE Meteorological Year Maximum Impact ( μ g/m 3 )

1989 9.77

1990 10.19

1991 8.72

1992 10.55

1993 9.16

As shown in the table above, t he m aximum m odeled i mpacts f rom pos t

- project f acility

- wide

forma ldehyde emissions are less than the corresponding MAAC of 12 μg/m 3 . Therefore, the postproject facility

- wide emissions from the proposed project at the Valliant Mill are in compliance with the requirements of Subchapter 41.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for t esting, m onitoring a nd r ecordkeeping a nd applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance wit h emissions limitations or standards, the Air Quality Director may require t he ow ner or ope rator of a ny s ource i n t he s tate of O klahoma t o i nstall, m aintain a nd operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice -of- intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or m onitoring not c onducted i n a ccordance w ith t he pr ovisions of t his subchapter shall be considered invalid. Nothing shall preclude the use, including the exc lusive use, of any credible evidence or information relevant to whether a source would have been in compliance w ith applicable r equirements i f t he appr opriate pe rformance or compliance test or procedure ha d be en pe rformed. All r equired tests s hall be ma de and the r esults cal culated in accordance w ith t est pr ocedures de scribed or r eferenced i n t he pe rmit a nd a pproved by Air Quality.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Emissions Reduction not requested OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevators not in source category

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

OAC 252:100-47 Landfills not municipal landfillPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 68

SECTION XII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable] The f acility ha s be en i ssued f our P SD pe rmits. T hese pe rmits w ere issued following demonstrations tha t ins ure tha t the f acility w ill not c ause or c ontribute to a violation of a NAAQS, PSD increment, or adversely affect visibility or other air quality related value (AQRV). Since the net emissions increase from the project will exceed the PSD significant emission rate for VOC and SAM, PSD review was applicable for these pollutants. The facility is a major source for NOx, CO, SO 2 , PM 10 , and VOC. Any future increases must be evaluated in the context of PSD significance levels: 40 TPY NOx, 100 TPY CO, 40 TPY SO 2 , 15 TPY PM 10 , 40 TPY VOC, 10 TPY TRS, or 0.6 TPY lead.

NSPS, 40 CFR Part 60 [Applicable] NSPS r equire ne w, m odified, or r econstructed s ources t o c ontrol e missions t o t he l evel achievable by t he be st de monstrated t echnology s pecifie d in the a pplicable pr ovisions. N SPS regulations apply t o any “af fected” f acility, “modification” of an existing af fected facility, or “reconstruction” of an existing affected facility for which construction commences after the date of proposal of NSPS. The new Recovery Furnace, new Lime Kiln, new Smelt Dissolving Tanks, new CFB Boiler, and the new brownstock washing system are units associated with the project that are affected by an NSPS. Subpart D (Steam G enerating U nits) af fects boi lers w ith a r ated h eat i nput g reater t han 250 MMBTUH w hich c ommenced c onstruction, r econstruction, or m odification a fter August 17, 1971. T his s ubpart a ffects t he ne w B ark B oiler, specifying emissions limitations of 0.8

lb/MMBTU S O 2 , 0.10 l b/MMBTU P M, a nd 0.3 l b/MMBTU N Ox. C EMS systems m easuring opacity, NOx, SO 2 , and a diluent gas (CO 2 or O 2 ) are required. The existing bark boiler will be

decommissioned. Subpart Db (Commercial -Industrial- Institutional Steam Generating Units) affects boilers with a rated he at i nput a bove 100 MMBTUH w hich c ommenced c onstruction, reconstruction, or modification after June 19, 1984. This s ubpart a ffects t he C FB B oiler, s pecifying e missions

limitations of 0.80 lb/MMBTU SO 2 , 0.10 l b/MMBTU PM, and 0.20 l b/MMBTU NOx. CEMS systems m easuring N Ox, SO 2 , and a di luent g as ( CO 2 or O 2 ) a re r equired. C ontinuous monitoring of opacity is only required during periods of oil combustion in the CFB Boiler. The permit will require compliance with all applicable requirements of this subpart. Subpart K b (Volatile O rganic Materials S torage V essels) af fects t anks w ith a capa city above 19,812 g allons w hich c ommenced c onstruction, r econstruction, or m odification a fter J uly 23,

1984. The project does not pr opose a ny ne w or m odified s torage ve ssels e xceeding t he de

minimi s c apacities a nd/or va por pr essures s pecified i n 40 C FR 60.110b( b). Therefore, this subpart is not applicable. Subpart B B (Kraft P aper M ills) af fects each digester s ystem, brown stock washer system, multiple

- effect eva porator, recovery f urnace, smelt di s solving tank, lime ki ln, a nd c ondensate stripper s ystem ( i.e., s team s tripping s ystem) i n kr aft pul p m ills, f or w hich construction, modification, or reconstruction is commenced after September 24, 1976. T he No. 2 br ownstock washer and spent liquor concentr ator were m odified after t he effective date, therefore t hey are subject t o N SPS, S ubpart B B. T he L ime K iln a nd t he N CG T hermal O xidizer a re pollutionPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 69

control de vices f or e quipment s ubject t o S ubpart BB. S ubpart BB pr ohibits di scharge i nto the atmosphere of gases that contain total reduced sulfur (TRS) in excess of 5 ppm by volume unless the gases a re c ombusted i n a n i ncinerator or ot her de vice not subject to the provisions of this subpart and are subjected to a minimum temperature of 1200 oF for at least 0. 5 seconds. Subpart BB requires a continuous monitoring system and describes excess emissions as periods in excess of 5 minutes in duration in which the combustion temperature at the point of incineration is less than 1200oF. T he applicant will maintain co mpliance with NSPS, Subpart BB by continuously monitoring the control device combustion t emperature a nd us ing e ngineering c alculations t o determine r esidence time . T he L ime K iln is a lso subject to this s ubpart when combusting exhaust gases as a ba ck up to the N CG C ollection System a nd Thermal O xidizer. The ne w Recovery F urnace, ne w L ime K iln, ne w S melt D issolving T anks, a nd t he new brownstock washing system a re s ubject to this s ubpart. The pe rmit w ill r equire c ompliance w ith all applicable requirements for each affected emission unit. Subpart Y (Coal P reparation Plant) af fects t hermal dryers, pneumatic coal cl eaning equi pment (air tables), coal processing a nd c onveying e quipment ( including br eakers a nd c rushers), c oal storage s ystems, and coal t ransfer an d l oading s ystems a t a ny c oal pr eparation pl ant t hat commences c onstruction or m odification a fter O ctober 24, 1974 . T he V alliant M ill is not considered a coal preparation plant, as it does not operate any of the processes identified in 40 CFR 60.251(a): b reaking, crushing, screening, wet or dry cleaning, and thermal drying of coal

. Therefore, this subpart is not applicable.

NESHAP, 40 CFR Part 61 [Subpart E Applicable] Subpart E (Mercury E missions) a ffects w astewater tr eatment s ludge inc ineration, limiti ng mercury e missions t o 3,200 g rams pe r 24

- hour pe riod. T his s tandard a ffects t he Bark Boiler, which is used to dispose of water treatment sludges. The permit will require compliance with all applicable requirements.

NESHAP, 40 CFR Part 63 [Subparts S, MM, and DDDDD are Applicable] There are three subparts that affect the Pulp and Paper Industry. The provisions of these subparts apply to a major source that uses the following processes and materials:

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

2. Mechanical pulping processes using wood; or

3. Any process using secondary or non-wood fibers.

Subpart S (Pulp & Paper Industry) establishes MACT standards for control of HAPs pulp and paper production which were finalized and published in the Federal Register on April 15, 1998. These s tandards w ill a ffect knot ter s ystems ( wood knot r emoval systems), pulp screens, pulp washing s ystems, de cker s ystems, di gester ve nts, e vaporator s ystem vents, turpentine recovery systems, w eak l iquor e vaporators, a nd ot her hi gh -volume-low- concentration ( HVLC) a nd low

volume- high

- concentration (LVHC) systems. With the exception of those systems not required to be collected and controlled until April 2006, these units are currently vented to the NCG thermal

ox idizer. The Valliant Mill was granted an extension for compliance with Subpart S until April 15, 2002. T herefore, the 180

- day period within which the facility must demonstrate compliance began on April 15, 2002. The pulp washing systems are allowed until A pril 17, 2006, to achievePERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 70

compliance provided that the owner or operator establishes milestones of progress and dates by

which these will be achieved.

There are several units not affected by Subpart S but which do have significant HAP emissions.

In addit ion to the No. 3 Digester system (semi

- chemical process), Subpart S does not affect the paper machines; applicability ends at the last pulp washing step. The OCC plants are “secondary fiber” processes, but the only standards of Subpart S which affect secon dary fiber processes are for bl eaching uni ts; t here i s no bl eaching uni t a t this facility. The new brownstock washing system is s ubject to this s tandard. T he pe rmit w ill r equire c ompliance w ith all a pplicable

standards.
Subpart M M

Subpart DDDDD (Industrial, Commercial, and Institutional Boilers a nd P rocess H eaters) w as published in the Federal Register on September 13, 2004, and affe cts any boiler or process heater located at a major source of HAP. The existing boiler at this facility is classified as an existing large s olid fuel boi ler ( ELSFB). T he ne w boi ler is c lassified as a ne w large solid fuel boiler (NLSFB). The LSFB’s will be required to meet the emission limitations in Table 1, Section 7 and the work practice standards of Table 2.A, Sections 3 or 4 of this subpart. E LSFBs will be required to conduct initial performance tests in accordance with Tables 5.A, 5.C, and 5.E. In itial compliance must be demonstrated no later than 180 days after the date of publication of the final rule in the federal register. (Chemical R ecovery C ombu stion Sources) establishes MACT st andards f or cont rol of HAPs f rom che mical r ecovery combustion sources w hich were f inalized and published in the Federal Register on January 12, 2001. T he new Recovery Furnace, new Lime Kiln, and new Smelt Dissolving

Tanks are subject to this standard. The permit will require compliance with all applicable requirements.

Compliance Assurance Monitoring, 40 CFR 64 [Applicable] Compliance A ssurance M onitoring, a s publ ished i n the Federal Reg ister on O ctober 22, 1997, applies to any pollutant specific emission unit at a major source, that is required to obtain a Title V permit, if it meets all the following criteria:

**•** It is subject to an emission limit or standard for an applicable regulated air pollutant.

**•** It uses a control device to achieve compliance with the applicable emission limit or

standard.

**•** It has potential emissions, prior to the control device, of the applicable regulated air pollutant greater than major source levels.

Emission uni t s subject to a standard established a fter da te ( 1990) a re not s ubject t o t his regulation. The facility will be required to achieve compliance with Part 64 during the Title V permit process.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility does not store any regulated substance above the applicable threshold limits. More information on this federal program is available at the web site: http://www.epa.gov/ceppo/

.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 71

Stra tospheric Ozone Protection, 40 CFR Part 82 [Applicable] This facility does not produce, consume, recycle, import, or export any controlled substances or controlled products as defined in this part, nor does the facility perform service on motor (fleet)

veh icles w hich i nvolves oz one

- depleting substances. T herefore, a s c urrently ope rated, t his facility is not subject to these requirements. To the extent that the facility has air -conditioning units that apply, the permit requires compliance with Part 82.

SE CTION XIII. COMPLIANCE

Tier Classification and Public Review

This a pplication ha s be en de termined t o be a Tier I I based on t he r equest f or a c onstruction permit for a major source. The applicant published the “Notice of Filing a Tier II Application” in

the McCurtain Gazette on January 30, 2004, a w eekly ne wspaper of g eneral c irculation i n McCurtain County. The notice said that the application was available for public review at the Public Library, T wo S E A venue “ D”, Idabel, O klahoma or a t t he A QD of fice. The appl icant published the “Notice of Draft Tier II Permit” in the McCurtain Gazette on January 30, 2004, a weekly newspaper of general circulation in McCurtain County, on the 24 th of August, 2004. The notice stated that the dr aft pe rmit w as a vailable for publ ic r eview a t P ublic L ibrary, T wo SE Avenue “D”, Idabel, Oklahoma and was available for review on t he Air Quality section of the DEQ w eb page at http://www.deq.state.ok.us

. The U .S.D.A. F orest S ervice m an ager of t he Ouachita National Forest has been notified of the application. The facility is located within 50 miles of the borders with the states of Texas and Arkansas; both states have been notified of the draft pe rmit. No comments w ere r eceived from t he public, the S tate of T exas, the S tate of Arkansas, or U.S. EPA Region VI.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. T he affidavit cer tifies that the applicant owns the property.

Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page: http://www.deq.state.ok.us/

Response to Comments on the Draft Permit

The following commen ts dated July 20, 2004, w ere received from USDA FS

- Southern Region. The comments are typed in italics.

1. Comment: The applicant used 2002 & 2003 emission inventories submitted to the state for their actual emissions. In these inventories, they used an older AP

- 42 (1/95) NOX emission factor of 0.55 lb/MMBtu for the power boiler using natural gas. The current version of AP -42 (7/98) cites a NOx emission factor of 0.28 lb/MMBtu, which is significantly lower. The use of the higher and older emission factor in a potential to emit or emission inventory calculation would be conservative, so in that context, its use is not a problem. However, if the higher emission factors are used in the actual emissions calculation, it is possible that the baseline (past -actual)PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 72

NOx emissions may have been over estimated. Therefore, I am requesting that you verify that the higher emission factors are appropriate for this source. If there are any existing stack test data (or CEM data) for this unit, then those data should be used to establish an accurate NOx baseline for the PSD netting analysis.

Response: Stack test was done on this unit on August 5, 2004. The results of 3 one-hour runs result in an emission of 0.39 l bs NOx/MMBtu when firing a mix of natural gas and fue l oil. This test result was used to revise the netting analysis.

2. Comment: Also please review that the baseline emission calculations for the other emission units included in the netting calculation and verify that they also use the most unit- specifi c data

available.

Response: Weyerhaeuser has documented emission factors that have been provided to the state and utilized for prior permitting, compliance demonstration and annual inventories.

3. Comment: Best Available Control Technology (BACT) is applicable at all emission units at which a net emissions increase would occur in the pollutants subject to PSD review (VOC and SAM in this case). Based on your review of the netting process, BACT may be applicable at

more emissions units than were actuall y listed.

Response: BACT is applicable to all emission units emitting a particular pollutant and that are physically modified located at a f acility for which a significant net emission increase has been determined for that particular pollutant. F or thi s particular modification at this facility, it was determined that there was only a significant net emission increase in VOC and SAM emissions. All emission units emitting VOC and SAM that will be physically modified as a result of this

modification were reviewed to determine if a BACT review was conducted for those emission units. The only emission units that were modified for which a BACT analysis was not conducted were the No. 4 B rownstock Washing System and the Spent Liquor Mix tank. Since the No. 4 Brownstock Washing System is subject to MACT Subpart S (40 CFR 63.443(c)), which requires

it to be enclosed and vented into a closed

- vent system and routed to a control device that meets the requirements of 40 CFR 63.443(d), the applicant did not consider it a separate emission unit subject to a BACT analysis. The applicant also reviewed emissions from the Spent Liquor Mix Tank for applicability of BACT. However, due to the small amount of VOC emissions from the Tanks (2.52 TPY) and the fact that the U.S. EPA's RBLC database does not identify any control technologies as BACT for Spent Liquor Mix Tanks a BACT analysis was not conducted for these

emission units.

4. Comment: We would like to see how compliance will be demonstrated with the BACT limits proposed.

Response: This is addressed in the specific conditions.

5. Comment: SAM for CFB Boiler, it is unclear if BACT is suggested as the top control option of “Dry Scrubbing in CFB Bed” or if no control was selected. If no control was selected then aPERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 73

cost effectiveness calculation should be made for the low sulfur coal option. We assume that the emission rates listed in the RBLC (appendix C of the application) are short term limits, since compliance is usually shown with stack tests. As such we feel it is most appropriate to compare the daily average proposed BACT limit to the RBLC, not the monthly average limit. When this comparison is made the proposed SAM limit of 0.0021 lb/MMBtu is above those listed. A comparison should be made between those boilers and this one to determine why this boiler

can’t achieve those emission levels at a minimum.

Response: Dry Scrubbing in C FB B ed w as s elected a s B ACT. T here a re da ily a nd m onthly average emission limits for BACT for SAM. The higher daily limit is to accommodate hi gher

sulfur content for short term use.

6. Comment: In order to control emissions of SAM for Recovery Furnace, emissions of SO 2 must be controlled. Therefore, the applicant focused on controlling emissions of SO 2 . High solids firing wa s selected as BACT for SAM. I found this statement in the Air Pollution Engineering Manual (2000, AWMA, ed. by W.T. Davis) section on kraft pulp mills for SO 2 emissions “Factors that influence SO 2 levels are liquor sulfidity, liquor solids content, stack gas O 2 , furnace load, auxiliary fuel use, and furnace design. None of these factors has exhibited a consistent relationship to SO 2 emissions (p. 789).” Obviously there are a number of factors that need to be considered regarding sulfur emissions from thi s unit, including upstream process units. The proposed BACT limit is in terms of concentration. Please tell us what this limit is in terms of mass flow (pound per hour). We can not find the stack gas flow rate in the application.

Response: More in

- dep th evaluation of current Kraft Recovery furnace designs reveal that high solids firing is key to consistently achieve very low SO 2 emission rates. The higher the solids content in t he l iquor t he l esser t he e nergy pe nalty i ncurred i n e vaporating t he l iquo r moi sture content. M ore he at be comes a vailable i n t he f urnace, r esulting i n hi gher t emperatures i n the

lower furnace and smelt bed. Higher temperatures lead to greater levels of sodium volatilization

and a concurrent decrease in the level of H 2 S released during char pyrolysis. The latter results from the e quilibrium in the H 2 S c apture r eaction shifting to the r ight w ith increasing temperatures, as given by the equation:

Na 2 CO 3 + H 2 S = Na 2 S + H 2 O + CO 2

All SO 2 originates in the furnace first as H 2 S, released during char pyrolysis. The H 2 S is oxidized

to S O 2 in t he uppe r ox idizing z ones. H ence, a r eduction i n H 2 S r eleased would lead to comparably l esser S O 2 emissions. T he S O 2 emissions r ates pr oposed i n t his pr oject r eflect utilizing the best current recovery design including high solids black liquor firing.

Pound per hour rates are included in the specific conditions.

7. Comment: Since it is not known if the proposed project indeed results in a less than significant net emissions incre ase of PM 10 , SO 2 , and NO

x , a Class I Area Analysis (including analysis of impacts to visibility, class I increment, and acid deposition) may be needed if the netting process uses the correct baseline emissions.PERMIT MEMORANDUM 97 -057- C (M

- 4) PSD 74

Response: See r esponse t o C omment N o. 1. T he e missions of P M 10 , S O 2 , a nd N O

x will be verified by stack testing.

Fees Paid

Major source construction permit fee of $1,500.

SECTION XIV. SUMMARY

Ambient air quality standards a re not thr eatened at thi s s ite. T here a re no active A ir Q uality compli ance or enforcement issues concerning this facility which would prohibit issuance of this permit. Issuance of the modified construction permit is recommended.PERMIT TO CONSTRUCT

AIR POLLUTION CONTROL FACILITY

Weyerhaeuser Company Permit No. 97-057- C (M

- 4) (PSD)

Valliant Mill

The permittee is authorized to construct in conformity with the specifications submitted to Air Quality on M ay 15, 2004. T he Evaluation Memorandum dated October 12, 2004, e xplains the derivation of a pplicable pe rmit r equ irements and estimates of e missions; how ever, i t doe s not contain limitations or permit requirements. C ommencing construction or operations under this permit constitutes acceptance of, and consent to, the conditions contained herein:

I. Equipment and Applic able Requirements [OAC 252:100-8- 6(a)(1)]

A. EUG FW

– Facility -Wide

1. The pe rmittee s hall s ubmit a modi fication to the pr eviously s ubmitted Title V operating pe rmit a pplication w ithin 180 da ys of s tart up of each of the Recovery Furnace, CFB Boiler, and No. 2 Lime Kiln. [OAC 252 -100-8- 4(b)(5)]

2. For t he e mission uni ts a uthorized unde r t his pe rmit f or w hich a F ederal N SPS or NESHAP is a pplicable, the pe rmittee s hall s ubmit the r equired notifications and/or conduct the required performance testing for the particu lar emission unit within the timeframes identified in the applicable regulation for that emission unit. [40 CFR Part 60.7]

3. The project is subject t o P SD m onitoring f or oz one; t herefore, t he pe rmittee s hall conduct ozone monitoring prior to the commencemen t of operation of the Recovery Furnace, C FB B oiler, or No. 2 Lime Kiln a s a greed upon w ith t he D EQ. T his monitoring w ill a lso complete the r equirements f or pos t

- construction oz one monitoring for Permit No. 97-057- C (PSD) (M -2). [OAC 252 -100-8-35]

B. EUG A1 – No. 1 Digester System

1. NCG’s from the No. 1 Digester System shall be routed to the Recovery Furnace, CFB

Boiler or Thermal Oxidizer for combustion. [OAC 252 -100-8-34]

2. The No. 1 Digester System shall comply with the following regulations:

a. Federal NSPS, 4 0 CFR 60, Subpart BB; and

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

C. EUG A2 – No. 2 Digester System

1. NCG’s from the No. 2 Digester System shall be routed to the Recovery Furnace, CFB

Boiler or Thermal Oxidizer for combustion. [OAC 252 -100-8-34]SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 2

2. The No. 2 Digester System shall comply with the following regulations:

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

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

D. EUG A4, A5, & A7 – OCC Plant

1. The OCC Plants shall comply with the following emission limits. [OAC 252 -100-8- 6(a)(1)]

Emission Point EU Name/Model Fugitive VOC A

lb/hr B TPY C

E

- A4, C No. 1 OCC Plant

9.28 36.89 A5 No. 2 OCC Plant

A7 No. 3 OCC Plant

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fis cal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Condition I.

- D.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records a nd emission factors.

E. EUG A8

– OCC Lightweight Rejects Handling System

1. The OCC Lightweight Rejects H andling S ystem s hall c omply w ith the f ollowing

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

Emission Point EU Name/Model PM 10 lb/hr A TPY B

E

- A8,A OCC Lig htweight Rejects Baghouse 0.43 1.90

A Weyerhaeuser fiscal month basis, and hours of operation.

B 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Condition I.

- E.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

F. EUG B1 – No. 1 Brownstock Washing Area

1. The No. 1 Brownstock Washing A rea S hall c omply w ith t he f ollowing e mission

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

Emission Point EU Name/Model VOC A TRS

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

E-B1,B

E

- B1,C Brownstock Washer 1A 30.00 122.64 8.03 32.81 Brownstock Washer 1B

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 3

2. Compliance with Specific Condition I.

- F.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

3. The No. 1 Brownstock Washing Area shall c omply with the following regulations:

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

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

G. EUG B2 – No. 2 Brownstock Washing Area

1. The N o. 2 B rownstock W ashing A rea s hall c omply w ith the f ollowing emission

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

Emission Point EU Name/Model VOC A TRS

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

E-B2,A E-B2,B 1 st Stage Brownstock Washer 21.67 87.60 5.80 23.43 2 nd Stage Brownstock

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month

.

2. Compliance with Specific Condition I.

- G.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal c alendar month operating rate records and emission factors.

3. The No. 2 Brownstock Washing Area shall comply with the following regulations:

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

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

H. EUG B4 – No. 4 Brownstock Washing Area

1. NCGs f rom t he N o. 4 B rownstock W ashing A rea s hall be collected and controlled (combusted in the recovery furnace, and CFB boiler or NCG Thermal Oxidizer).

2. The No. 4 Brownstock Washing Area shall comply with the following regulations:

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

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

I. EUG C1

– No. 1 Paper Machine (Stock Prep)

EUG C2

– No. 1 Paper Machine (Wet End)

EUG C3

– No . 1 Paper Machine (Dry End)

1. The No. 1 Paper Machine shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 4

Emission Point EU Name/Model VOC A

lb/hr B TPY C

C1 E-C2,A E-C2,B E-C2,D E-C3,A Stock Preparation

Fourdrinier

115.05 419.93 Vacuum Pumps/ Vacuum Flume

Press Section Dryer Section

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Comp liance with Specific Condition I.

- I.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors

.

J. EUG C4

– No. 2 Paper Machine (Stock Prep)

EUG C5

– No. 2 Paper Machine (Wet End)

EUG C6 – No. 2 Paper Machine (Dry End)

1. The No. 2 Paper Machine shall comply with the following emission limits. [OAC 252 -100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A

lb/hr B TPY C

C4 E-C5,A Stock Preparation

Fourdrinier 54.33 202.97 E

- C5,B Press Section

E

- C5,D Vacuum Pumps/ Vacuum Flume
E-C6,A Dryer Section

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month

.

2. Compliance w ith Specific Condition I.

- J.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

K. EUG C7

– No. 3 Paper Machine (Stock Prep)

EUG C8

– No. 3 Paper Machine (Wet End)

EUG C9 – No. 3 Paper Ma chine (Dry End)

1. The No. 3 Paper Machine shall comply with the following emission limits. [OAC 252 -100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A

lb/hr B TPY CSPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 5

C7

E

- C8,A Stock Preparation

Fourdrinier 62.32 209.97 E

- C8,B Press Section
E-C8,D Va cuum Pumps/ Vacuum Flume

E

- C9,A Dryer Section

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month

.

2. Compliance with Specif ic Condition I.

- K.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

L. EUG D2 – No. 1 Power Boiler

1. The N o. 1 Power B oiler s hall c omply w ith the f ollowing e mission limits during periods of supplemental steam production. [OAC 252 -100-8- 6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

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

Main

Stack No.1 Power

Boiler 171.00 299.16 92.99 407.29 1,486.80 933.18 623.70 622.07

Emission

Point EU Name/

Model VOC A Lead H 2 SO 4 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

Main

Stack No. 1 Power

Boiler 6.14 9.36 0.02 0.10 23.25 35.43

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis, and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Condition I.

- L.

- 1 shall be demonstrated monthly based on the a mount of e ach f uel f ired i n t he N o. 1 P ower B oiler dur ing pe riods of supplemental steam pr oduction a nd e mission f actors ( 0.39 l b/MMBTU N Ox a nd

other factors from AP -42)

.

3. The No. 1 Power B oiler m ay al so be us ed as a ba ck

- up s team pr oduction uni t f or periods when the Recovery Furnace and/or CFB Boiler are not in operation. D uring peri ods of ba ck

- up ope ration of t he N o. 1 P ower B oiler, t he s um of the annual emissions from the No. 1 Power Boiler, Recovery Furnace, and CFB Boiler shall not exceed the sum of the annual emission limits specified in Specific Conditions I.

- M. - 1 (CFB) and I.

- Q.

- 1 (Rec. Furn). This annual emission limitation shall be in addition to the emission limitations specified in Specific Condition I.

- L. -1.

M. EUG D5

– CFB BoilerSPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 6

1. The CFB Boiler shall comply with the following emission limits. [OAC 252 -100-8- 6(a)(1)]

E mission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

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

D5 CFB Boiler 47.29 207.12 378.30 1,656.95 378.30 952.75 283.73 828.48

Emission

Point EU Name/

Model VOC A Lead H 2 SO 4 lb/hr B TPY C lb/hr B T PY C lb/hr B TPY C

D5 CFB Boiler 9.46 41.42 0.19 0.83 4.05 10.21

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. The CFB Boiler shall comply with the following BACT requirements :

Pollutant Emission Limit Control Technology

H 2 SO 4 0.0012 lb/MMBtu (Weyerhaeuser fiscal month average) 0.0021 lb/MMBtu (daily average) CFB Boiler with Limestone Injection

VOC (as c arbon) 0.005 lb/MMBtu (Weyerhaeuser fiscal month average) Good Combustion Practices

3. Compliance with Specific Conditions I.

- M.

- 1 and I.

- M.

- 2 shall be demonstrated by an initial performance test using the test methods and procedures specified in 40 C FR §§ 60.8 and 63.7 i n a ccordance w ith 40 C FR §§60.46b a nd 63.7520. C ontinued compliance with the CO, SO 2 , VOC, Lead, and H 2 SO 4 limits shall be demonstrated monthly with monthly operating rate records and emission factors developed based on the ini tial pe rforma nce t est. C ontinued c ompliance w ith t he N O

x and P M / P M 10 limits shall be demonstrated utilizing continuous monitoring systems required by the regulations identified in Specific Condition I.- M. -4.

4. The CFB Boiler shall comply with the following regulatio ns:

a. OAC 252:100, Subchapters 19, 25, 31, and 33

b. Federal NSPS, 40 CFR 60, Subpart Db;

c. Federal NESHAP for Specific Pollutants, 40 CFR 61, Subpart E;

d. Federal NESHAP for Source Categories (MACT), 40 CFR 63, Subpart S (not an affected source and no applicable emission limitations – control device only): and

e. Federal NESHAP for Source Categories (MACT), 40 CFR 63, Subpart DDDDD.

N. EUG E1

– Turpentine Recovery System

1. NCG’s from the Turpentine S ystem s hall be r outed t o t he R ecovery F urnace, C FB

Boiler or Thermal Ox idizer for combustion.

2. The Turpentine Recovery System shall comply with the following regulations:

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

b. Federal NESHAP for Source Categories, 40 CFR 63, Subpart S.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 7

O. EUG E2a – Spent Liquor Concentration

1. NCG’s from t he Spent Liquor Concentration shall be routed to the Recovery Furnace,

CFB Boiler or Thermal Oxidizer for combustion.

2. The S pent L iquor C oncentration i s a m ultiple e ffect e vaporator s ystem and shall comply with the following regulations:

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

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

P. EUG E2b – Evaporator Sump

1. The Evaporator Sump shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A TRS

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

E2b Evaporator Sump 18.81 74.40 15.51 61.35

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Complian ce with Specific Conditions I.

- P.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

Q. EUG E3c

– Recovery Furnace

1. The Recovery Furnace shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

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

E3c Recovery

Furnace 46.34 179.54 1,351.70 1,047.35 507.85 523.67 353.37 912.69

Emission

Point EU Name/

Model VOC A T RS Lead H 2 SO 4 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

E3c Recovery

Furnace 30.90 119.70 5.79 22.44 0.01 0.06 3.86 14.96

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. The Recovery Furnace shall comply with the following BACT requirements.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 8

Pollutant Emission Limit Control Technology

H 2 SO 4 0.5 ppm @ 8% O 2 (Weyerhaeuser fiscal month average) GCP / High Solids Firing VOC (as carbon) 40 ppm @ 8% O 2 (Weyerhaeuser fiscal month average) Staged Combustion / NDCE

3. Compliance with Specific Conditions I.

- Q.

- 1 and I.

- Q.

- 2 shall be demonstrated by an initial pe rformance t est us ing t he t est m ethods and procedures specified in 40 C FR §§60.8 and 63.7 in accordance w ith 40 C FR §§60.285 a nd 63.865. C ontinued compliance with the P M / P M 10, CO, NO

x , V OC, Lead, a nd H 2 SO 4 limits s hall be demonstrated m onthly w ith m onthly ope rating r ate r ecords and emission factors

develo ped based on the initial performance test. Continued compliance with the TRS

and S O 2 limits shall be demonstrated utilizing c ontinuous moni toring s ystems required by the regulations identified in Specific Condition I - Q. -4.

4. The Recovery Furnace shall com ply with the following regulations:

a. OAC 252:100, Subchapters 19, 31, and 33;

b. Federal NSPS, 40 CFR 60, Subpart BB;

c. Federal NESHAP for Source Categories, 40 CFR 63, Subpart MM; and

d. Federal NESHAP for Source Categories (MACT), 40 CFR 63, Subpart S (not an affected source and no applicable emission limitations – control device only).

R. EUG E3d

– Spent Liquor Mix Tanks

1. The Spent Liquor Mix Tanks shall comply with the following emission limits. [OAC 252 -100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A TRS

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

E3d Spent Liquor Mix

Tanks 0.65 2.52 3.58 13.85

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar mon th.

2. Compliance with Specific Conditions I.- R. -1 will be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

S. EUG E4b – Smelt Dissolving Tanks

1. Gases from the Smelt Dissolving Tanks shall be routed to the Recovery Furnace as

combustion air.

2. The Smelt Dissolving Tanks shall comply with the following regulations:

a. OAC 252:100, Subchapters 19, 31, and 33;

b. Federal NSPS, 40 CFR 60, Subpart BB; andSPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 9

c. Federal NESHAP for Source Categories, 40 CFR 63, Subpa rt MM.

T. EUG E5

– Lime Slakers

1. The Lime Slakers shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission

Point EU Name/Model PM / PM 10 TRS VOC A

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

C

E-E5,A Lime Slaker Vent #1 1.62 4.85 0.06 0.17 8.15 24.36

E

- E5,B Lime Slaker Vent #2 1.62 4.85 0.06 0.17 8.15 24.36

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar mon th.

2. Compliance with Specific Conditions I.T.48 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors

.

U. EUG E6

– Causticizing System

1. The Causticizing System shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A TRS

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

E6 (2 stacks) No. 1a Causticizer

15.12 45.18 0.11 0.33 No. 2 Causticizer

No. 1b Causticizer

No. 3 Causticizer

A VOC emissi ons limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation..

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month. 2. Compliance with Specific Condition I.

- U.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

V. EUG E7b – No. 2 Lime Kiln

1. The No. 2 Lime Kiln shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 10

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

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

E7b No. 2 Lime

Kiln 3.18 13.91 24.26 106.25 74.04 72.87 79.76 203.59

Emission

Point EU Name/

Model VOC A TRS Lead H 2 SO 4 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

E7b No. 2 Lime

Kiln 4.13 18.08 1.52 6.68 0.07 0.32 1.13 1.12

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. The No. 2 Lime Kiln shall comply wit h the following BACT requirements

.

Pollutant Emission Limit Control Technology

H 2 SO 4 0.002 lb/MMBtu (Weyerhaeuser fiscal month average) 0.0089 lb/MMBtu (daily average) Lime Kiln (Inherent Scrubbing)

VOC (as carbon) 0.26 lb/ton CaO (Weyerhaeuser fiscal month average) Good Combustion Practices

3. Compliance with Specific Conditions I.

- V.

- 1 and I.

- V.

- 2 shall be demonstrated by an initial performance test using the t est m ethods a nd pr ocedures s pecified i n 40 C FR §§60.8 a nd 63.7 i n a ccordance w ith 40 CFR §§60 .285 a nd 63.865. C ontinued compliance w ith th e P M / P M 10, CO, NO

x , V OC, L ead, a nd H 2 SO 4 limits s hall b e demonstrated monthly with m onthly ope rating r ate r ecords a nd e mission f actors developed based on the initial performance test. C ontinued compliance with the TRS

and SO 2 limits shall be demonstrated utilizing continuous monitoring systems required by the regulations identified in Specific Condition I.

- V.

- 4.

4. The No. 2 Lime Kiln shall comply with the following regulations:

a. OAC 252:100, Subchapters 19, 31, and 33;

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

c. Federal MACT, 40 CFR 63, Subpart MM.

W. EUG E8

– Tall Oil Plant

1. The Tall Oil Plant shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A TRS

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

Main Stack Tall Oil Plant 43.20 189.22 5.60 24.51

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Conditions I.- W. -1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 11

X. EUG F1 – Woodyard

1. The Woodyard shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission

Point EU Name/Model PM PM 10 VOC A

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

F1 Woodyard 5.44 4.70 2.70 2.28 0.33 1.44

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Conditions I.

- X.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

Y. EUG F1b – Coal Mate rial Handling

1. These emission units are considered insignificant be cause t heir em issions ar e l ess

than 5 TPY.

Emission Point EU Name/Model Construction

/Modification

-- Coal Material Storage Piles 2005 (Planned)

-- Coal Material Stacking 20 05 (Planned)

-- Coal Material Reclaiming 2005 (Planned)

2. The permittee shall keep records to verify insignificance.

Z. EUG F3a – Wastewater Treatment System

1. The Wastewater Treatment System shall comply with the following emission limits. [OA C 252:100-8- 6(a)(1)]

Emission Point EU Name/Model VOC A TRS

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

F3a Wastewater Treatment System 111.71 441.82 27.30 119.58

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of opera tion.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Condition I.

- Z.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 12

AA. EUG F4a – NC G Collection and Thermal Oxidation System – LVHC

EUG F4b – NCG Collection and Thermal Oxidation System – HVLC

1. The N CG T hermal O xidizer m ay be us ed as a back

- up uni t f or t he c ontrol a nd combustion of NCGs and SOGs for periods when the Recovery Furnace and/ or CFB Boiler is not in operation. During periods of back

- up operation of the NCG Thermal Oxidizer, t he s um of t he a nnual e missions f rom the NCG Thermal Oxidizer, Recovery Furnace, and CFB Boiler shall not exceed the sum of the annual emission limits spec ified in Specific Conditions I.M.29 (CFB) and I.Q.39 (Rec. Furn.).

Prior to the operation of the CFB Boiler, the NCG Thermal Oxidizer shall be used as a back -up unit for the control and combustion of NCGs and SOGs for periods when the Recovery Furnace

is not in operation. During these periods of back -up operation of the NCG Thermal Oxidizer, the sum of the annual emissions from the NCG Thermal Oxidizer and Recovery Furnace shall not exceed t he a nnual e mission l imits s pecified i n S pecific Conditions I.Q.39 (Rec. F urn.); t he Thermal Oxidizer lb/hr emissions shall not exceed previously permitted (No. 99-134- C) emission limits specified for the Thermal Oxidizer.

Emission

Point EU Name/

Model PM / PM 10 CO SO 2 NO

x lb/hr B lb/hr B lb/hr B lb/hr B

F4 Therma l

Oxidizer 7.6 0.4 41.5 91.1

Emission

Point EU Name/

Model VOC A TRS

lb/hr B lb/hr B

F4 Thermal

Oxidizer 0.6 0.5

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

2. The Thermal Oxidizer shall comply with the following regulations:

a. OAC 252:100, Subchapters 19, 31, and 33;

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

c. Federal MACT, 40 CFR 63, Subpart S.

3. Compliance with Specific Condition I.- BB. -1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

BB. EUG F5

– Landfill Operations

1. Landfill Operations shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission Point EU Name/Model PM PM 10 lb/hr A TPY B lb/hr A TPY B

F5 Landfill Operations 15.84 4.11 7.58 1.95

A Weyerhaeuser fiscal month basis and hours of operation.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 13

B 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance with Specific Condition I.- CC. -1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

CC. EUG F7 & F9

– Chip Thickness Screening and Conditioning System

1. The C hip T hickness S creening a nd C onditioning S ystem s hall comply with the

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

Emission

Point EU Name/Model VOC A PM PM 10 lb/hr B TPY C lb/hr B TPY C lb/hr B TPY C

F7/F9 Bar Screen

3.90 15.41 2.05 8.09 1.23 4.85 Chip Conditioner
Air Density Separator #1

Air Densit y Separator #2
Air Density Separator #3

A VOC emissions limitations expressed as carbon.

B Weyerhaeuser fiscal month basis and hours of operation.

C 12

- month rolling total based on Weyerhaeuser fiscal calendar month.

2. Compliance w ith S pecific C ondition I.

- DD.

- 1 s hall be de monstrated m onthly based on W eyerhaeuser f iscal c alendar m onth on ope rating rate records and emission

factors.

DD. EUG F10 – Steam Stripper System

1. SOG’s from the Steam Stripper S ystem s halll be r outed t o t he R ecovery F urnac e, CFB Boiler or Thermal Oxidizer for combustion.

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

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

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

EE. EUG F14 – Petcoke Silo Bin Vent No. 2

1. The Petcoke Silo Bin Vent No. 2 shall comply with the following emission limits. [OAC 252:100-8- 6(a)(1)]

Emission

Point EU Name/Model PM PM 10 lb/hr A TPY B lb/hr A TPY B

F14 Petcoke Silo Bin Vent No. 2 0.10 0.45 0.10 0.45

A Weyerhaeuser fis cal month basis and hours of operation.

B 12

- month rolling total based on Weyerhaeuser fiscal calendar month.SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 14

2. Compliance with Specific Condition I.

- FF.

- 1 shall be demonstrated monthly based on Weyerhaeuser fiscal calendar month operating rate records and emission factors.

GG. The permittee shall maintain records of operations as listed below. These records shall be

maintained on

- site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:100-8- 6 (a)(3)(B)]

a. The OCC Plants (EUG A4, A5, & A7) operating rate as a monthly basis.

b. The O CC L ightweight R ejects H andling S ystem ( E

- A8,A) operating rate as a monthly basis.

c. The N o. 1 B rownstock W ashing A rea ( E

- B1,B & E

- B1, C) operating r ate as a monthly basis.

d. The No. 2 Brownstock W ashing A rea ( E

- B2,A & E

- B2,B) operating r ate as a monthly basis.

e. The No. 2 Paper Machine (C1, E

– C2,A, E

– C2,B, E

– C2,D, & E –C3,A) operating rate as a monthly basis.

f. The No. 2 Paper Machine (C4, E

– C5,A, E

– C5,B, E

– C5,D, & E –C6,A) operating rate as a monthly basis.

g. The No. 3 Paper Machine (C7, E

– C8,A, E

– C8,B, E

– C8,D, & E –C9,A) operating rate as a monthly basis.

h. The No. 1 Power Boiler (E- D2) operating rate as a monthly basis.

i. The CFB Boiler ( E- D5) operating rate as a monthly basis. j. The Evaporator Sump (E-E2b) operating rate as a monthly basis.

k. The Spent Liquor Mix Tanks (E-E3d) operating rate as a monthly basis.

l. The Lime Slakers (E -E5,A & E-E5,B) operating rate as a monthly basis.

m. The Caustici zing System (E -E6) operating rate as a monthly basis.

n. The No. 2 Lime Kiln (E-E7b) operating rate as a monthly basis.

o. The Tall Oil (E -E8) operating rate as a monthly basis.

p. The Woodyard (E-F1) operating rate as a monthly basis.

q. Insignificance activity (E

- F1 b) from coal material handling .

r. The Evaporator Sump (E- F3a) operating rate as a monthly basis.

s. The Evaporator Sump (E- F3a) operating rate as a monthly basis.

t. The Wastewater Treatment System (E

- F3a) operating rate as a monthly basis.

u. The NCG Thermal Oxidi zer (E -F4) operating rate as a monthly basis.

v. Landfill Operations (E-F5) operating rate as a monthly basis.

w. The Chip Thickness Screening (E- F7 & E -F9) operating rate as a monthly basis.

x. The Petcoke Silo Bin Vent No. 2 (E-F14) operating rate as a monthly ba sis.

HH. Within 180 days from issuance of this permit, the permittee shall conduct testing of actual emissions of NOx (lb/MMBTU) for the power boiler (EUG

- D2) as follows and furnish a written report to Air Q uality. Testing s hall be c onducted unde r c ond itions w hich ar e r epresentative of normal operations over the previous two years. The following USEPA methods shall be used for testing of emissions, unless otherwise approved by Air Quality: [OAC 252:100-8- 6(a)]

A. The following EPA testing methods shall be used:SPECIFIC CONDITIONS 97 -057- C (M

- 4) PSD 15

Method 7E: Determination of Nitrogen Oxide Emissions from Stationary Sources.

Method 19: Determination of Sulfur Dioxide Removal Efficiency and Particulate Matter, Sulfur Dioxide, and Nitrogen Oxide Emission Rates

B. At least 30 days written notice shall be given prior to the testing to allow an observe to be present, and a pre

- test plan shall be submitted at the time of notification of the day of testing. [OAC 252:100-43]

C. T esting s hall be c onducted w hile t he P ower Boiler is operating u nder the following

conditions:

1. Heat input shall be 660 MMBTUH + 60 MMBTUH.

2. Heat input from gas fuel shall be 250 MMBTUH + 33 MMBTUH.

3. Heat i nput f rom N o. 6 r esidual oi l s hall be 330 MMBTUH + 33

MMBTUH.

D. Testing shall include a demonstration that oxygen and NOx concentrations across the

diameter of the stack/duct are within 10% of the mean concentrations. The mean shall be determined by sampling at least at 8 points across the diameter.Weyerhaeuser Company Attn: Kelly Folsom

2821 West &th Stre et Ft Worth , Texas 76107

SUBJECT: Permit Number: 97-057- C (M

- 4) PSD Facility: Valliant Paper Mill Location: Secs. 26, 27, 28, 33 and 34- T6S -R21E, McCurtain County

Dear Mr. Folsom:

Enclosed is the permit authorizing construction of the referenc ed facility. Please note that this permit is i ssued s ubject t o t he c ertain s tandards a nd s pecific c onditions, w hich a re a ttached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic insp ections.

Also note that you are required to annually submit an emissions inventory for this facility. An emissions i nventory m ust be c ompleted on a pproved A QD f orms a nd submitted (hardcopy or electronically) by M arch 1 st of eve ry y ear. Any que stions c on cerning the f orm or s ubmittal process should be referred to the Emissions Inventory Staff at 405-702-4100.

Thank y ou f or y our c ooperation. P lease r efer t o t he pe rmit num ber a bove a nd direct any questions concerning the status of this application to Roya Sharifsoltani at (405) 702-4215.

Sincerely,

Dawson Lasseter, P.E. Chief Engineer AIR QUALITY DIVISION

# PERMIT

AIR QUALITY DIVISION

STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLA HOMA CITY, OKLAHOMA 73101 -1677

Issuance Date Permit No. 97-057- C(M

- 4)

Weyerhaeuser Company_________________________

, having complied with the requi rements of the law, is hereby granted permission to construct

a Kraft Process paper mill at Valliant, McCurtain County, Oklahoma.

subject to the following conditions, attached:

[X] Standard Conditions dated October 15, 2003

[X] Specific Conditions

____________________________________________________ Director, Air Quality Division

DEQ Form # 100-890 Revised 2/25/04

### TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT

STANDARD CONDITIONS (October 15, 2003)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there und er. [ Oklahoma Clean Air Act , 27A O.S. § 2-5-112]

B. The is suing A uthority f or the pe rmit is the A ir Q uality D ivision (AQD) of the O klahoma Department of E nvironmental Q uality ( DEQ). T he pe rmit doe s not relieve the holder of the obligation to comply with o ther applicable federal, state, or local statutes, regulations, rules, or

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

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

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial of an application to renew thi s pe rmit. A ll a pplicable requirements (excluding state -only requi rements) are enforceable by the D EQ, by E PA, a nd by c itizens unde r s ection 304 of t he Clean Air Act. This permit is valid for operations only at the specific location listed. [OAC 252:100-8-1.3 and 8- 6 (a)(7)(A) and (b)(1)]

D. It s hall not be a defense for a pe rmittee i n a n e nforcement a ction t hat i t w ould ha ve be en necessary to halt or reduce the pe rmitted activity in order to maintain compliance w ith the conditions of the permit. [OAC 252:100-8- 6 (a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any e xceedance r esulting f rom e mergency c onditions a nd/or posing an imminent and substantial danger t o publ ic he alth, s afety, or t he e nvironment s hall be r eported i n a ccordance

with Section XIV. [OAC 252:100-8- 6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. [OAC 252:100-8- 6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also ac ceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the ow ner ope rator s hall s ubmit a w ritten report describing the extent of the excess emissions and response actions taken by the facility. Every written report submitted under this section shall be certified by a responsible official. [OAC 252:100-8- 6 (a)(3)(C)(iii)(I) and (iv)]STANDARD CONDITIONS 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The pe rmittee s hall ke ep r ecords a s s pecified i n t his pe rmit. T hese r ecords, i ncluding monitoring data and necessary support information, shall be retained on

- site or at a ne arby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel u pon request. S upport i nformation i ncludes a ll or iginal s trip

- chart r ecordings f or c ontinuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

t he permit may specify that records may be maintained in comput erized form. [OAC 252:100-8- 6 (a)(3)(B)(ii), 8 -6 (c)(1), and 8- 6 (c)(2)(B)]

B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which perf ormed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions as existing at the time of sampling or measurement. [OAC 252:100-8- 6 (a)(3)(B)(i)]

C. No later than 30 da ys after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required m onitoring. A ll i nstances of de viations f rom pe rmit requirements since the previous report shall b e clearly identified in the report. [OAC 252:100-8- 6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions. [OAC 252:100-8- 6 (a)(3)(C)(iii)]

E. In a ddition t o a ny m onitoring, r ecordkeeping or r eporting r equirement s pecified i n this permit, monitoring and reporting may be r equired unde r t he pr ovisions of O AC 252: 100 -43, Testing, Monitoring, and Recordkeep ing, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi

- annual reports required by any applicable requirement that are dupl icative of t he r eporting r equired i n the previous paragraph will s atisfy the r eporting requirements of the previous paragraph if noted on the submitted report.

G. Every report submitted under this section shall be certified by a responsible official. [OAC 252:100-8- 6 (a)(3)(C)(iv)]

H. Any ow ner or ope rator s ubject t o t he pr ovisions of N SPS s hall m aintain r ecords of the occurrence and duration of any start

- up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]STANDARD CONDITIONS 3

I. Any ow n er or ope rator s ubject t o t he pr ovisions of N SPS s hall m aintain a f ile of a ll measurements and other information required by the subpart recorded in a permanent file suitable for ins pection. T his f ile s hall be r etained for a t le ast tw o years f ollowing the date of s uch measurements, maintenance, and records. [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi

- annually. The progress reports shall cont ain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. T he progress reports shall also contain an explanation of why any dates in t he schedule of compliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8- 6 (c)(4)]

K. All t esting m ust be c onducted by m ethods a pproved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. T he permittee may request the use of alternative test methods or analysis procedures. The AQD shall approve or disapprove the request within 60 days. When a portable a nalyzer i s us ed t o m easure e missions i t s hall be setup, calibrated, and operated in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of t he “A QD P ortable A nalyzer G uidance” doc ument or an equivalent m ethod approved by Air Quality. [OAC 252:100-8-6 (a)(3)(A)(iv) and OAC 252:100-43]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, a nd 63, f or a ll e quipment c onstructed or ope rated unde r t his pe rmit subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later t han 30 days af ter each anniversary da te of t he i ssuance of t he or iginal P art 70 operating permit, the pe rmittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance w ith t he t erms a nd c onditions of t his pe rmit a nd of a ny ot her applicable r equirements w hich have be come ef fective s ince t he i ssuance of t his pe rmit. The

co mpliance certification shall a lso include s uch other f acts a s the pe rmitting a uthority ma y require to determine the compliance status of the source. [OAC 252:100-8- 6 (c)(5)(A), (C)(v), and (D)]

B. The certification shall describe the operating permit te rm or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining c ompliance, c urrently a nd ove r t he r eporting pe riod; a nd a statement that the facility will continue to comply with all applicable requirements. [OAC 252:100-8- 6 (c)(5)(C)(i)

- (iv)]

C. Any document required to be submitted in accordance with this permit shall be certified as being true, accurate, and complete by a responsible official. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. [OAC 252:100-8-5 (f) and OAC 252:100-8- 6 (c)(1)]STANDARD CONDITIONS 4

D. Any f acility reporting nonc ompliance s hall s ubmit a s chedule of c ompliance f or emissions units or s tationary s ources t hat a re not i n c ompliance w ith all applicable requirements. This schedule s hall i nclude a s chedule of r emedial m easures, including an enforceable sequ ence of actions with milestones, leading to compliance with any applicable requirements for which the emissions uni t or s tationary s ource i s i n nonc ompliance. T his c ompliance s chedule shall resemble and be at l east as s tringent as t hat cont ained in any j udicial cons ent de cree or administrative order to which the e missions uni t or s tationary s ource i s s ubject. A ny s uch schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based. Except that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8- 6 (c)(3)]

SECTION V. RE QUIREMENTS T HAT B ECOME AP PLICABLE DURI NG THE

PERMIT TERM

The permittee s hall comply w ith any additional r equirements that become effective during the permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8- 6 (c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance w ith t he t erms a nd c onditions of t his pe rmit ( including t erms and conditions established f or a lternate ope rating s cenarios, e missions t rading, a nd e missions a veraging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100- 8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8- 6 (d)(1)]

B. Those requirements that are applic able are listed in the Standard Conditions and the Specific Conditions of this permit. Those requirements that the applicant requested be determined as not applicable ar e l isted in the E valuation Memorandum and are s ummarized in the S pecific

Conditions of this permit. [OAC 252:100-8- 6 (d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD. [OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8- 6 (a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating pe rmit shall be five years from the date

of issuance. [OAC 252:100-8- 6 (a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been s ubmitted a t l east 180 da ys be fore t he da te of expiration. [OAC 252:100-8-7.1 (d)(1)]STANDARD CONDITIONS 5

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100 -8- 1.4(b)) if the construction

is not commenc ed within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a c onstruction pe rmit s hall a pply f or a pe rmit t o ope rate ( or m odi fied operating permit) within 180 days following the first day of operation. [OAC 252:100-8- 4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application of a ny pr ovision of t his permit t o a ny c ircumstance, i s he ld i nvalid, t he a pplication of s uch provision to other circumstances, and the remainder of this permit, shall not be affected thereby. [OAC 252:100-8- 6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege. [OAC 252:100-8- 6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8- 6 (c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee s hall furnish to the DEQ, upon r eceipt of a written request and within sixty (60) days of the request unless the DEQ specifies another time period, any information that the DEQ m ay r equest t o de termine w hether c ause e xists for modifying, reopening, revoking,

re issuing, terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8- 6 (a)(7)(E)]

B. The permittee may make a cl aim of confidentiality for any information or records submitted pursuant to 27A O.S. 2 -5- 105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment. [OAC 252:100-8- 6 (a) (7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall be made in writing within 10 days after such date. [ Oklahoma Clean Air Act , 27A O.S. § 2-5-112 (G)]STANDARD CONDITIONS 6

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause. Except as provided for minor permit modifications, the filing of a request by the permittee for a permit modification, revocation, reissuance, termina tion, notification of planned changes, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8- 7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source category three or m ore y ears pr ior t o t he e xpiration da te of t his pe rmit. N o s uch reopening i s required if the effective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit m ust be r evised or r evoked t o a ssure c ompliance w ith the app licable requirements. (3) The DEQ determines that inaccurate information was used in establishing the emission standards, limitations, or other conditions of this permit. The DEQ may revoke and not reissue this permit if it de termines that the permittee has submitted false or misleading information to the DEQ.

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1]

(1) It only applies to that s pecific item by s erial num ber or s ome ot her pe rmanent

identification. (2) Grandfathered status is lost if the item is s ignificantly modi fied or if it is r elocated outside the boundaries of the facility.

D. To make changes other than (1) those described in Section XV III (Operational Flexibility), (2) administrative permit amendments, a nd ( 3) t hose not de fined a s a n I nsignificant A ctivity (Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8- 6 (c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of c redentials a nd ot her doc uments a s m ay be r equired by l aw, t he permittee shall allow authorized regulatory of ficials to perform the f ollowing ( subject to the permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1 998, § 2 -5-105(18) for confidential information submitted to or obtained by the DEQ under this section):STANDARD CONDITIONS 7

(1) enter upon the permittee's pr emises dur ing r easonable/normal w orking hour s w here a

source is located or emissions

- related activity is conducted, or wh ere records must be kept under the conditions of the permit; (2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (3) inspect, at r easonable t imes and using r easonable s afety practices, any facilities, equipment ( including m onitoring a nd a ir pol lution control equipment), practices, or operations regulated or required under the permit; and (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit. [OAC 252:100-8- 6 (c)(2)]

SECTION XIV. EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall notification be more than 24 hours after the exceedance. [The degree of promptness in reporting shall be proportional to the degree of danger.] [OAC 252:100-8- 6 (a)(3)(C)(iii)(II)]

B. An " emergency" m eans a ny s ituation a rising f rom s udden a nd r easonably unf oreseeable events be yond t he c ontrol of t he s ource, i ncluding a cts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology- based emission limitation under t his pe rmit, due t o una voidable i ncreases i n emissions attributable to the emergency. [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompli ance with such technology-based emission limitation if the conditions of paragraph D below are met. [OAC 252:100-8- 6 (e)(1)]

D. The affirmative de fense of e mergency s hall be de monstrated t hrough pr operly s igned, contemporaneous operating logs or other r elevant evidence that:

(1) an emergency occurred and the pe rmittee can identify t he caus e or caus es of t he

emergency; (2) the permitted facility was at the time being properly operated; (3) during the period of the emergency the permittee took all reasonable steps to minimize levels of e missions t hat e xceeded t he e mission s tandards or ot her r equirements i n t his permit; (4) the pe rmittee s ubmitted notice of the e mergency to AQD w ithin 24 hours of the time when emission limitations were exceeded due to the emergency. This notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emissions, and corrective actions taken; and (5) the permittee submitted a follow up w ritten r eport w ithin 10 w orking da ys of f irst becoming aware of the exceedance. [OAC 252:100-8- 6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]STANDARD CONDITIONS 8

E. In any enf orcement pr oceeding, the pe rmittee s eeking t o establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8- 6 (e)(3)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and r egister w ith t he a ppropriate a gency a r isk m anagement pl an by June 20, 1999, or the applicable effective date. [OAC 252:100-8- 6 (a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units t hat a re e ither on t he l ist i n A ppendix I , or w hose a ctual calendar year emi ssions do not exceed any of the limits below. Any activity to which a State or federal applicable requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

(1) 5 tons p er year of any one criteria pollutant. (2) 2 tons per y ear f or a ny one ha zardous a ir pol lutant ( HAP) or 5 t ons pe r y ear f or a n aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish b y rule. (3) 0.6 tons per year for any one category A substance, 1.2 tons per year for any one category B substance or 6 tons per year for any one category C substance as defined in 252:100-41-

40.

SECTION XVII. TRIVIAL ACTIVITIES

Except as ot herwise pr oh ibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in the permit). When an operating scenario is changed, the permittee shall record in a log at the facility the scenario under which it is operating. [OAC 252:100-8- 6 (a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted emission rate of any existing emissions unit to be exceeded;STANDARD CONDITIONS 9

provided t hat t he f acility pr ovides t he E PA a nd t he D EQ w ith w ritten not ification as required below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for emergencies as defined in OAC 252:100 -8- 6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted fac ility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8- 6 (f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE

- ONLY REQUIREMENTS

A. The following a pplicable r equirements a nd s tate

- only r equirements a pply to the f acility unless elsewhere covered by a more restrictive requirement:

(1) No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] (2) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning Subchapter. [OAC 252:100-13] (3) No particulate emissions from any fuel

- burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19] (4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60, NSPS, no discharge of g reater t han 20% opa city i s a llowed e xcept f or s hort

- term
occurrences which consist of not more than one six

- minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six -minute period exceed 60% opacity. [OAC 252:100-25] (5) No visible fugitive dust emissions shall be discharged beyond the property lin e on which the emissions or iginate i n s uch a m anner a s t o da mage or t o i nterfere w ith t he us e of adjacent properties, or caus e ai r qua lity s tandards t o be ex ceeded, or i nterfere w ith the maintenance of air quality standards. [OAC 252:100-29] (6) No sulfur ox id e em issions from new gas

- fired fuel

- burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31] (7) Volatile O rganic C ompound ( VOC) s torage t anks bui lt a fter December 24, 1 974, a nd with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor- recovery system. [OAC 252:100-37-15(b)] (8) All f uel -bu rning e quipment s hall a t a ll t imes be pr operly ope rated a nd m aintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36] (9) Except as otherwise provided, no person shall cause or permit the emissions of any toxic

air c ontaminant i n s uch c oncentration a s t o c ause or t o c ontribute t o a violation of the

MAAC. (State only) [OAC 252:100-41]STANDARD CONDITIONS 10

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of ozone- deplet ing s

1. P ersons pr oducing, i mporting, or pl acing a n or der f or pr oduction or importation of certain class I and class II substances, HCFC

- 22, or HCFC

- 141b shall be subject to the requirements of §82.4. 2. P roducers, i mporters, e xporters, pur chasers, a nd pe rsons w ho t ransform or de stroy certain class I and class II s ubstances, HCFC

- 22, or H CFC

- 141b a re s ubject t o t he recordkeeping requirements at §82.13. 3. Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon t etrachloride, t richloroethane ( methyl c hloroform), a nd bromomethane ( Methyl B romide). C lass I I s ubstances ( listed a t Appendix B to Subpart A) include HCFCs.

B. If t he permittee performs a s ervice on motor (fleet) vehi cles when this service involves an

ozone- depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is s ubject to all a pplicable r equirements. N ote: T he te rm

“motor vehicle” as used in Su bpart B does not include a vehicle in which final assembly of the vehicle has not been completed. T he term “MVAC” as used in Subpart B does not include the

air

- tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC- 22 refrigerant. [40 CFR 82, Subpart B]

C. The pe rmittee s hall c omply w ith the f ollowing s tandards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F]

(1) Persons ope ning a ppliances f or m ain tenance, service, r epair, or di sposal m ust c omply with the required practices pursuant to § 82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to § 82.158. (3) Persons performing maintenance, service, repair, or di sposal of a ppliances m ust be certified by an approved technician certification program pursuant to § 82.161. (4) Persons disposing of small appliances, MVACs, and MVAC

- like appliances must c omply

with record -keeping requirements pursuant to § 82.166. (5) Persons ow ning c ommercial or i ndustrial pr ocess r efrigeration equipment must comply with leak repair requirements pursuant to § 82.158. (6) Owners/operators of a ppliances nor mally c ontaining 50 or m ore pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.STANDARD CONDITIONS 11



### SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not inconsistent w ith F ederal r equirements, t o pr ovide f or i ncorporation of r equirements established through construction permitting into t he S ources’ T itle V pe rmit w ithout c ausing redundant review. Requirements from construction permits may be incor porated into the Title V permit through the a dministrative a mendment pr ocess s et f orth in Oklahoma A dministrative Code 252:100-8-7.2(a) only if the following procedures are followed:

(1) The c onstruction pe rmit g oes out f or a 30

- day public not ice a nd c omment us ing t he procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice shall include n otice to th e p ublic th at th is p ermit is s ubject to E nvironmental P rotection Agency (EPA) review, EPA objection, and petition to EPA, as provided by 40 C FR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through t he a dministrative a mendment pr ocess; t hat t he public will not receive another opportunity t o pr ovide c omments w hen the r equirements a re i ncorporated i nto t he T itle V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from t he c onstruction pe rmit a re i ncorporated i nto t he T itle V permit. (2) A copy of the co nstruction permit application is sent to EPA, as provided by 40 C FR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR § 70.8(b). (4) A copy of the proposed construction permit is sent to EPA for a 45

- day review period as provided by 40 CFR § 70.8(a) and (c). (5) The DEQ complies with 40 C FR § 70.8 ( c) upon t he written receipt within the 45

- day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit unti l EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 CFR § 70.8 (d). (7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a). (8) The D EQ s hall not i ssue t he pr oposed c onstruction pe rmit until any affected State and EPA ha ve ha d a n oppor tunity t o r eview t he pr oposed pe rmit, as provided by these permit

conditions. (9) Any r equirements of t he c onstruction pe rmit m ay be r eopened f or c ause a fter incorporation in to th e T itle V permit by th e administrative am endment process, by DEQ as provided in OAC 252:100 -8- 7.3 (a), (b), and (c), and by EPA as provided in 40 CFR § 70.7 (f) and (g). (10) The DEQ shall not issue the administrative permit amendment if performance tests fail to

demonstrate th at the source is o perating in s ubstantial c ompliance w ith a ll p ermit requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.STANDARD CONDITIONS 12

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall preclude the us e, i ncluding t he e xclusive us e, of a ny c redible e vidence or i nformation, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

MEMORANDUM June 12 , 2006

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality

THROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits Section

THROUGH: Peer Review, Davi d Pollard, ROAT

FROM: Herb Neumann, ROAT

SUBJECT: Evaluation of Construction Permit Application No. 99-113- C (M -4) (PSD) Fort James Operating Company – Muskogee Mill 4901 Chandler Road, Muskogee Section 33 & W1/2 Section 34, T15N, R19E Muskogee County , OK Driving directions: Muskogee Turnpike to Chandler exit, east to 45 th Street, south to Harold Abitz Drive, east into facility.

SECTION I. INTRODUCTION

Applicant received c onstruction pe rmit N o. 99 -113- C(M

- 3)(PSD) for t he M ill P rocess Improvemen t P roject, i ssued M arch 27, 2006. T he applicant has requested clarification of several conditions of the permit, as presented at the end of this Introduction. These clarifications do not relax any permit conditions, do not authorize additional emitting equipment, and do not increase permitted emission amounts. All requested c hanges t o t he S pecific C onditions ha ve been made, although the e xact l anguage m ay va ry s lightly f rom t hat r equested. W ith t he exception of the material at the end of the Introductio n, the balance of this Memorandum remains unchanged. The mill is an existing major manufacturer and converter of sanitary paper products such as tissue, napkins, and paper towels (SIC 2621). A uxiliary operations include flexographic printing, platemaking, and production polyethylene film wrap for the paper products.

DEQ r eceived a n a pplication f or a P art 70 P ermit on M arch 5, 1999. A draft permit was prepared and was made available for public comment. The only comments received were those

of the facili ty . A fter extensive review, a proposed permit commenced review by EPA Region 6 on December 16, 2005 . Until the Part 70 permit is issued, the facility operates under a number of DEQ and EPA permits, w here “ DEQ” i ncludes pe rmits i ssued by t he O klahoma S tat e Department of Health, predecessor agency to DEQ. T he following table lists these permits, but does not detail their contents, because that information is available in the pending Part 70 permit. Note that an operating permit has not be en i ssued f or one c onstruction pe rmit, be cause t he operating pe rmit a pplica tion was w ithdrawn a fter s ubmittal of t he P art 70 a pplication, which included the equipment authorized by the construction permit.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 2

75

- 053

- O PSD

- OK

- 404 (M

- 1) 79

- 021

- O

77

- 076

- O 81

- 081

- O 81

- 066

- O

97

- 218

- C 83

- 062

- PSD 91

- 127

- O (M

- 1)

Applicability Determination 99-113- AD was issued June 7, 2002, to correct the factors used in certain emission calculations to bring them in to agreement with current AP -42 numbers.

The current application is styled as a Mill Process Improvement Project. The project will affect three areas of the plant and is intended to improve energy efficiency, to allow for papermaking with l ower g rades of w astepaper, a nd t o r educe dependence on outside vendors of packaging

materi al. The three areas affected are the paper machine and converting area, the polyethylene plant, and the System 5 Pulp area. Increased emissions from this project are expected to trigger Prevention of S ignificant D eterioration (PSD) s ignificance le vels, r equiring T ier I I pe rmitting and BACT analysis. These issues w ill be di scussed a t a ppropriate poi nts i n t he f ollowing

sections of this Memorandum.

SECTION II. PROCESS DESCRIPTION

The facility is a major manufacturer and converter of sanitary paper p roducts, i.e., they make parent rolls and they also make finished products such as tissue, napkins, and paper towels. Many of these products are printed with decorative i nks dur ing t he c onverting pr ocess. T he m ain pr ocesses involved i n pa permaking a re pu lping, de

- inking ( bleaching out t he i nks i n t he r ecycled pa per), paper production, and printing. The company’s basic raw material for wet papermaking is currently recycled wastepaper and a small amount of purchased pulp, which is processed into pulp using a proprietary process. The facility typically recycles over a thousand tons of wastepaper per day. A complete description of the processes used may be found in the memorandum associated with the pending P art 70 pe rmit, s o t he di scussion i n t his s ection will address only those portions of the process affected by the current project.

Pulping and Pulp Processing The derivation, rationale, and technical justification for the emission calculations are presented in the section for emissions. F ollowing is a list of functions performed in the pulping process and equipment used to perform each.

Converting wastepaper to a pulp slurry, using mechanical agitation and water

- Pulpers. Pulp blending

- Stock Blend Tank. Mixing the pulp slurry with process water, dilu tion water, chemicals, etc.

– Mixer. Providing residence time to allow the bleach medium to react with the pulp slurry

- Bleach Towers. Separating s olid c ontaminants f rom t he pul p s lurry

– Screens, Washers, Flotation C ell W ashers,

Cleaners. Dewatering the p ulp slurry and increasing consistency

- Stock Presses. Increasing pulp slurry consistency

- Thickeners.

The pulping and pulp processing systems process and bleach wastepaper for use in the manufacture of tissue, towel, and napkin paper. This proprietary process uses bleaching agents on most grades of paper. Recycled wastepaper is re

- pulped by physical and chemical processes into a pulp slurry toPERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 3

recover usable fiber, blended with various de

- inking and bleaching compounds, and processed into paper stock to make the paper products. At the pulpers, recycled wastepaper is blended with hot water while mechanical agitation is used to convert the mixture into pulp slurry. Generally, t he incoming slurry is screened to remove debris and impurities. Contaminants are removed in this step, as well. A dditional contaminant removal is accomplished by means of processes performed by other equipment described above. B leaching agents are added to the slurry for the purpose of increasing brightness. T he facility uses n o chlorine or chlorine dioxide to bleach pulp. B leached pulp is stored in storage tanks for later use on pa per machines to make paper. V OCs and organic pollutants are released during pulp processing as a result of chemical and mechanical processes.

The facility h as f ive s ystems f or th is p rocess. A ll s ystems are similar in design and operation, although t hey a re c apable of us ing di ffering t ypes of bleaching agents or other chemicals. An extensive di scussion of t he e ffect of s uch ope rating va riability i s found i n t he Memorandum associated with the pending Part 70 pe rmit and there will be further discussion in the Emissions section of t his m emorandum. O nly S ystem 5 i s a ffected by t he c urrent pr oject, a nd only non

emitting components will be physically alt ered. F or instance, existing items, such as wastepaper handling equipment, pumps, rotors, screens, and cleaners may be upgraded, new items, such as a clarifier, a washer, and a fiber recovery unit may be added, and certain other units, such as presses,

wa shers, flotation cells, or thickeners may be added or upgraded. None of these proposed changes affects the design capacity of System 5, but they are expected to enable it to perform closer to that capacity.

Paper Production The processed secondary pulp fiber is pumped to the paper machines, PM

- 11, PM

- 12, PM

- 13, PM

14, and PM

- 15, where the “parent” rolls are produced. P arent rolls are large continuous rolls of paper that are slit into narrower rolls for further handling. At this facility a roll can be as wide as

273 **′′** , or nearly 23 **′** . Water is removed from the incoming pulp stock by a screen. The pulp is then sprayed onto a belt where a vacuum is pulled from below to remove additional water. R esidual moisture i s r emoved f rom t he pr oduced pa per a s i t i s dr ied i n f uel

- burning hoods a nd/or i n the Yankee Dryers by steam. T hese drying processes result in emissions of VOCs from the pulp and paper. All hoods will be modified to provide more efficient flow and heating and new burners will

be installed in all ma chines except PM

- 15. T he burners to be installed will use natural gas, with propane as an alternate. The boilers providing steam combust coal and/or natural gas. PM

- 11, 12,

and 13 ha ve after

- dryers that use steam from the power plant. T he nature and qu antity of process and c ombustion e missions w ill be a ddressed i n t he E missions section following. Much of the parent roll paper is slit into product r olls a nd c onverted t o f inished pr oduct a t t he f acility. Following is a description of each paper machine.

PM

- 11 is a 209

- inch, wet crepe/dry crepe t win

- wire periformer, manufactured by KMW, with a suction forming r oll, s ingle

- felted pr ess s ection, t wo pr essure r olls, a n 18

- foot Y ankee dr yer equipped with two 24 M MBTUH gas

- fired hoods, and five after

- dryers. The current project will replace the burners with new burners rated as high as 70 MMBTUH total. The stock system is conventional, utilizing a dr um s ave

- all f or f iber r ecovery an d an ai r f lotation cl arifier f or w ater recycling.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 4

PM

- 12 is a 209

- inch, w et c repe t win

- wire pe riformer, m anufactured by K MW, w ith a s uction forming roll, single

- felted press section, two pressure rolls, an 18

- foot Yankee dryer equipped with two 16.5 MMBTUH gas

- fired hoods, and fourteen after

- dryers. The current project will replace the burners with new burners rated as high as 70 M MBTUH total. T he stock system is conventional, utilizing a drum save

- all for fiber recovery and an air flotation clarifier for water recycling.

PM

- 13 is a 209

- inch, wet crepe/dry crepe S

- wrap twin

- wire periformer, manufactured by KMW, with a solid forming roll, single

- felted press section, two pressure rolls, an 18

- foot Yankee dryer equipped with two burners rated at 16.5 M MBTUH gas

- fired hoods, and eight after

- dryers. The current project may replace th e burners with new burners rated as high as 70 MMBTUH total. The stock s ystem i s c onventional, ut ilizing a dr um s ave

- all f or f iber r ecovery a nd a n a ir flotation clarifier for water recycling.

PM

- 14 is a 271

- inch, dry crepe twin

- wire periformer, manufactu red by Beloit, with a solid forming roll, single

- felted press section, two pressure rolls, and an 18

- foot Yankee dryer equipped with two 24 MMBTUH gas

- fired hoods. The current project will replace the burners with new burners rated as high as 70 MMBTUH to tal. The stock system is conventional, utilizing a drum save

- all for fiber recovery and an air flotation clarifier for water recycling.

PM

- 15 is a 273

- inch, dry crepe twin

- wire periformer, manufactured by Beloit, with a solid forming roll, single

- felted press section, two pressure rolls, and an 18

- foot Yankee dryer equipped with two 25 MMBTUH gas

- fired hoods and high temperature hot water. The stock system is conventional, utilizing a disc save

- all for fiber recovery and an air flotation clarifier for wa ter recycling.

A table identified as “ Process F low

– Paper Machines” in the pending Part 70 summarizes the equipment used in each system line and the point of entry in the process for additives in the order they are utilized. It also identifies the emiss ion units that were tested by The National Council for Air and Stream Improvement ( NCASI) in an industry

- wide study of emissions from such facilities. The lengthy table is not duplicated here.

Solvent Cleaning of Paper Machines Cleanup solvent is pumped from tanks or totes to paper machines PM

- 11, PM

- 12, PM

- 13, PM

- 14,

and PM

- 15 for application on the machine clothing (felts and wires). The purpose of this cleanup is to rid the machine c lothing of a ny c ontaminants, c ommonly know n a s s tickies, w hich m ay be deposited from the paper stock going to the machines. These contaminants would adversely affect product from the machine by forming small holes or creating inconsistencies in the paper if not cleaned r egularly. A dditionally, s maller a mounts of s olvent a r e u sed o ccasionally f or cl eaning equipment at the pulp processing mill, PP

- 1. N o physical changes or changes in the method of operation are proposed for the current project. Emissions of VOC authorized in the pending Part 70 permit do not require adjusti ng.

Flexographic Paper Printing Designs are printed on the tissue products by flexographic paper printer systems FP

- 1, FP

- 7, and

FP

- 8. These systems use water

- based inks for printing. Because the project should increase parent roll production, it is reasonable to assume that more printed product will be manufactured, but the current project proposes no physical or operational changes in this area.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 5

FP -1 consists of six flexographic printing presses that print paper parent rolls to produce printed

parent rolls. These printed parent rolls become paper towel and napkin products.

FP -7 is a 101.5

- inch, four color, in

- line flexographic printing press and re

- winder that also prints paper parent rolls to produce printed towel products at the end of the unit.

FP-8 is a 4

- color, 78

- inch wide, flexographic printing press, manufactured by Bretting. I t was custom built and has no number. This unit was proposed for addition during the Part 70 permit

review and was installed in June 2005.

Polyethylene Extruding and Flexographic Printing (polyethylene film) The pol yethylene e xtruder, t he plate

- making r oom, a nd t he f lexographic pr inting r oom a re a ll housed in the Poly Plant Building.

Flexo

- plate making is conducted in the plate

- making room. The plates are produced for use with all of the mill plant’s flexographic printers. VOC

- containing solvents are used in the finishing step of plate

- making. V OC emissions from a plate washing process are discharged from the building through a hor izontal ve nt. A s maller a mount of fugitives l eave t he r oom t hrough two door openings i nto t he P oly P lant bui lding. T he P oly P lant building has numerous vents, the most prominent being three 5’ x 5’ exhaust vents down the center

- line peak of the building roof. These vents have hinged

- fla p rain caps that result in somewhat of a horizontal discharge. S ome of the solvent is recovered and recycled. A proposed second plate washer will use in

- line cleaning and

minimize the emissions of solvent.

PO -1 is t he de signation of t he pol yethylene e xtruding pl ant. T he pa per pr oducts are ultimately wrapped with polyethylene over

- wrap and other materials, packaged, and distributed to customers.

Plastic o ver

- wrap i s pr oduced on

- site f rom t he pol yethylene a nd e xtruding pl ant. Polyethylene pellets, s tored in silos, are pneumatically conveyed t o t he e xtruder. T he e xtruder pr oduces a polyethylene tube which is elongated by take

- off nip rollers, air cooled, solidified, passed through a corona t reater, a nd w ound ont o t akeoff r olls. O zone generated in the cor ona t reating process i s discharged through a horizontal vent. Once a full roll is produced, it is taken from the takeoff roll, rewound into rolls of unprinted polyethylene film, and stored in the same building until needed for printing. The current proje ct will add three new extruders, each with a corona treater.

Flexographic printing of the polyethylene film is conducted in the flexographic printing room. The polyethylene rolls are fed into a six

- color, central impression flexographic printing press and dried through the tunnel dryer to produce printed parent rolls of polyethylene film. A catalytic

oxidizer c ontrols V OC e missions. T he f inished r olls a re s tored a nd t ransferred t o locations within t he f acility w here t he pr oduct m ay be ne eded. T he c urren t pr oject w ill a dd three new presses and replace the catalytic ox idizer w ith a l arger t hermal ox idizer, because t he cat alytic oxidizer will be too small to handle the increased printing load. A complete enclosure will be constructed around all four presses and negative pressure maintained, resulting in 100% capture

of all VOC.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 6

Steam and Electricity Co

- generation (power plant) The facility has a power plant utilizing four boilers, identified as emission units B

- 1, B

- 2, B

- 3, and

B- 4, which co

- generate most of the electrical and steam needs of the facility. T hey are fueled by coal and natural gas. The ash residue generated from this operation is landfilled in an approved on

site landfill. Opacity of the boiler emissions is monitored continuously and recorded on strip charts. Following is a description of each boiler.

B-1 is primarily a natural gas

- fired package boiler rated at 310 M MBTUH. I t shares a common

stack with boiler B

- 2.

B-2 is p rimarily a p ulverized coal

- fired boi ler r ated a t 440 M MBTUH. I t i s capable o f f iring natural gas as a backup fuel. It uses an electrostatic precipitator for particulate control and shares a

common stack with boiler B

- 1.

B-3 is primarily a pulverized coal

- fired boiler rated at 557.11 MMBTUH. I t is capable of firing

nat ural gas as a backup fuel. It uses a baghouse for particulate control and shares a common stack

with boiler B

- 4.

B-4 is primarily a pulverized coal

- fired boiler rated at 557.11 MMBTUH. I t is capable of firing natural gas as a backup fuel. It uses a bag house for particulate control and shares a common stack

with boiler B

- 3.

Coal Preparation Plant The coal preparation plant supplies t he boi lers w ith pul verized c oal f uel. A ll e mission uni ts except t he c oal pi le a re s ubject t o t he pr ovisions of 40 CFR 60, Subpart Y, (Coal Preparation Plants). More detail on the applicability criteria is found in the NSPS discussion of Section VIII of t he m emorandum a ssociated w ith t he pe nding P art 70 pe rmit. The current project will not affect the applicability of any ru le or regulation pertaining to the use or handling of coal. Also, the current project will not cause physical or operational changes in any of these processes.

SECTION III. EQUIPMENT

The following tables list those Emission Units (EUs) at the facili ty that contribute to a process that generates significant emissions. T he t ables ar e categorized b y Emission U nit G roups (EUGs), based on the type of emission and/or an applicable rule. The application states that the

date of construction is either the a pproximate date the company commenced construction of the particular process, or the date of t he l ast m odification of t he pr ocess f or w hich t he c ompany obtained an air permit under laws existing at that time. Only those EUGs or portions of EUGs

affected b y the current project are listed. Additional details may be found in the Memorandum associated with the pending Part 70 permit.

EUG 1

– Subpart D Boilers This EUG includes boilers that are subject to 40 C FR 60, S ubpart D (Fossil

- Fuel

- Fired Steam

Generato rs for Which Construction is Commenced After August 17, 1971).PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 7

Subpart D Boilers

EU

ID Boiler Manufacturer Boiler Rating

MMBTUH Burner Model Construct

Date

B

- 1 Zurn Industries, Inc. 310 Keystone SAOH

- MJ

- DAR

- 48 1975

B

- 2 Babcock & Wilcox Company 440 BW

- 24 089 1975

B

- 3 Combustion Engineering, Inc. 557.11 VU -40 1978

B

- 4 Riley Stoker 557.11 RX Turbofurnace 1981

EUG 2

– Combustion Sources Not Subject to NSPS or NESHAP This EUG includes e mission uni ts t hat ha ve c ombustion e missions, but a re not s ubject t o a n NSPS or a NESHAP performance standard. P O

- 1, the catalytic oxidizer, will be replaced by a regenerative thermal ox idizer (RTO). PM

- 11, 12, 13, and 14 will have their burners replaced. The f irst ta ble f ollowing ide ntifies e xisting e quipment, while the sec ond t able de scribes t he changes to be made to the emission source within the unit.

Existing Units

EU ID EU Name Model # Const. Date

PM

- 11 Paper Machine #11 Kinedizer 27M 1975

PM

- 12 Paper Machine #12 Oven

- Pak EB6 Model 400 1975

PM

- 13 Paper Machine #13 O ven

- Pak EB6 Model 400 1979

PM

- 14 Paper Machine #14 Combustifume 1981

PM

- 15 Paper Machine #15 LV

- 85 1992

PO

- 1 Printing Press Tunnel Dryer Oven

- Pak EB3 1983

PO

- 1 Catalytic Oxidizing Incinerator HXC II

- 400 1983

DG

- 1 Emergency Generator Marathon Electri c, Magna One 1982

DG

- 2 Emergency Generator Marathon Electric, Magna One 1982

Proposed Changes

EU ID Burners and Heat Input Rating Existing Proposed

PM

- 11 2 @ 24 MMBTUH each 2 @ 35 MMBTUH each

PM

- 12 2 @ 16.5 MMBTUH each 2 @ 35 MMBTUH each

PM

- 13 2 @ 16.5 MMBTUH each 2 @ 35 MMBTUH each

PM

- 14 2 @ 24 MMBTUH each 2 @ 35 MMBTUH each

PO -1* 2 MMBTUH 10.4 MMBTUH * Catalytic oxidizer to be replaced by regenerative thermal oxidizer.

EUG 3 – Subpart Y Coal Preparation Plant The Coal Preparation Plant, includ ing all emission units, such as coal processing and conveying equipment and coal storage systems, is subject to the provisions of 40 CFR 60, Subpart Y, which affects coal preparation plants that process more than 200 t ons per day. T he coal storage pile

, i ncluding railcar unloading and s tacking e quipment l eading t o t he pi le

, are not s ubject t o t his rule, and are not included in this EUG. T he detailed equipment list found in the Memorandum associated with the pending Part 70 pe rmit is not repeated here, bec ause t here are no physicalPERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 8

changes or changes in the method of operation. Increased use of coal as boiler fuel is possible, but this does not affect the equipment.

EUG 4

– PP

- 1 Pulp Processing Units (Subpart S Affected/No Applicable Standards)

Process un its in this EUG emit VOC from bleaching and pulping operations. Some of these units are affected processes under 40 CFR 63, Subpart S (Pulp and Paper Industry). The facility uses secondary wood (recycled paper) fiber and is therefore an affected facility , but is not subject to any performance standard or other requirements at this time because of the sort of processes and type of bleaching agents currently used in producing the secondary fiber pulp. T herefore, this EUG i s r eserved f or a ny f uture S ubpart S r egulated uni ts. E missions f rom the se uni ts a re included with those for EUG 6. The current project is expected to add or modify several items as identified by a 2006 construction date in the following table, without altering the applicability of any MA CT requirements . The bulk of these changes will occur in System 5.

Pulp Processing Units

EU Name Construction Date Pulpers (not system specific) 1977, 1979, 1981, 1983, 1992, est.

Unbleached Stock Blend Tanks 1977 & 1983, est.

Screens 1977, 1979, 1981 , 1983, & 1992, est., 2006

Unbleached Washers 1977, est., 2006

Flotation Cell Washers 1977, 1979, 1981, 1983, & 1992, est., 2006

Unbleached Thickener 1977 & 1992, est.

Bleached Washers 1977, 1981, 1983, 1992, est., 2006 Storage (not system specific) 1 977, 1979, 1981, 1983, 1992 est.

Bleach Towers 1977, 1979, 1981, 1983, 1992, est.

Thickeners 1979, 1981, 1983, est., 2006

Unbleached Stock Presses 1992, est., 2006

Mixers 1992, est.

Cleaners 1992, est., 2006

EUG 5

– Subpart KK Flexographic Printing This EUG includes emission units such as flexographic printing presses and auxiliary equipment that are subject to 40 C FR 63, S ubpart KK (Printing and Publishing Industry). N o equipment will be modified, but three additional polyethylene printers will be added by the current project.

EUG 5

– Subpart KK Flexographic Printing

EU

ID EU Name Manufacturer/Model No. Const.

Date

PO -1 Polyethylene Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer 6 /84

Polyethylene Printer 2 Make/model N/A, but similar to that listed above. 2005 Polyethylene Printer 3 Polyethylene Printer 4

FP -1 Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724

Flexo 31-001 – Fort Howard

Flexo 31

- 002

– Fort Howard 1983

1980

1980PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 9

F lexo 31

- 003

– Fort Howard

Flexo 31-005 – PCMC/Model No. 6992

Flexo 31

- 008

– PCMC/Model No. 7416 1980

1990

1993

FP

- 7 Paper Printer Flexo #7

– PCMC/Model No. 6726 1997

FP

- 8 Paper Printer Flexo #8

– Bretting 4

- color 78 **′′** wide 6/05PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 10

EUG 6 – V OC Sources Not Subject to a NSPS or NESHAP This EUG includes emission units that are subject to a VOC limit or may potentially be subject

to OAC 252:100

- 42. It includes units having VOC or HAP emissions that are part of the paper making pr ocess, but not s ubject t o 40 C FR 63 S ubpart S , uni ts not s ubject to a n NSPS or NESHAP pe rformance s tandard , a nd uni ts s ubject t o a n NSPS or N ESHAP pe rformance standard but e mitting V OC pol lutants not c overed by t he s tandard ( such a s the flexographic printers).

EUG 6

– VO C Sources Not Subject to a NSPS or NESHAP

EU ID EU Name Manufacturer/Model/Serial # Const. Date

PP

- 1 Pulp Processing Units Components listed in EUG 4 197 5

- 1992

PM

- 11 Paper Machine #11 KMW 1975

PM

- 12 Paper Machine #12 KMW 1975

PM

- 13 Paper Machine #13 KM W 1979

PM

- 14 Paper Machine #14 Beloit 1981

PM

- 15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA

SC

- 1 Solvent Cleaning of PM

- 11,

PM

- 12, PM

- 13, and PM

- 14 NA 1975

PM

- 15 Solvent Cleaning NA 1992

PO

- 1 Flexo

- plate making Anderson

- Vreeland June, 1984 Flexographic Polyethylene

Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color, w/ vapor collection hood and tunnel dryer June, 1984

Polyethylene Printers (3) Similar to above (proposed) 2005

FP

- 1 Flexographic Paper Printers (six) Flexo 21

- 182

– PCMC/ Model No. 6724

Flexo 31-001 – Fort Howard

Flexo 31-002 – Fort Howard

Flexo 31-003 – Fort Howard

Flexo 31-005 – PCMC/Model No. 6992

Flexo 31

- 008

– PCMC/Model No. 7416 1983

1980

1980

1980

1990

1993

FP

- 7 Flexographic Paper Printer Flexo #7

– PCMC/Model No. 6726 1997

FP

- 8 Flexographic Paper Printer Bretting 4

- color, 7 8” wide 6/05

EUG 7

– Non

- Combustion PM Sources Not Subject to NSPS or NESHAP This EUG includes emission units that ha ve pa rticulate pr ocess e missions not r esulting from combustion, and that are not subject to an NSPS or a NESHAP performance standard.

Non

- Combustion PM Sources

EU ID EU Name Manufacturer/Serial # Construct Date

FS 1 Coal Pile NA 1975

PM

- 11 Paper Machine #11 KMW 1975

PM

- 12 Paper Machine #12 KMW 1975

PM -13 Paper Machine #13 KMW 1979

PM

- 14 Paper Machine #14 Beloit 1981

PM

- 15 Paper Machine #15 Beloit 1992PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 11

SECTION IV. EMISSIONS

This section will review calculated potential emissions f or th ose E UGs a ffected b y th e c urrent project. Actual emissio ns for each EUG will also be stated, but analysis of the increase or decrease

will be deferred to Section VIII (Federal Regulations). Nominal capacity of the plant is 1,476

air

- dried tons of paper per day (ADT) and the system design capacity is 205,381 tons per year of

oven- dried finished stock (ODTP). The 2002

- 2003 average has been 948 ADT and the decrease in qua lity of w astepaper ha s de pressed t he pl ant’s c urrent t hroughput t o 114,766 O DTP. T he facility bases its calculations on t he high end of the ADT, using 1,476 A DT as a standard for calculating potential to emit (PTE). The facility expects a realistic increase in annual production of 36,500 ODTP, leaving annual production well below the 205,381 ODTP design rate.

EUG 1

– Subpart D Boilers

The f ol lowing tables condense information available in t he m emorandum a ssociated w ith t he pending Part 70 permit. Fuel o il data is excluded here, since the facility states that it no longer has the ability to burn oil. There are no changes contemplated for thes e boilers and these tables will not be used to support analysis of PSD significance.

Boiler Descriptions

EU

ID Rating (MMBTUH) Firing Configuration Controls Low

NO X Fuels

B

- 1 310 Forced Draft Package None No Gas

B

- 2 440 Wall Fired Electrostatic Precipit ator No Coal/Gas

B

- 3 557.11 Tilting Tangential Baghouse Filter No Coal/Gas

B

- 4 557.11 Wall Fired, Opposing Walls Baghouse Filter Yes Coal/Gas

Boiler Emission Calculations (TPY)

COAL NATURAL GAS

Emissions Factor Emissions Emissions Factor Emission sB-1: 310 MMBTUH PM NA NA 7.6 lbs/MMCF (4) 12.4 (1)

NO NA X NA 0.115 lbs/MMBTU (3) 187 (1)

SO 2 NA NA 0.6 lbs/MMCF (4) 0.98 (1)

VOC NA NA 5.5 lbs/MMCF (4) 8.96 (1)

CO NA NA 84 lbs/MMCF (4) 137 (1)

HCl NA NA NA NA

H 2 SO 4 NA NA NA NA

HF NA NA NA NAB-2: 440(9) PM (Hi Btu Coal) 0.032 lbs/MMBTU (3) 74.0 (1) 7.6 lbs/MMCF (4),(5) 0.18 (1) PM (Lo Btu Coal) 0.027 lbs/MMBTU (3) 62.4 (1)

NO X 0.43 lbs/MMBTU (3) (Hi Btu Coal) 994 (1) 190 lbs/MMCF (6) 366 NO X (Lo Btu Coal) 0.319 lbs/MMBTU (3) 738 (1)

SO 2 (Hi Btu Coal) 0.644 lbs/MMBTU (3) 1,489 (1) 0.6 lbs/MMCF (4) 1.39 (1) SO 2 0.267 lbs/MMBTU (3) (Lo Btu Coal) 617 (1)
VOC (Hi Btu Coal) 0.075 lbs/MMBTU (3) 173 (1) 5.5 lbs/MMCF (4),(1) 12.7 (1) VOC (Lo Btu Coal) 0.002 lbs/MMBTU (3) 4.63 (1)PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 12

COAL NATURAL GAS

Emissions Factor Emissions Emissions Factor Emission s CO (Hi Btu Coal) 0.022 lbs/MMBTU (3) 50.9 (1) 84 lbs/MMCF (1), (6) 194 (1) CO (Lo Btu Coal) 0.004 lbs/MMBTU (3) 9.25 (1)
HCl (Hi Btu Coal) 0.012 lbs/MMBTU (3) 27.8 (1) NA NA HCl (Lo Btu Coal) 0.003 lbs/MMBTU (3) 6.94 (1)

H 2 SO 4 (Hi Btu Coal) 0.00 1 lbs/MMBTU (3) 2.31 (1) NA NA H 2 SO 4 (Lo Btu Coal) 0.017 lbs/MMBTU (3) 39.3 (1)
HF (Hi Btu Coal) 0.006 lbs/MMBTU (3) 13.9 (1) NA NA HF (Lo Btu Coal) 0.001 lbs/MMBTU (3) 2.31 (1)B-3: 557 MMBTUH PM 0.005 lbs/MMBTU (3) 14.6 (1) 7.6 lbs/MMCF (4),(7 ) 0.09 (1)

NO 0.224 lbs/MMBTU (3)
X 656 (1) 170 lbs/MMCF (6) 456 (2)

SO 2 0.403 lbs/MMBTU (3) 1,180 (1) 0.6 lbs/MMCF (4) 1.76 (1)

VOC 0.001 lbs/MMBTU (3) 2.93 (1) 5.5 lbs/MMCF (4) 16.1 (1)

CO 0.003 lbs/MMBTU (3) 8.78 (1) 24 lbs/MMCF (6) 70.3 (1)

HCl 0.03 l bs/MMBTU (3) 87.8 (1) NA NA

H 2 SO 4 0.003 lbs/MMBTU (3) 8.78 (1) NA NA

HF 0.001 lbs/MMBTU (3) 2.93 (1) NA NAB-4: 557 MMBTUH PM 0.015 lbs/MMBTU (3) 43.9 (1) 7.6 lbs/MMCF (4),(8) 0.18 (1)

NO 0.339 lbs/MMBTU (3)
X 992 (1) 190 lbs/MMCF (6) 464

SO 2 0.631 lbs/MMBTU (3) 1,847 (1) 0.6 lbs/MMCF (4) 1.76 (1)

VOC 0.001 lbs/MMBTU (3) 2.93 (1) 5.5 lbs/MMCF (4) 13.4

CO 0.012 lbs/MMBTU (3) 35.1 (1) 84 lbs/MMCF (6) 205

HCl 0.033 lbs/MMBTU (3) 96.6 (1) NA NA

H 2 SO 4 0.004 lbs/MMBTU (3) 11.7 (1) NA NA

HF 0.001 lbs/MMB TU (3) 2.93 (1) NA NA (1) 20% contingency added (2) 10% contingency added (3) Stack tests conducted in June 1980 for Boiler B -1, on January 7, 8, 9, 2003, for B-2 (High Btu coal), May 16 & 17, 2003, f or B

- 2 (Low Btu coal), May 20 & 21, 2003, f or B

- 3, and April 15 & 16, 2003, for B-4. (4) Table 1.4-2 of AP-42 (7/98) (5) ESP efficiency of 99% (6) Table 1.4-1 of AP-42 (7/98) (7) Baghouse efficiency of 99.60% (8) Baghouse efficiency of 99.20% (9) Low BTU coal is sub -bituminous and high BTU coal is bituminous.

Worst- case PTE Summary for Boilers

PM NO SO 2 X VOC CO HCl H 2 SO 4 HF

B

- 1 (2) 12.4 187 0.98 8.96 137 NA NA NA

B

- 2 (1) 74.0 994 1,489 173 194 (2) 27.8 39.3 13.9

B

- 3 (1) 14.6 656 1,180 16.1 (2) 70.3 (2) 87.8 8.78 2.93

B

- 4 (1) 43.9 992 1,847 13.4 (2) 205 (2) 96.6 11.7 2.93

Total 145 2,829 4,517 211 606 212 59.8 19.8 (1) – Coal fired emissions, unless noted otherwise (2)

– Natural gas fired emissions, unless noted otherwisePERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 13

Establishing the a ctual

- to

- potential increase in emissions for P SD a nalysis is di fficult w i th respect to the boilers. Since the drying operations have several options available, heat for drying may come from the hood burners, from hot water, or from steam. As will be seen at a later point in this memorandum, the full actual

- to

- potential emissi on increase is assumed to occur for the hood burners. While it is certainly possible that steam could just as easily be used, the increases in bur ner c apacity due t o t his pr oject a re m ore t han a dequate t o c over the planned production increases. T he appl i cant has proposed that i ncreases i n actual

- to

- potential f or s team f rom the boilers be ba sed on t he c omparison be tween m aximum actual production as the facility is currently configured and the maximum production that the applicant hopes to achieve after the current project is completed. The current maximum daily production achieved is 1,224 ADT and the design capacity is 1,476 A DT. F acility records for actual production and actual steam use during t he t wo

- year pe riod 2002

- 2003 s how a n a verage s team use equ ivalent t o 7 MMBTU/ADT. Thus, the increase to 1,476 ADT would require

(1,476 – 1,224) ADT **×** 7 MMBTU/ADT **×** 365 days/year = 643,860 MMBTU/year.

All boilers were reviewed t o de termine t he c onservatively hi ghest e missions t hat c ould be realized by combusting the BTUs required. The first table following shows the emission factors used in this analysis. Factors for SO 2 , NO X , and PM 10 are maximum allowables from Subpart D and/or Subchapters 19, 31, and 33. All others are footnoted. The second table shows addi tional project e missions f rom e ach boi ler, c iting t he hi ghest e missions f rom e ach. N ote t hat gas for

boilers 2 a nd 3 i s used only for ignition or flame stabilization and cannot be delivered to these boilers in sufficient amount to allow for operation solely on gas.

Pollutant Emission Factors (lb/MMBTU)

Coal Gas

SO 2 1.20 0.2

NO X 0.7 0.2

PM 10 0.1 0.1

CO 0.028 (1) 0.084 (2)

VOC 0.0034 (3) 0.0055 (4)

Sulfuric acid mist 0.017 (5)

-- Lead 6.02E

- 06 (6) 5.0E

- 06 (4)

1. P ulverized Coal NSPS Unit emission factor from Table 1.1

- 3 of AP

- 42 (9/98), using

worst -case heat content sampling of 17.68 MMBTU/ton for 2002-2003.

2. Uncontrolled Post

- NSPS Large Wall

- Fired Units emission factor from Table 1.4

- 1 of

AP -42 (7/98), assuming 1,000 BTU/CF.

3. T otal Non Methane OC emission factor for Dry Bottom Units from Table 1.1

- 19 of

AP -42 (9/98), using 17.68 MMBTU/ton as in note 1. 4. Emission factor from Table 1.4-2 (7/98), assuming 1,000 BTU/CF. 5. The highest average value from three runs for each boiler during stack testi ng in May

2003. 6. T he hi ghest a verage v alue, i ncluding soot

- blowing t imes, f rom t hree r uns f or e ach boiler during stack testing on January 7 and 8, 2003.

Pollutant Emissions (TPY)PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 14

B

- 1 (Gas) B

- 2 or B

- 3 (Coal) B

- 4 (Coal/Gas) Maximum

SO 2 64.4 386 386 386

NO X 64.4 225 225 225

PM 10 32.2 32.2 32.2 32.2

CO 27.0 9.01 27.0 27.0

VOC 1.77 1.09 1.77 1.77

Sulfuric Acid Mist 0 5.47 5.47 5.47

Lead 0.0016 0.0019 0.0019 0.0019

EUG 2

– Combustion Sources Not Subject to NSPS or NESHAP

Discussion i n t he m emoranda a ssociated w ith t he pe nding P art 70 pe rmit a nd with earlier operating permits, some of whose conditions will be included in the Part 70 permit , considers fuel oil as an alternate fuel for the burners in the paper machine hoods. Since the burners are no longer capable of using liquid fuel, the only a lternate c onsidered f or t he c urrent pr oject i s propane. Emission factors for natural gas represent the worst

- case analysis when compared with propane and will be used for this discussion. F actors for SO 2 , PM 10 , VOC, and lead are taken

from Table 1.4

- 2 of AP

- 42 (7/98), inflated by 20% as a safety factor, and assumed to apply on a 1, 000 BTU/CF basis. T he PM 10 factor used is that for total PM. F actors for NO X and CO are taken f rom bur ners s imilar t o t hose c urrently i n pl ace. A lthough t he ne w bur ners might have lower em ission factors and may even be r equired by B ACT t o ha ve l ower e missions, and although a l ower pe rmit l imit i s i n pl ace f or t he bur ners on P M

- 14, hi gher va lues a re us ed throughout t his di scussi on to ensure conservatively high results. N o claim is made here as to requirements for, or results from, BACT analysis. Note that the burners in PM

- 15 are not to be modified or replaced. T he f ollowing ta ble lis ts a ll of the e mission factors us ed to calc ulate combustion emissions from the paper machine hood burners.

Machine No. Pollutant Emission Factors (Lbs/MMBTU)

SO PM 2 VOC 10 Lead NO CO X PM

- 11

7.2 **×** 10 9.12 **×** 10 -4 6.6 **×** 10 -3 6 **×** 10 -3 0.12

-7 0.37

PM

- 12 0.12 0.29

PM

- 13 0.12 0.29

PM

- 14 0.15 0.44

PM

- 15 0.15 0.44

The following table lists average annual fuel consumption for the burners in each paper machine hood for 2002 a nd 2003, a s well as the potential fuel consumption after the project, assuming 8,760 hours per year of operation.

Machine No. Fuel Use, MMBTU/year Average Actual Potential

PM

- 11 113,627 613,200

PM

- 12 197,251 613,200

PM

- 13 159,772 613,200

PM

- 14 111,735 613,200

PM

- 15 93,679 438,000PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 15

The f inal s et of t ables f or bur ners c ombine da ta f rom t he pr eceding t wo tables to calculate average and projected (PTE) emissions. Increase/decrease rows are shown in anticipation of later discussion concerning PSD. A summary table condenses the results into a single table covering all six pollutants. Hourly emissions may be calc ulated from these tables by assuming continuous operation and dividing by 8,760 hours per year.

SO 2 Machine No. Emissions - TPY

PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 0.041 0.071 0.058 0.040 0.034 0.243

Potential 0.22 0.22 0.22 0.22 0.16 1.04

Chan ge 0.18 0.15 0.16 0.18 0.12 0.80

PM 10 Machine No. Emissions - TPY

PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 0.52 0.90 0.73 0.51 0.43 3.08

Potential 2.80 2.80 2.80 2.80 2.00 13.2 Change 2.28 1.90 2.07 2.29 1.57 10.1

VOC Emissions - TPY

Machine No. PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 0.37 0.65 0.53 0.37 0.31 2.23

Potential 2.02 2.02 2.02 2.02 1.45 9.54 Change 1.65 1.37 1.50 1.65 1.14 7.31

Lead Emissions

– TPY **×** 10

Machine No. -5

PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 3.41 5.92 4.79 3.35 2.81 17.2

Potential 18.4 18.4 18.4 18.4 13.1 86.7 Change 15.0 12.5 13.6 15.0 10.3 66.4

NO X Machine No. Emissions - TPY

PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 6.8 11.8 9.6 8.4 7.0 43.6

Potential 36.8 36.8 36.8 46.0 32.9 189 Change 30.0 25.0 27.2 37.6 25.8 146

CO Emissions - TPY

Machine No. PM

- 11 PM

- 12 PM

- 13 PM

- 14 PM

- 15 Total Average 21.0 28.6 23.2 24.6 20.6 118

Potential 113.4 88.9 88.9 134.9 96.4 523 Change 92.4 60.3 65.7 110.3 75.8 405PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 16

Burner Combustion Emissions Summary - TPY

SO PM 2 VOC 10 Lead NO CO X Average 0.243 3.08 2.23 1.72 **×** 10 43.6

- 4 118

Potential 1.04 13.2 9.54 8.67 **×** 10 189

- 4 523 Change 0.80 10.1 7.31 6.64 **×** 10 146

- 4 405

Emission calculations for the existing tunnel dryer at the polyethylene printer and for the three new dryers are ba sed on f actors f rom T ables 1.4

- 1 a nd 2 of A P

- 42 ( 7/98), a s s hown i n t he following t able. T he ne w t unnel dr yers m ay be r ated a s hi gh a s 3.2 M MBTUH. If de sired, hourly emission rates can be found by dividing the annual emissions by 8,760 hours.

Tunnel Dryer Combustion Emissions - TPY

SO PM 2 VOC 10 NO CO X Existing dryer 0.01 0.07 0.05 0.88 0.74 Dryer #2 (new) 0.01 0. 11 0.0 8 1.40 1.18 Dryer #3 (new) 0.01 0.11 0.08 1.40 1.18 Dryer #4 (new) 0.01 0.11 0.08 1.40 1.18

Total 0.0 3 0. 39 0. 28 5 .08 4.27

Increase 0.0 3 0. 32 0. 23 4.20 3.53

The catalytic oxidizer was evaluated in the Memorandum for the Part 70 pe rmit using emission

factors f rom T ables 1.4

- 1 a nd 2 of A P

- 42 (7/98) for a r ating of 2 M MBTUH. T he ne w regenerative thermal oxidizer has not been selected, but the largest unit currently being evaluated is r ated a t 10.4 M MBTUH. T he s ame f actors a re us ed in evaluating the new unit, except for

NO X . T he manufacturer has supplied NO X emission factors based on PTE, expected emission

rate w ith no V OC pr esent, a nd e xpected r ate w ith V OC pr esent. T he hi ghest of t hese i s equivalent to the emission factor used for the smaller unit. The existing catalytic unit has been

tested at 98.6 % de struction efficiency, while the ne w R TO is e stimated to be mor e t han 95% efficient, although 95% will be used as a conservative number for this discussion. Only annual totals are listed in the following table, while hour ly r ates ma y be c alculated by di viding e ach number by 8,760 hours per year.

Oxidizing Unit Comb ustion Emissions (TPY)

SO PM 2 VOC 10 NO CO X Old Catalytic (2 MMBTUH) 0.01 0.07 0.05 0.88 0.74 New RTO (10.4 MMBTUH) 0.03 0.35 0.25 4.56 3.83

Increase 0.02 0.28 0.20 3.68 3.09

VOC emissions from polyethylene printing depend on c apture and destruction efficiency. The existing single printer has capture efficiency of only 70%, which is a datum agreed upon by the facility a nd D EQ i n di scussions s urrounding t he P art 70 pe rmit. As s tated above, testing

indicates 9 8. 6% destruction efficiency. Average 2002

- 2003 uncontrolled VOC from the printer was 197.5 TPY. F ugitive emissions were 30% of this number, or 59.3 T PY. T he 70% portion captured was reduced by 9 8. 6%, leaving stack emissions of 1.9 TPY. Plans for the new printers include constructing a n e nclosure a round a ll f our uni ts, l eading t o 100% c apture. A ssumingPERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 17

conservatively low destruction efficiency of 95% and using potential printer VOC emissions of 971 TPY leads to zero fugitive emissions and 48.6 TPY of stack emissions. The following table

summar izes these calculations.

Oxidizer Emissions From Printer VOC (TPY) Unit(s) Uncontrolled VOC Fugitive Stack Total Catalytic Ox & 1 Printer 197.5 59.3 1.9 61.2

RTO & 4 Printers 971 0 48.6 48.6 Change 774

- 59.3 46.7

- 12.6

The following table summarizes all groups discussed for EUG 2, and shows their total increase in

emissions.

EUG 2 - Emissions Summary (TPY) Group PM NO SO 2 X VOC CO Lead

Hood burners 13.2 189 1.04 9.54 523 8.67 **×** 10 - 4
Tunnel dryers 0.32 4.20 0.03 0.23 3.53 Oxidizer (combustion) 0.35 4.56 0.03 0.25 3.83

Printer VOC 48.6

Totals 13. 9 19 8 1. 10 58.6 530 8.67 **×** 10 - 4

Increase 10. 7 15 3 0.8 6

- 4. 85 410 6.64 **×** 10 - 4

EUG 3 – Subpart Y Coal Preparation Plant

Steam use may increase as a result of this project, and a method of calculati ng actual

- to

- potential emissions is needed. T he i ncrease w ill be di scussed m ore f ully l ater i n t his m emorandum. Emission estimates have been calculated for this EUG, but the only limits placed in the pending Part 70 permit concern opacity. A n analysis of the factors used, their origin, and some of the discussion w ith t he a pplicant c oncerning t hese e stimates m ay be found in the memorandum associated with the pending Part 70 permit. The following table summarizes the conclusions of that di scussion, but i s not used for setting a l imit he re, nor i s i t of fered a s s upport f or P SD considerations. Coal throughput for 2003 was 519,362 t ons. U sing 8,300 B TU/lb as a lower

value for sub

- bituminous coal and assuming the continuous operation of Boilers 2, 3, a nd 4 a t rated capacity implies maximum coal throughput of 820,200 tons. T he table indicates that the

actual

- to -potential increase in PM emissions is 49.0 TPY.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 18

EUG 3 –Coal Preparation Plant

EU Name Particulate Matter

Emission Factors (lbs/ton coal) PM Emissions (TPY)

2003 Actual PTE

Railcar Unloading

0.0859 22.3 35.2 Radial Stacker Grizzly Feeder

Coal Sizer/Crusher 0.2 51.9 82.0 Conveying 0.02 5.19 8.20

Coal Bunkers 0.02 5.19 8.20

Coal Feeders Closed Process

No emissions Pulverizers

EUG 4 – PP- 1 Pulp Processing Units This E UG i s r eserved f or f uture S ubpart S a pplicable uni ts. H AP and VOC emission calculations are included in EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP.

EUG 5

– Subpart KK Flexographic Printing

Printing Presses

Emiss ions of H APs a re l imited by S ubpart K K t o 400 ki lograms pe r m onth. I n a ddition to restrictions on H AP e missions, t hese uni ts ha ve a l arge a mount of VOC emissions. VOC emissions for the printers are illustrated in the discussion of emissions for EUG 6, VO C Sources Not Subject to an NSPS or NESHAP, and are not repeated here.

EUG 6

– VOC Sources Not Subject to a n NSPS or NESHAP

PP

- 1 Pulp Processing Units Emission factors for these units were developed in a comprehensive emissions testing program by The Nat ional Council for Air and Stream Improvement (NCASI). Lengthy discussion of this program, with de tails c oncerning a pplicant’s pa rticipation m ay be f ound i n t he m emorandum associated with the pending Part 70 permit. The Pulp Processing emission factors developed in this program are used to estimate total VOC and HAP emissions for all pulping systems. This action was taken in the discussion for the Part 70 permit, which concluded that such an approach is reasonable since all systems use similar processes a nd raw materials to produce similar products. The primary difference in the Systems lies in t he bl eaching a gent a nd/or s equence. E mission factors for the systems were de veloped by a pplying t he pr oduction r ate

- normalized emission

factors from the two areas tested. In every case where the choice of bleaching agent created a difference in emissions, the higher factors were selected and applied to the maximum expected production rates for the pulping system, producing conservatively high results. An overall factor

of 0.45 lb s of VOC per ton of pulp processed is the highest value shown in the NCASI study. Paper production requires approximately 100 tons of pulp for every 95 tons of finished product. The following table uses this factor in a comparison of 2002

- 2003 average actual emissions with current project PTE.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 19

Paper production (TPY) Pulp use (TPY) Emission

factor VOC Emissions (TPY)

Average Potential Average Potential Lb/ton Average Potential Increase 345,880 538,845 364,0084 567,205 0.45 82 128 46

Pap er Machines PM -11, PM-12, PM-13, PM-14, and PM-15 Various methods have been used in the past to calculate e missions of VOC from chemicals used at the paper machines . One method used a site

- specific evaluation by NCASI. Emissions from building vents and e quipment vents were measured, certain worst

- case assumptions were made, and uniform values applied to all machines. M ass ba lance m ethods ha ve a lso be en us ed, sometimes with restrictions as to the amount of VOC released, as opposed to VOC reacted or

bound in some other fashion. The method used for this permit analysis is reflected in the section following this.

Paper Machine Additives The additives to which the heading refers are chemicals used with paper machines, but that were not in use when the NCASI testing was performed in 1995. They include chemicals that enhance the product, such as s oftness a ids, dyes, bi ocides, e tc. Considerations s imilar to those in the preceding section were made in c alculations of VOC emissions for the memorandum associated with the pending Part 70 permit.

The c urrent a pplication r e

- visits t he pr eceding i ssues f or s everal r easons. F irst, t he current project i s ex pected to increase pa per pr oduction dramatically, with a conc omitant increase in additive us e. S econd, a pr incip al f orce be hind the de tailed analysis i n earlier ve rsions of the pending Part 70 permit was the presence of Part 5 of Subchapter 41 of Oklahoma’s Air Pollution Control Rules, which c oncerned e missions of T oxic A ir C ontaminants. P art 5 ha s be en superseded by Subchapter 42 and no longer applies to toxics emitted by this facility. The facility has reviewed all chemical use in terms of VOC content, and has divided the VOC totals by paper production in each of 2002 and 2003. This analysis covers the chemicals covered by the NCASI study in the preceding section, as well as the additives used since the NCASI study . The worst

case results have been combined to produce a ratio, or emission factor, for all VOC as a function of paper production. B ecause of the unc ertainty associated with formulations that may become available, the calculated factor was inflated by nearly 50% to provide a s afety factor. The first table following shows the data used to calculate the ratio and the second table shows the effect of using the ratio in calculating emission changes due to the current project.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 20

VOC Usage (TPY)

Additive 2002 2003 Maximum 2002/2003 Wet Strength 30.63 50.22 50.22

Softeners 4.67 1.76 4.67 Release Agents 0.26 0.44 0.44

Miscellaneous 10.11 7.03 10.11

Felt /Wire Conditioners 6.79 6.90 6.90

Defoamers 8.73 6.11 8.73

Biocides 0 9.94 9.94 Paper Machine Dyes 0.19 0.18 0.19

Total 61.39 82.58 91.21 ADT/yr* 342,202 349,558 345,880** Lb VOC/ton paper 0.359 0.472 0.527 *Paper production in air-dried tons per ye ar **Two- year average ADT

Production (ADT) Emission factor VOC Emissions (TPY)

2002

- 2003 Average Potential Lb/ADT 2002

- 2003 PTE Increase 345,880 538,845 0.75 72.0* 202 130 *Average of actuals.

Solvent Cleaning of Paper Machines

Emissions of VOCs from SC

- 1, solvent cleaning, are based on the use of a 100% VOC solvent to clean Paper Machine wires. This solvent is applied through spray nozzles located across a boom that stretches across the Paper Machine. E mission amounts authorized in the pending Part 70 permit for machines PM

- 11 through PM

- 14 are based on research from a s imilar de

- ink facility paper m achine. A ccording t o t hat r esearch, onl y 60% of t he s olvent a pplied t o the machine becomes air emissions, 20% is consumed in the reaction with the latex buildup on the wire, and 20% e nds up i n t he w ater l oop a nd e ventually i n t he w astewater treatment plant. This 60% evaporation rate analysis was first utilized to calculate authorized emissions in the memorandum

associated with Permit No. 91 -127- O (M

- 1), issued for PM

- 15. E xtending this analysis to the other four machines that had not previously been subject to emission limits would have resulted in authorizing 179.1 TPY of VOC for a rolling 12

- month total , but the facility requested a limit of 338 T PY, based on hi storic increases in use of such solvents . P ermitted emissions of 37.57

TPY of VOC for PM

- 15 were carried into the pending Part 70 permit from Permit No. 91-127- O (M

- 1).

The appl icant ha s re

- visited t he c alculation pr ocess a nd pr oposes a m ore di rect m ethod of accounting. Under this method, a ctual s olvent us e f or 2002

- 2003 w as c ompared w ith pa per production for each of the two years and the most

- polluting ratio was taken to represent future production. T he first table following shows the data u sed to calculate the ratio and the second table s hows t he e ffect of us ing t he r atio i n c alculating e mission c hanges due to the current project. Note that this approach assumes that all of the VOC is emitted, making recordkeeping much simpler, and assuring conservatively high calculations. It also combines the emissions andPERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 21

conditions f or S C

- 1 (PM

- 11, 12, 13, a nd 14) w ith t hose f or P M

- 15 i nto a s ingle s et of requirements.

2002 2003

Solvent use 500 tons 414 tons

ADT* 342,202 349,558

Lbs of VOC/ADT 2.92 2.37 *Paper production in air

- dried tons.

Production (ADT) Emission factor VOC Emissions (TPY)

2002

- 2003 Average Potential Lb/ADT 2002

- 2003 PTE Increase 345,880 538,845 2.92 505 * 787 282 *Note that this is not the figure reported as actual for invent ory purposes. It represents the emissions that would have been reported had the derived emission factor been used.

The m emorandum a ssociated w ith t he pe nding P art 70 pe rmit a ddresses i ndividual H AP components of the solvents in use, but the Specific Conditions proposed for that permit do not set limits or standards. S ince HAP are required to be speciated for annual emission inventory purposes, a nd s ince e numeration of va rious H AP w ill not a lter t he status of this permit, no attempt i s m ade he re t o analyz e t he i ndividual c omponents of t he s olvents, or t o e stablish anticipated quantities of each that may be emitted.

Polyethylene Extruder In e stimating e missions f rom th e P oly P lant e xtruder processes, e mission f actors f rom a 1996

article in the Journal of t he Air and Waste Management Association (JAWMA) were used for linear low density polyethylene (LLDPE) bl own f ilm a t a 355 **°** F me lting te mperature. T he polyethylene ( poly) f ilm pr oduced a t t he P oly P lant i s a bl own f ilm pr ocess us ing 20 – 22%

LLDPE at a melt ing temperature of approximately 350 **°** F. Other emission factors associated with the JAWMA document refer to either high

- density blow molding or extrusion coating. N either of these processes matches the process at the Poly Plant.

VOC and HAP emissions are calculated using emission factors developed in the JAWMA study

in units of pounds of emissions per million pounds of poly extruded. P otential production was estimated at 6.0 MM lbs/yr for the Part 70 pe rmit, and actual production figures for 2002 a nd

200 3 were 5,020,914 pounds and 5,358,174 pounds , r espectively. A ddition of t hree ne w extruders i s ex pected to increase capa city t o 35 MM l bs/yr. The following table reflects calculations based on these assumptions and data.

EUG 6

– VOC and HAP Emissions fr om the Polyethylene Extruders

CAS # Factor Emissions (Lbs/yr)

lbs/MMlb 2002/2003 PTE Increase Formaldehyde 50

- 00

- 0 0.09 0.48 3.15 2.68 Acetaldehyde 75

- 07

- 0 0.03 0.16 1.05 0.89 Methyl ethyl ketone 78

- 93

- 3 0.02 0.10 0.70 0.60 Acrylic acid 79

- 10

- 7 0. 02 0.10 0.70 0.60

Acrolein 107

- 02

- 8 0.02 0.10 0.70 0.60 Propionaldehyde 123

- 38

- 6 0.02 0.10 0.70 0.60

VOC

--------- 8.0 41.5 280.0 238.5PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 22

Corona Treaters These equipment items generate a cor ona that is used to treat the polyethylene film produced at

the Polyethylene Plant, allowing for enhanced ink bonding to the film. O zone is generated by this process and is vented to the atmosphere without any controls. M anufacturer’s data for the existing uni ts i ndicates de sign pr oduction of 0.073 lbs/hr/kVa, where kVa i s ki lovolt

- ampere. The pr incipal uni t i s r ated a t 5 kV a. A ba ckup uni t i s r ated a t 10 kVa and has an associated decomposer, w hich c onverts 95% of t he oz one t o m olecular ox ygen. T he P art 70 pe rmit

memorandum s hows t otal oz one e missions f rom t hese t wo treaters to be 1.76 T PY, a ssuming continuous ope ration. T hree ne w uni ts t o be a dded i n t he c urrent project do not have decomposers, so their emissions are simply

3 units **×** 10 kVa/unit **×** 0.073 lb/kVa/hr **×** 8,760 hrs/yr = 9.6 TPY of ozone.

This entire amoun t may be treated as the increase in emissions for this equipment.

Plate Making Analysis in the memorandum a ssociated w ith t he pe nding P art 70 pe rmit e stimated VOC emissions f or t he pr ocess t o be 1.83 T PY f or a single press, based on solvent component

concentrations and the fact that the solvents are 100% VOC. Emissions are small because almost all of the used solvent is recycled at the Poly Plant. Further review of actual use suggests that 900 l bs of V OC pe r y ear i s a m ore r easonable num ber. A dding t hre e mor e pr esses w ill not multiply the emissions by four, because the plates made may be used interchangeably among the presses. Despite that fact, the facility has opted to make the conservatively high assumption that

emissions w ill be 900 **×** 4 = 3,600 l bs/yr ( 1.8 T PY). T his num ber i s l ess t han t he a mount estimated i n t he P art 70 m emorandum, s o t he actual

- to

- potential difference is taken to be 900 lb/press/yr times three new presses, or 1.35 TPY.

Flexographic Printers VOC emissions from polyethylene printing depend on c apture and destruction efficiency. The existing single printer has capture efficiency of only 70%, which is a datum agreed upon by the facility a nd DEQ in discussions s urrounding the P art 70 permit. R ecall tha t te sting indi cates 96.8% destruction efficiency. Average 2002

- 2003 uncontrolled VOC from the printer was 197.5 TPY. Fugitive emissions were 30% of this number, or 59.3 TPY. The 70% portion captured was reduced by 96.8% , l eaving s tack e missions of 1.9 T PY. P lans for the new printers include constructing an e nclosure a round a ll f our uni ts, l eading t o 100% c apture. A ssuming conservatively low destruction efficiency of 95% and using potential printer VOC emissions of 971 TPY leads to zero fugitive emissions and 48.6 TPY of stack emissions. The following table

summarized these calculations.

Oxidizer Emissions From Printer VOC (TPY) Unit(s) Uncontrolled VOC Fugitive Stack Total Catalytic Ox & 1 Printer 197.5 59.3 1.9 61.2

RTO & 4 Printers 971 0 48.6 48.6 Change 774 -59.3 46.7 -12.6PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 23

VOC emissions from paper printing are calculated based on a ssumptions made in analyses for earlier permits and assuming that the current project will lead to a large increase in the amount of printed paper products manufactured. The project will increase actual paper production, but will not e xceed t he a mount of pa per a lready a uthorized. T hus, t he e xisting 92.28 T PY of V OC authorized by existing permits is not to be increased by this permit. At the time the VOC level was authorized, average VOC concent ration in water

- based inks ranged from approximately 6% to 8%. A conservatively high 10% was used to calculate a PTE and to allow for flexibility in varying ink VOC concentrations. T he data used imply use of 0.343 pounds of VOC per ton of paper. Actual use figures for 2002 a nd 2003 i ndicate that calculations supporting the 92 TPY level g reatly e xaggerated t he V OC c oncentration, i n t hat 2002 use was approximately 0.018

lb s /ton a nd 2003 us e w as a pproximately 0.031 l b s /ton. T here a re t wo pos sible a pproaches t o

establish the act ual

- to

- potential increase. F irst (Option 1), we could use the original emission

factor of 0.343 l b s /ton and apply it to all potential production, comparing that result with 2002

- 2003 actuals. S econd, (Option 2) we could apply the 0.343 l b s /ton emission factor to only the increase i n pr oduction, hol ding t he e xisting pr oduction a t t he l evels s hown i n 2002

- 2003, and then compare the total to the 2002

- 2003 actuals. Both options use actual average production of 345,880 tons and design capacity of 538,845 t ons per year, for an increase of 192,965 tons per year. The following table shows these calculations. The second option is clearly more realistic, but the first option may be required for technically accurate PSD analysis.

Paper Print er VOC Emissions (TPY)

Potential Emissions 92.28 37.31

2002

- 2003 Actual Average 4.26 4.26

Increase 88.02 33.05

EUG 7

– Non

- Combustion PM Sources Not Subject to NSPS or NESHAP

Paper Machines Paper fibers are released into the atmosphere via the drying, trimming, handling and slitting of the paper sheet. Emissions were calculated using stack test data from a sister mill in Rincon, Georgia. Results f rom t he 2002 s tack t esting of R incon’s #19 P aper M achine dr ying hood

indicated 0.415 lb s /hr of non -combus tion particulate matter generated. Dividing this number by the paper production rate yielded an emission f actor of 0.048 l bs P M/ton pa per. T he de rived emission factor was doubled to account for particulate matter emissions generated by the wet end

of t he paper m achine, w hich i s a c onservatively hi gh a ssumption. S imilarly, s tack test data (November 2001) from the roof vents in the building above Rincon’s #19 paper machine showed

0.875 lb s /hr of particulate matter, which was converted to an emission factor of 0.108 lb PM/ton paper produced. T he m emorandum a ssociated w ith t he pe nding P art 70 pe rmit t reats t hese factors separately, but they are combined here for ease of presentation. Details may be found in the referenced memorandum. The following table shows 2002-2003 average actual emissions for each machine, potential emissions after the current project, and the actual

- to

- potential increase.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 24

Machine Paper Throughput (TPY) PM Emissions (TPY)

2002

- 2003 Potential 2002

- 2003 Potential Increase

PM -11 48,335 91,250 4.93 9.31 4.38

PM

- 12 77,338 127,750 7.89 13.03 5.14

PM

- 13 70,961 109,500 7.24 11.17 3.93

PM

- 14 75,145 109,500 7.67 11.17 3.50

PM

- 15 74,101 100,845 7.56 10.29 2.73

Total 345,880 538,845 35.3 55.0 19.7

Coal Pile Emissions Although a dditional c oal m ay be ha ndled, none of t he considerations involved in calculating emissions for the coal pile will change. Thus, there is no change in emissions to be expected.

Polyethylene Plant The Part 70 pe rmit c alculated PM emissions from resin storage and handling using an emission

factor from Table 6.6.2

- 1 of AP

- 42 (1/95) for dimethyl terephthalate resin production processes, assuming a resin usage rate of 6.0 M M lbs/yr. A ddition of three more extruders will increase throughput to 35 MM lbs/yr. The foll owing table presents the results, using 2002

- 2003 average production instead of the Part 70 Memorandum estimate.

Film Production (MMlbs/yr) Factor PM Emissions (TPY)

2002

- 2003 Potential 2002

- 2003 Potential Increase

5.19 35.0 0.017% 0.44 2.98 2.53

Hazardous Air Pollutants (HAPs)

Individual HAP emissions were discussed in the memorandum associated with the pending Part 70 permit and are not repeated here, both because the PTE for these materials will not increase and because any act ual

- to

- potential inc r eases r equire di scussion i n t he c ontext of P SD. P SD

issues will be discussed later in this memorandum.

The following table summarizes actual

- to

- potential emission changes for all EUGs discussed in

this section.

EUG NO X CO SO 2 PM 10 VOC Other

1 225 27.0 386 32.2 1.77 H 2 SO 4 - 5.47, Lead

– 0.0019

2 152 410 0.83 10.6 (4.94) Lead

– 0.000664

3 49.0

4 No change, or changes were discussed in other EUGs

5 No change, or changes were discussed in other EUGs

6 490 O 3

– 9.6 (included in VOC total)

7 22.2

Totals 377 437 387 114 487 H 2 SO 4 - 5.47, Lead

– 0.0026PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 25

SECTION V. AIR DISPERSION MODELING

Overview Air dispersion modeling has been performed at various times in the permitting life of the facility. Some modeling has been performed to demonstrate compliance with Part 5 of OAC 252:100 -41 and s ome ha s be en pe rformed t o de monstrate c ompliance w ith ot her a mbient s tandards. Two PSD permits and evaluations have been issued during the life of this plant and further analyses

were submitted with the application for the pending Part 70 pe rmit. T hese analyses have been reviewed i n pr evious pe rmit m emoranda or w ill ha ve be en r eviewed i n the memorandum associated with the Part 70 ope rating permit. T hese reviews are not reproduced or summarized

here. Note that pr evious a nalyses de aling w ith t oxic a ir c ontaminants ( TACs) a re no l onger pertinent, due t o t he r eplacement of P art 5 of S ubchapter 41 by S ubchapter 42. Modeling information for those TAC constituents that are also HAP remain valid unless updated by this construction permit.

Ozone Modeling

The modeling analysis for ozone was performed by DEQ. O AC 252:100 -8- 35 requires an air quality i mpact e valuation f or e ach r egulated pol lutant f or w hich a m ajor m odification would result in a s ignificant n et emissions increase. N o de mini mis air quality level is provided for ozone. However, any net increase of 100 t ons per year or more of volatile organic compounds subject to PSD is required to perform an ambient impact analysis. Methods for evaluating s ingle source impacts on ozone concentrations are not consistent, due to the lack of availability of data at a r efined level, readily available tools and EPA guidance. DEQ has evaluated the impact of the pr oposed m odification t o t he F ort J ames f acility us i ng an existing ai r qua lity da tabase generated for a SIP evaluation and the CAMx photochemical modeling system.

Oklahoma entered into Early Action Compact ( EAC) a greements w ith E PA f or t he T ulsa a nd Oklahoma C ity me tropolitan areas. P hotochemical mode ling evaluations w ere pr epared in support of the agreements. These evaluations were conducted in accordance with EPA guidance and underwent an extensive public comment process and EPA review. The modeling was based on a two week episode beginning in Mid

- Augu st of 1999 and extending through the first week of September 1999. T his episode was chosen both by virtue of being a prolonged period of high ozone concentrations and a reflection of the most common meteorological conditions that spawn high concentrations for Tulsa and Oklahoma City.

Modeling f or F ort J ames w as c onducted us ing t he E AC ba se c ase. Emissions to be modeled were calculated by subtracting the 1999 i nventoried e missions f rom t he f uture pot ential emissions identified in the a pplication. V OC e mi ssions w ere f urther s peciated by S ource Classification Code, SCC, using speciation tables generated by EPA and SCCs for Fort James processes as identified in annual inventories.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 26

NOx CO VOC

1999

TPY Model

TPY 1999

TPY Model

TPY 1999

TPY Model

TPY

Boi ler

- Unit B

- 1 Zurn 24.63 17.99 1.18

Boiler

- Unit B

- 2 Babcock & Wilcox 222.04 44.79 5.08

Boiler

- Unit B

- 3 512.76 48.77 5.96

Boiler

- Unit B

- 4* 655.2 225.35 12.52 27.04 5.42 1.77
Paper Dryer

- Hood PM

- 11 11.15 25.65 9.37 104.03 6.86 35.58
Paper D ryer - Hood PM

- 12 6.706 30.094 6.94 81.96 9.79 32.65
Paper Dryer

- Hood PM

- 13 10.28 26.52 9.63 79.27 8.57 33.87
Paper Dryer

- Hood PM

- 14 9.84 36.16 8.27 126.63 7.92 34.52
Paper Dryer

- Hood PM

- 15 7.88 25.02 6.62 89.78 8.52 33.35

FXRT #1

- Unleaded Gasoline 1.23

FXRT #2 - Aqueous NH3
Emergency Diesel Generators 0.31 0.08 0.01
Chlor Alkali Absorption Towers

Misc VOC 2.04
Pulp Bleaching with Hypochlorite 13.98 32.23 Polyethylene Extruding and Printing ** 0.62 0.13 67.62

- 18.98
PM Solvent Cleaning 151.16 635.5537

Non

- hypochlorite Pulp Bleaching 15.304
Paper Printing 3.91 29.19
Coal Pile Fugitive Emissions

Waste Water Treatment Plant 7.06
Paper Machine Additives 10.17

* The applicant requested a maximum duty increase for boilers. Modeling reflects the maximum increase as requested rather than actual to future potential. T here have been no permit modifications to the boilers since the baseline ozone modeling inven tory (1999). ** Negative emissions were not included in the modeling.

Maximum impacts from the proposed increases occur in the Muskogee area. A maximum 8 -hour average increase of 1.3 ppb was predicted for Muskogee in the immediate vicinity of the facil ity. Maximum downwind impacts in Wagoner and Mayes Counties did not reach 1 ppb ove r any 8

- hour average during the episode. T he maximum increase in predicted concentrations in south west Tulsa County was 0.3 ppb. T he highest current design value for Tulsa (2003

- 2005) is 79 ppb.

The hi ghest concentrations were pr edicted in Muskogee a nd S outh E ast por tions of W agoner

Counties. The total modeled concentrations for those areas were less than 70 ppb for the entire episode. The facility is not expected to ca use or significantly contribute to a violation of the 8

- hour standard.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 27

Point Source M odeling The f ollowing m aterial i s t aken f rom t he a pplication. I t has been reviewed by ODEQ and determined to be acceptable. Table and section numbering used in the app lication is preserved

here. ( Begin material from application )

D.1 INTRODUCTION United S tates E nvironmental P rotection A gency ( EPA) a nd O klahoma Department of Environmental Quality (ODEQ) r ules r equire ma jor ne w f acilities a nd major modi fications to

un dergo several analyses for emission increases s ubject t o Prevention of S ignificant Deterioration (PSD) r eview. T hese ana lyses de termine w hether s ignificant air quality deterioration will result from the new or modified facility. The modifications propose d and the resultant emission changes are described in their application and previously in this memorandum. In addition to an a nalysis of c ontrol t echnology di scussed i n t his m emorandum’s F ederal Regulations ( Section V III), P SD r eview requires G -P (Georgia

- Pacific, pa rent c ompany t o F t. James) to conduct the following analyses.

Source impact analysis Good engineering practice stack height (GEP) Air quality analysis (monitoring) Additional impact analyses

EPA regulations (40 CFR 52.21(k)) require that an ap plicant perform a s ource impact analysis for e ach a pplicable pol lutant. T he P SD r egulations specifically provide for the use of atmospheric dispersion models in performing impact analyses, estimating baseline and future air quality l evels, a nd de termining compliance with National A mbient A ir Q uality S tandards (NAAQS) a nd a llowable P SD i ncrements. S ection D .2 of t his di scussion pr esents t he Source Impact Analysis.

In addition to the source impact analysis, PSD review requires that any emission limit must be applied in a source i mpact analysis with a s tack height t hat doe s not ex ceed GEP (refer t o 40 CFR 52.21(h)). T o demonstrate this, G

- P performed an analysis of the physical arrangement of stacks and solid physical structures that may affect dispersion a nd computed GEP stack heights. Section D.3 of this discussion presents the GEP Analysis.

The third analysis is specified by EPA regulation 40 CFR 52.21(m). In addition to predicting a source i mpact, a P SD pe rmit a pplication m ust c ontain a n a nalysis of c ontinuous a mbient a ir quality data in the a rea a ffected by t he pr oject. T he r egulation pr esents t he c onditions t hat require pr e

- construction a nd pos t

- construction monitoring of a mbient a ir. S ection D .4 of t his discussion presents the Ambient Air Quality A nalysis.

Lastly, EPA regulations (40 CFR 52.21(o)) require an analysis of the impairment to visibility and the impacts on soils and vegetation that would occur as a result of the project. These analyses are to be conducted primarily for PSD Class I areas. Impacts from general commercial, residential, industrial, and other growth associated with the facility or modification also must be addressed. Sections D.5 and D .6 pr esent t he A dditional I mpact A nalysis f or C lass I I a nd C lass I a reas, respectively.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 28

D.2

. SOURCE IMPACT ANALYSIS

G- P conducted the Source Impact Analysis in two phases: 1) impact of the project, and 2) full impact analysis. The first phase determines the impact from the change in emissions associated with the project a lone. G

- P com par es t hese i mpacts t o E PA t hresholds f or s ignificance a nd ambient monitoring criteria. If the project impacts exceed the Significant Impact Levels (SILs),

then G

- P conducts a full impact analysis. A f ull impa ct a nalysis pr edicts impa cts f rom the

sources ac ross the e ntire M ill. G

- P compares t hese i mpacts t o state and national am bient ai r quality standards. T he following sections discuss the methodology, data inputs, and techniques for both phases of the Source Impact Analysis.

D.2.1 AIR MODELING METHODOLOGY The general m odeling a pproach f ollows E PA a nd O DEQ m odeling guidelines for determining compliance with the NAAQS and PSD Increments. In general, current policies stipulate that the highest annual average and highest, second

- highest or highest

- sixth -hi ghest short

- term ( i.e., 24 hours or l ess) c oncentrations be c ompared t o t he applicable standard when 5 years of meteorological data are used. T his approach is consistent with the air quality standards, which permit a short- term average concentration to be exceeded once per year at each receptor.

To develop the maximum short

- term impacts for the G

- P Muskogee Mill, the general modeling approach was to first perform a s creening ana lysis w ith a coa rse r eceptor g rid spacing t o determine the critical impact loc ations. F irst, G

- P predicted impacts for the screening analysis using a 5

- year meteorological data record. Then, a refined analysis was performed if the receptor spacing at the location of maximum impact is greater than 100 meters (m). The refined analy ses used a denser receptor grid centered on the receptor at which the concentration produced from the screening phase. G

- P then executed the air dispersion model for the entire year(s).

D.2.2 MODEL SELECTION

G- P selected an air dispersion model based on the model ’ s ability to simulate air quality impacts in areas surrounding the Muskogee Mill. T he a rea s urrounding t he M ill i s m ostly r ural a nd gently rolling with some isolated areas of significant terrain. Along the southeast edge of the property, the t opography changes to a hilly area with several areas of elevated terrain. Figure D -1 presents a t opographic m ap of t he M uskogee M ill vi cinity. Based on these features, G

- P ha s selected t he I ndustrial S ource C omplex S hort

- Term ( ISCST3) m odel ve rsion t o pr edict maximum concentrations in all areas in the vicinity of the plant site.

In t his a nalysis, t he U S E PA r egulatory de fault opt ions a re ut ilized i n t he ISCST3 model to predict all maximum impacts. These options include:

Final plume rise at all receptor locations

Stack -tip downwash Buoyancy-induced dispersion Default wind speed profile coefficients Default vertical potential temperature gradients Calm wind processingPERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 29

D.2.3 LAND USE CLASSIFICATION Dispersion coefficients are set in the model by selecti ng the land-use mode as urban or rural. The land use in the vicinity of the source is the criteria used to determine the setting. Auer developed

a land

- use procedure in 1978 to determine the model setting. The procedure involves classifying

land areas w ithin a 3

- kilometer ( km) r adius c ircle c entered on t he M ill. T he ur ban m ode is selected if more than 50 percent of the land -use consists of one or more of heavy industrial, lightmoderate industrial, commercial, or c ompact r esidential la nd

- use cl assificat ions. U rban classifications constitute less than 50% of the total area. T herefore, the rural mode is used for ISCST3 modeling.

D.2.4 METEOROLOGICAL DATA Tulsa i s t he ne arest s ite f or s urface obs ervations t o t he M ill a nd i s l ocated approximately 30

mile s t o t he north west. G

- P pr edicted impacts w ith hourly me teorological da ta f or the y ears

1986- 1988 with upper air obs ervations f rom O klahoma C ity a nd s urface obs ervations f rom Tulsa. In 1989, the NWS moved the upper air monitoring site from Oklahoma City to Norman in 1989, causing a three

- week gap in met data for this year. Thus, to complete a 5

- year dataset for the analyses, G

- P also predicted impacts with 1990

- 1991 data using upper air observations from Norman and surface observations from Tulsa. The anemometer height for observations in Tulsa during t his pe riod i s 23 f eet. F igure D

- 2 in t he a pplication pr esents a r egional m ap w ith t he locations of the Mill and meteorological sites.

The s urface obs ervations i nclude w ind di rection, w ind s peed, t emperat ure, c loud c over, a nd cloud ceiling. The wind speed, cloud cover, and cloud ceiling values were used in the ISCST meteorological preprocessor program to determine a tmospheric s tability us ing t he T urner stability s cheme. B ased on the t emperature m easureme nts a t m orning a nd a fternoon, m ixing heights were calculated with the radiosonde data using the Holzworth (1972) approach. Hourly mixing heights were derived from the morning a nd a fternoon m ixing he ights us ing a n interpolation method.

ODEQ accepted this dataset for the most recent air modeling for the Mill. Roberts/Schornick & Associates, Inc ., provided the ISCST- ready meteorological data to G

- P.

D.2.5 BUILDING DOWNWASH Aerodynamic f orces i n t he vi cinity of s tructures a nd obstacles, such as buildings, disturb atmospheric flow fields. T his flow disturbance near buildings and other structures can enhance the dispersion of emissions from stacks affected by the disturbed flow. The disturbance can also reduce the effective height of emissions from stacks l ocated near buildings and obstacles. T he height of t hese di sturbances c an be c ompared t o t he r elease poi nts of m odeled s ources. For sources with release points above these disturbances, the effect on di spersion is not significant. This r elease he ight thr eshold i s know n a s t he G ood E ngineering P ractice ( GEP) he ight. G EP stack height is defined in Section 123 of the Clear Air Act Amendments of 1977 as:

“the height necessary to ensure that emissions from the stack do not result in excessive

concentrations of any air pollutant in the immediate vicinity of the source as a result of atmospheric downwash, eddies, and wakes which may be created by the source itself, nearby structures, or nearby terrain obstacles.”PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 30

The E PA G uideline f or D etermination of Good Engi neering P ractice S tack Height 1 contains detailed guidance on issues relating to the determination of GEP height. This guidance specifies use of the following formula for “new” stacks ( e.g., stacks not in existence until after J anuary 1979) for calculating the minimum stack height for which the adverse aerodynamic effects are

avoided.

H GEP = H B + 1.5 L, where

H GEP = GEP formula stack height

H B = height of building or nearby structure

L = lesser of the height or projected width of the structure

The formula for stacks in existence before 1979 is:

H GEP = 2.5 H B
Both the height and projected width of the structure are determined from the projection of the structure on a plane perpendicular to the direction of the wind. T he downwind area in which a

ne arby structure is presumed to have a s ignificant effect on a stack is defined as 5L. Therefore, the GEP formula heights calculated by the formulas listed above are only applicable to stacks that are located within 5L of the building or structure in question.

No stack height that exceeds GEP stack height (predicted by the formulae) can be used in any modeling that is used to determine emission limitations. This does not limit actual stack height, only the portion of stack height that can be used in modeli ng. T he construction date for both boiler stacks is prior to 1979. S tacks in other areas of the mill were constructed in periods both before and after 1979. All modeled stack heights at the Mill are less than the calculated GEP formula heights (see Sect ion C.3 for detailed calculations).

G- P entered the dimensions for a ll s ignificant bui lding s tructures a t the M ill int o the E PA program, B uilding P rofile I nput P rogram. T he B PIP pr ogram computes direction

- specific building heights and widths. These data describe the downwash effects to the dispersion model.

Table D

- 1 presents a summary of the horizontal a nd ve rtical ( above grade) di mensions of t he Mill s tructures a nalyzed by B PIP. A dditional s mall ta nks a nd structures e xist a t the M ill. However, G

- P exc luded structures with heights and widths (or diameters) less than 10 feet (ft) or other remote structures. Figures D

- 3 and D

- 4 in the application present plot plan drawings of the buildings, tanks, and sources.

Table D -1. Summary of Downwash Structures Analyzed at G

- P Muskogee Mill

1 EPA, 1985. Guideline for Determination of Good Engineering Practice Stack Height (Technical Support Document for the Stack Height Regulation) Revised. EPA450/4

- 80

- 023R BPIP ID Building Description Base Elev. (m) Peak Ht (m)

BLD #1 BLD #1 165.4 15.24

BLD #2 BLD #2 163 15.24

BLD #3 BLD #3 163 7.32

BLD #4 BLD #4 158.1 13.72

BLD #5 BLD #5 159.5 13.72

BLD #6 BLD #6 160.2 8.53PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 31

BPIP ID Building Description Base Elev. (m) Peak Ht (m)

BLD #7 BLD # 7 160.2 8.53

BLD #8 BLD #8 162.3 25.6

BLD #9 BLD #9 162.8 15.54

BLD #10 BLD #10 163.8 15.54

BLD #11 BLD #11 164.2 15.54

BLD #12 BLD #12 162.5 18.29

BLD #14 BLD #14 161.9 5.18

BLD #15 BLD #15 160.7 7.01

BLD #16 BLD #16 156.8 15.24

BLD #18 BLD #18 1 59.2 15.24

BLD #20 BLD #20 163.5 15.54

BLD #21 BLD #21 161.1 9.45

BLD #22 BLD #22 162.8 8.53

BLD #23 BLD #23 159.8 25.6

BLD #24 BLD #24 162.1 15.54

BLD #25 BLD #25 157.1 15.24

BLD #26 BLD #26 158.7 15.24

BLD #27 BLD #27 164.2 15.54

BLD #28 BLD #28 161.6 18.29

BLD #29 BLD #29 162.3 6.1

BLD #30 BLD #30 161.7 15.24

BLD #31 BLD #31 164.9 15.54

BLD #32 BLD #32 159.6 25.6

BLD #34 BLD #34 161.7 8.53

BLD #36 BLD #36 165.7 15.24

BLD #39 BLD #39 156.5 15.24

BLD #40 BLD #40 161 25.6

BLD #41 BLD #41 1 61 15.24

BLD #42 BLD #42 159.6 15.24

BLD #43 BLD #43 160.2 15.24

BLD #44 BLD #44 162.3 15.24

BOILERS BOILER COMPLEX 162.6 39.62

COOLLT COAL PILE LONG TERM 162.1 9.14

COOLM COOLING TWR MIDDLE 159.9 18.29

COOLN COOLING TOWER N 160.6 18.29

COOLS COOLI NG TOWER S 160.1 12.19

COOLST COAL PILE SHORT TERM 162 15.24PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 32

Table D

- 2 presents a summary of structure dimensions for storage tanks also considered in the downwash analysis. While additional tanks and structures exist at the Mill, the analysis excluded structures with heights and widths (or diameters) less than 10 ft.

Table D -2

BPIP ID Building Description Base Elevation (m) Tank Height(m) Tank Diameter (m)

TANK4 1 Near Bldg 4 Tank 1 158.7 30.48 16

TANK5 1 Near Bldg 5 Tank 1 158.5 30.48 11.4

TANK5 2 Near Bldg 5 Tank 2 158.2 30.48 12

TANK8 1 Near Bldg 8 Tank 1 158.6 15.24 10.6

TANK8 2 Near Bldg 8 Tank 2 159.4 15.24 10.6

TANK8 3 Near Bldg 8 Tank 3 160.6 15.24 10.6

TANK8 4 Near Bldg 8 Tank 4 161.2 15.24 10.6

TANK14 1 Near Bldg 14

- Tank 1 162 5.18 47

TANK14 2 Near Bldg 14 Tank 2 160.9 5.18 31.7

TANK14 3 Near Bldg 14 Tank 3 160.6 5.18 31.6

TANK23 1 Near Bldg 23 Tank 1 158.4 15.24 10.6
Tank 23 2 Near Bldg 23 Tank 2 158.4 15.24 10.6
Tank 32 1 Near Bldg 32 Tank 1 159.9 15.24 10.6
Tank 32 2 Near Bl dg 32 Tank 2 159.3 15.24 10.6
Tank 40 1 Near Bldg 40 Tank 1 161.9 15.24 10.6
Tank 40 2 Near Bldg 40 Tank 2 161.8 15.24 10.6
Tank 40 3 Near Bldg 40 Tank 3 161.3 15.24 10.6

D.2.6. SIGNIFICANT IMPACT ANALYSIS Purpose and Methodology The significant imp act analysis is the first phase of the Source Impact Analysis and determines

two results: 1) the maximum impacts from the project emissions increase and 2) the location of predicted impacts greater than significant impact levels (SILs). The area of these impacts defines the impact area of the project and the significant impact distance (SID).

G- P performed a significant impact analysis to determine whether the emission increases result in maximum predicted impacts greater than the P SD mode ling S ILs or th e E PA m onitoring de minimis concentrations. Current EPA and ODEQ policies stipulate that G

- P compare the highest predicted s hort

- term impa cts to these le vels. Table D

- 3 pr esents t he S ILs a nd de minimis

concentrations.

Table D -3

Pollutant Averaging

Time Significant Impact Levels (μg/m 3 ) De Minimis Concentration (μg/m 3 )

PM 10 24

- hour 5 10

Annual 1

-- NO 2 Annual 1 14

SO 2 3

- hour 25

-- 24

- hour 5 13

Annual 1

-- CO 1

- hour 2,000

-- 8

- hour 500 575PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 33

Model Inventory For the significant impact analysis, t he model inventory only includes point and fugitive sources that w ill ex perience an increase or de crease i n emissions due t o the pr oject. The emission increase r epresents t wo sets of s ources. For s ources phy sically m odified, G

- P de termined an

emission in crease by calculating t he di fference be tween the pot ential m aximum em issions limited by permit or source capacity, and the actual level of emissions for the period 2002 -2003.

G- P calculated annual and short

- term average emission changes. Table D

- 4 present s the baseline emissions, potential e missions a nd computes the di fference in particulate ma tter ( PM 10 ) emissions from the modified project sources.

Table D

- 4 PM 10 Significant Impact Analysis Emiss

. Rates

Model ID Source Description Baseline (TPY) Potenti al (TPY) Project (TPY) Project (g/s) No. 11 and 12 Paper Machines (a) (b)

1112_8 PM 11 Yankee Wet End Exh.

- process 1.16 2.19

2.17 0.062 PM 11Yankee Wet End Exh.

- burner 0.26 1.40

PM 11 Yankee Wet End Exh.

- total 1.42 3.59

1112_7 PM 11 Y ankee Dry End Exh.

- process 1.16 2.19

2.17 0.062 PM 11Yankee Dry End Exh.

- burner 0.26 1.40 PM 11 Yankee Dry End Exh.

- total 1.42 3.59

1112_20 PM12 Yankee Exh

- process 3.71 6.13

4.32 0.124 PM12 Yankee Exh

- burner 0.90 2.80

PM12 Yank ee Exh

- total 4.61 8.93 1112_1 Building Exhaust 0.35 0.61 0.26 0.0077 1112_2 Building Exhaust 0.35 0.61 0.26 0.0077 1112_3 Building Exhaust 0.35 0.61 0.26 0.0077 1112_4 Building Exhaust 0.35 0.61 0.26 0.0077 1112_5 Building Exhaust 0.35 0.61 0.26 0 .0077 1112_9 Building Exhaust 0.35 0.61 0.26 0.0077 1112_10 Building Exhaust 0.35 0.61 0.26 0.0077 1112_11 Building Exhaust 0.35 0.61 0.26 0.0077 1112_13 Building Exhaust 0.35 0.61 0.26 0.0077 1112_14 Building Exhaust 0.35 0.61 0.26 0.0077 1112_15 Bu ilding Exhaust 0.35 0.61 0.26 0.0077 1112_17 After Dryer Exh. 0.29 0.51 0.22 0.0064 1112_18 After Dryer Exh. 0.29 0.51 0.22 0.0064 1112_19 After Dryer Exh. 0.29 0.51 0.22 0.0064 1112_22 Vacuum Pump 0.18 0.31 0.13 0.0039 1112_23 Vacuum Pump 0.18 0.31 0 .13 0.0039 1112_24 Former Exh 0.37 0.65 0.28 0.0082 1112_25 Fan Pump Silo 0.04 0.07 0.03 0.00091 1112_26 Wall Exh. 0.18 0.31 0.13 0.0039 1112_28 Wall Exh. 0.18 0.31 0.13 0.0039 1112_29 Fan Pump Silo 0.04 0.06 0.03 0.0008 1112_30 Former Exh 0.36 0.63 0.27 0.0079 1112_31 Wall Exh. 0.18 0.31 0.13 0.0039 1112_27 Wall Exh. 0.18 0.31 0.13 0.0039 1112_32 Wall Exh. 0.18 0.31 0.13 0.0039PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 34

Table D

- 4 PM 10 Significant Impact Analysis Emiss

. Rates

Model ID Source Description Baseline (TPY) Potenti al (TPY) Project (TPY) Project (g/s) Paper Machine 13

13_13 Yankee Economizer

- burner 0.729 2.796

3.92 0.113 Yankee Economizer

- process 3.406 5.256

Yankee Economizer

- total 4.135 8.052 13_1 Roof Exhausts 0.30 0.47 0.17 0.005 13_2 Roof Exhausts 0.30 0.47 0.17 0.005 13_3 Roof Exhausts 0.30 0.47 0.17 0.005 13_4 Roof Exhausts 0.30 0.47 0.17 0.005 13_5 Roof Exhausts 0.30 0.47 0.17 0.005 13_6 Ro of Exhausts 0.30 0.47 0.17 0.005 13_7 Roof Exhausts 0.30 0.47 0.17 0.005 13_10 After Dryer Hood Exh 0.56 0.86 0.30 0.009 13_14 Fan Pump Silo 0.06 0.09 0.03 0.001 13_17 Vacuum Pump 0.25 0.39 0.14 0.004 13_18 Former Exh 0.41 0.64 0.22 0.006 13_19 Wall Exh. Fan 0.21 0.33 0.11 0.003 13_20 Wall Exh. Fan 0.21 0.33 0.11 0.003 Paper Machine 14

14_13 Yankee Wet End Exh.

- burner 0.255 1.398

1.968 0.057 Yankee Wet End Exh.

- process 1.803 2.628

Yankee Wet End Exh.

- total 2.058 4.026

14_17 Yanke e Dry End Exh.burner 0.255 1.398

1.968 0.057 Yankee Dry End Exh.process 1.803 2.628 Yankee Dry End Exh. total 2.058 4.026 14_1 Vacuum Pump exh. 0.18 0.26 0.08 0.010 14_2 Building exh. 0.33 0.48 0.15 0.002 14_3 Building exh. 0.33 0.48 0.15 0.0 04 14_4 Building exh. 0.33 0.48 0.15 0.004 14_5 Building exh. 0.33 0.48 0.15 0.004 14_6 Building exh. 0.33 0.48 0.15 0.004 14_7 Building exh. 0.33 0.48 0.15 0.004 14_8 Building exh. 0.33 0.48 0.15 0.004 14_9 Building exh. 0.33 0.48 0.15 0.004 14_10 Fan Pump Silo Exh. 0.27 0.40 0.13 0.004 14_11 Former Exh. 0.32 0.46 0.15 0.004 14_20 Wall Exh. Fan 0.27 0.40 0.13 0.004 14_21 Wall Exh. Fan 0.27 0.40 0.13 0.004 14_22 Wall Exh. Fan 0.27 0.40 0.13 0.004 Paper Machine 15

15_13 Yankee Wet End Exh.

- bur ner 0.214 0.999

1.427 0.041 Yankee Wet End Exh.

- process 1.778 2.420

Yankee Wet End Exh.

- total 1.992 3.419

15_18 Yankee Dry End Exh.burner 0.214 0.999

1.427 0.041 Yankee Dry End Exh.process 1.778 2.420 Yankee Dry End Exh. total 1.99 2 3.419 15_11 Riffler Roof Exhaust 0.20 0.28 0.074 0.002PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 35

Table D

- 4 PM 10 Significant Impact Analysis Emiss

. Rates

Model ID Source Description Baseline (TPY) Potenti al (TPY) Project (TPY) Project (g/s) 15_12 Former Exhaust w/ separator 0.50 0.67 0.179 0.005 15_2 Roof Exh. 0.28 0.39 0.102 0.0029 15_3 Roof Exh. 0.28 0.39 0.102 0.0029 15_4 Roof Exh. 0.28 0.39 0.102 0.0029 15_5 Roof Exh. 0.28 0 .39 0.102 0.0029 15_6 Roof Exh. 0.28 0.39 0.102 0.0029 15_7 Roof Exh. 0.28 0.39 0.102 0.0029 15_8 Roof Exh. 0.28 0.39 0.102 0.0029 15_9 Roof Exh. 0.28 0.39 0.102 0.0029 15_22 Roof Exh. 0.28 0.39 0.102 0.0029 15_1 Vacuum Pump Silo 0.34 0.46 0.123 0.00 35 15_19 Wall Fan 0.24 0.32 0.085 0.0025 15_20 Wall Fan 0.24 0.32 0.085 0.0025 15_21 Fan Pump Silo 0.14 0.20 0.052 0.0015 Subtotals for all Paper Machine emissions 38.570 68.376 29.807 1.633

For sources affected by a change in a production rate ( i.e.

, debottlenecking), G

- P determined an emission i ncrease by c alculating t he a mount of e missions attributable to the production rate change. Table D

- 5 presents the emission changes associated with the project at affected emission sources for particulate matter.

Table D -5

Model ID Source Description Project Emission

Rates
(TPY) (g/s)
Steam Production by Boilers (a)

Stack1 Boilers 1 and 2 34.824 1.002

Stack3 Boilers 3 and 4 34.824 1.002
Associated Fuel Handling for Steam Production

RCUN Railcar Unload 0.008 0.00024

STKER Coal Stacker 0.008 0.00024

CRUSHER Coal Crusher 0.11 0.0105

GRIZZLY Coal Grizzly 0.008 0.00024

BNKXF Bunker Coal Transfer 0.73 0.021

Roads

RDA1..A39 Main Gate to 1st intersection 0.108 0.003

RDB1..B57 1st Intersection to Coal Pi le 0.006 0.000

RDC1..C28 1st Intersection to Shipping/Rcv 0.079 0.002

RDD1..D300 Ash Management 1.149 0.033
(a) Steam increase can be produced by any boiler. The total PM 10 emission increase attributable to the project for steam is 2.0 grams/sec. The emission rate reflects the permit limit of 0.1 lb s /MMBtu. The analysis to determine project impact divided these emissions equally between the two stacks.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 36

Tables D

- 6, D

- 7, and D

- 8 present the project emissions for sulfur dioxide, nitrogen oxides, and

car bon monoxide, respectively.

Table D -6

Model ID Source Description Annual Fuel Usage (MMBTU) SO 2 Emission Rates for Significant Impact Analysis

Baseline

(TPY) Potential (TPY) Project (TPY) Project (g/s) Baseline Potential

Modified Sources

11 12_8 PM 11 Yankee Wet End 56813.5 219000 0.020 0.110 0.090 0.0026 1112_7 PM 11 Yankee Dry End 56813.5 219000 0.020 0.110 0.090 0.0026 1112_20 PM12 Yankee Exh 197251 438000 0.071 0.221 0.150 0.0043 13_13 PM 13 Yankee Economizer 159772 438000 0.058 0.221 0.163 0.0047 14_13 PM 14 Yankee Wet End 55868 219000 0.020 0.110 0.090 0.0026 14_17 PM 14 Yankee Dry End 55868 219000 0.020 0.110 0.090 0.0026 15_13 PM 15 Yankee Wet End 46840 219000 0.017 0.079 0.062 0.0018 15_18 PM 15 Yankee Dry End 46840 219000 0.01 7 0.079 0.062 0.0018

Affected Sources

Stack1 Boilers 1 and 2 (a) NA NA NA NA 193.2 5.56

Stack3 Boilers 3 and 4 (a) NA NA NA NA 193.2 5.56

Totals 0.24 1.05 387.12 11.14
(a) N et E mission R ate i ncrease r eflects an at tributable h eat i nput o f 6 43,860 M M Btu/yr or 73. 5 M MBtu/hr a nd w orst

- case f uel. Attributable B oiler E missions m ay b e e xhausted v ia e ither S tack 1 o r S tack 2 . Total attributable emissions are equal t o 73. 5

MMBtu/hr x 1.2 lb s SO 2 /MMBtu x 454 g/lb x hr/3

, 600s = 11.13 gram/s

Table D -7

Model ID Source Description Annual Fuel Usage (MMBTU) NO X Emission Rates for Significant Impact Analysis

Baseline

(TPY) Potential (TPY) Project (TPY) Project (g/s) Baseline Potential

Modified Sources 1112_8 PM 11 Yankee Wet End 56813.5 306600 3.409 18.40 14.99 0.43 1112_7 PM 11 Yankee Dry End 56813.5 306600 3.409 18.40 14.99 0.43 1112_20 PM12 Yankee Exh 197251 613200 11.835 36.79 24.96 0.72 13_13 PM 13 Yankee Economizer 159772 613200 9.586 36.79 27.21 0.78 14_13 PM 14 Yankee Wet End 55868 306600 4.190 23.00 18.80 0.54 14_17 PM 14 Yankee Dry End 55868 306600 4.190 23.00 18.80 0.54 15_13 PM 15 Yankee Wet End 46840 306600 3.513 16.425 12.91 0.37 15_18 PM 15 Yankee Dry End 46840 306600 3.513 16.425 12.91 0.37

PPRTO Proposed Press RTO 0 26280 0.88 2.19 1.31 0.038

Affected Sources

Stack1 Boilers 1 and 2 (a) NA NA NA NA 112.7 3.24

Stack3 Boilers 3 and 4 (a) NA NA NA NA 112.7 3.24

Totals 44.52 191.41 372.24 10.71
(a) N et E mission R ate i ncrease r eflects an at tributable h eat i nput o f 6 43,860 M MB tu/yr or 73. 5 M MBtu/hr a nd w orst

- case f uel. Attributable Boiler Emissions may be exhausted via either Stack 1 or Stack 2. Actual model runs applied two source groups fo r these

two cases. Total attributable emissions are equal to 73.5 MMBtu/hr x 0.7 lb s N Ox/MMBtu x 454 g/lb x hr/3

, 600s = 6.48 gram/s.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 37

Table D -8

Model ID Source Description Annual Fuel Usage (MMBTU) CO Emission Rates for Significant Impact Analysis

Baseline

(TPY) Potential (TPY) Project (TPY) Project (g/s) Baseline Potential

M odified Sources 1112_8 PM 11 Yankee Wet End 56813.5 306600 10.510 56.72 46.21 1.33 1112_7 PM 11 Yankee Dry End 56813.5 306600 10.510 56.72 46.21 1.33 1112_20 PM12 Yankee Exh 197251 613200 28.601 88.91 60.31 1.74 13_13 PM 13 Yankee Economizer 159772 613 200 23.167 88.91 65.75 1.89 14_13 PM 14 Yankee Wet End 55868 306600 12.291 67.45 55.16 1.59 14_17 PM 14 Yankee Dry End 55868 306600 12.291 67.45 55.16 1.59 15_13 PM 15 Yankee Wet End 46840 306600 10.305 48.18 37.88 1.09 15_18 PM 15 Yankee Dry End 46840 306600 10.305 48.18 37.88 1.09

PPRTO Proposed Press RTO 0 26280 0 3.68 3.68 0.11

Affected Sources

Stack1 Boilers 1 and 2 (a) NA NA NA NA 13.5 0.39

Stack3 Boilers 3 and 4 (a) NA NA NA NA 13.5 0.39

Totals 117.98 285.75 194.81 5.60
(a) N et E mission Rate i ncrease r eflects an at tributable h eat i nput o f 6 43,860 M MBtu/yr o r 7 3.5 MM Btu/hr an d worst

- case f uel. Attributable Boiler Emissions may be exhausted via either Stack 1 or Stack 2. Actual model runs applied two source groups fo r these

two cases. Tot al attributable emissions are equal to 73.5 MMBtu/hr x 0.084 lb s CO/MMBtu x 454 g/lb x hr/3

, 600s = 0.78 gram/s.

G-P modeled point sources using the POINT source type. Table D

- 9 presents source modeling parameters

for POINT sources.

Table D -9

Model ID Des cription Source Location UTM (m) Stack Parameters

East North Hs (m) Temp K Vs (m/s) Ds (m)

STACK3 STACK #3

– BOILERS

B

- 3 & B

- 4 292538 3956420 79.3 433.15 12.06 4.20

STACK1 STACK #1 - BOILER B -2 292498 3956399 79.3 410.93 13.2 3.05

1112_1 Building Exh aust 292399 3956330 26.3 295 0.001 1.22

1112_2 Building Exhaust 292400 3956345 26.3 295 0.001 1.22

1112_3 Building Exhaust 292401 3956359 26.3 295 0.001 1.22

1112_4 Building Exhaust 292401 3956420 26.3 295 0.001 1.22

1112_5 Building Exhaust 292415 3956333 26.3 295 0.001 1.22

1112_9 Building Exhaust 292413 3956335 26.3 295 0.001 1.22

1112_10 Building Exhaust 292413 3956344 26.3 295 0.001 1.22

1112_11 Building Exhaust 292413 3956357 26.3 295 0.001 1.22

1112_13 Building Exhaust 292379 3956330 26.3 295 0.001 1.22

1112_14 Building Exhaust 292385 3956335 26.3 295 0.001 1.22

1112_15 Building Exhaust 292386 3956345 26.3 295 0.001 1.22

1112_8 Yankee Wet End Exh. 292416 3956372 27.6 400 14.7 1.74

1112_7 Yankee Dry End Exh 292419 3956372 27.6 400 14.7 1.74

1112_17 After Dryer Exh. 292383 3956362 25.5 295 16.84 1.22PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 38

Table D -9

Model ID Des cription Source Location UTM (m) Stack Parameters

East North Hs (m) Temp K Vs (m/s) Ds (m)
1112_18 After Dryer Exh. 292384 3956380 25.5 295 16.84 1.22

1112_19 After Dryer Exh. 292384 3956383 25.5 295 16.84 1.22

1112_20 Yankee Exh 292376 3956386 25.5 400 10.47 2.80

1112_22 Vacuum Pump 292376 3956336 24.7 295 80 0.30

1112_23 Vacuum Pump 292421 3956349 24.7 295 80 0.30

1112_24 Former Exh 292422 3956342 3.7 295 0.001 1.80

1112_25 Fan Pump Silo 292418 3956352 16.2 295 0.001 0.91

1112_26 Wall Exhaust 292420 3956333 12.2 295 0.001 1.22

1112_28 Wall Exhaust 292376 3956328 12.2 295 0.001 1.22

1112_29 Fan Pump Silo 292376 3956341 16.2 295 0.001 0.91

1112_30 Former Exh 292373 3956353 6.1 295 20.62 1.22

1112_32 Wall Exhaust 292410 3956322 12.2 295 0.001 1.22

13_1 Roo f Exhausts 292336 3956328 26.4 295 0.001 1.52

1112_31 Wall Exhaust 292382 3956322 12.2 295 0.001 1.22

1112_27 Roof Exhausts 292426 3956367 12.2 295 0.001 0.00

13_2 Roof Exhausts 292332 3956358 26.4 295 0.001 1.52

13_3 Roof Exhausts 292344 3956334 26.4 295 0.001 1.52

13_4 Roof Exhausts 292344 3956340 26.4 295 0.001 1.52

13_5 Roof Exhausts 292345 3956345 26.4 295 0.001 1.52
13_6 Roof Exhausts 292344 3956357 26.4 295 0.001 1.52
13_7 Roof Exhausts 292349 3956330 26.4 295 0.001 1.52
13_10 Aft er Dryer Hood Exh 292348 3956370 26.4 295 21.08 1.52
13_13 Yankee 292351 3956383 26.4 400 10.91 1.74
13_14 Fan Pump Silo 292348 3956350 28.3 295 21.08 0.46
13_17 Vacuum Pump 292318 3956342 25.6 295 20.12 0.91
13_18 Former Exh 292353 3956347 6.1 295 21.56 1.22
13_19 Wall Exhaust Fan 292353 3956332 18.9 295 19.7 1.22
13_20 Wall Exhaust Fan 292353 3956335 18.9 295 0.001 0.61
14_1 Vacuum Pump Exhaust 292258 3956345 27.1 295 8.55 1.07
14_2 Building Exhaust 292269 3956330 26.4 295 0.001 1.22
14_3 Building Exhaust 292269 3956335 26.4 295 0.001 1.22
14_4 Building Exhaust 292269 3956341 26.4 295 0.001 1.22
14_5 Building Exhaust 292269 3956347 26.4 295 0.001 1.22
14_6 Building Exhaust 292269 3956353 26.4 295 0.001 1.22
14_7 Building Exhau st 292269 3956362 26.4 295 0.001 1.22
14_8 Building Exhaust 292269 3956385 26.4 295 0.001 1.22
14_9 Building Exhaust 292269 3956410 26.4 295 0.001 1.22
14_10 Fan Pump Silo Exhaust 292289 3956332 26.5 295 13.2 1.07PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 39

Table D -9

Model ID Des cription Source Location UTM (m) Stack Parameters

East North Hs (m) Temp K Vs (m/s) Ds (m) 14_11 Former Exhaust 292285 3956336 28.9 295 20.84 0.91
14_13 Yankee Wet 292291 3956359 30.5 400 22.93 1.88
14_17 Yankee Dry 292293 3956391 30.5 400 22.93 1.88
14_20 Wall Exhaust Fan 292272 3956327 12.2 295 0.001 1.22
14_21 Wall Exhaust Fan 292292 3956366 12.2 295 0.001 1.22
14_22 Wall Exhaust Fan 292297 3956325 12.2 295 0.001 1.22
15_11 Riffler Roof Exhaust 292227 3956329 27.1 295 8.77 1.22

15_12 Former Exhaust w/
separator 292227 3956333 28.7 295 21.22 1.22

15_2 Roof Exhaust 292206 3956334 27.1 295 12.13 1.22
15_3 Roo f Exhaust 292206 3956340 27.1 295 12.13 1.22
15_4 Roof Exhaust 292206 3956346 27.1 295 12.13 1.22
15_5 Roof Exhaust 292206 3956353 27.1 295 12.13 1.22
15_6 Roof Exhaust 292206 3956358 27.1 295 12.13 1.22
15_7 Roof Exhaust 292206 3956364 27.1 295 12.13 1.22
15_8 Roof Exhaust 292206 3956406 27.1 295 12.13 1.22
15_9 Roof Exhaust 292206 3956419 27.1 295 12.13 1.22
15_22 Roof Exhaust 292211 3956321 27.1 295 12.13 1.22
15_1 Vacuum Pump Silo 292192 3956345 27.4 295 19.01 1.07
15_13 Wet End Yankee Exhaust 292229 3956342 31.6 400 18.48 2.13
15_18 Dry End Yankee Exhaust 292229 3956380 31.6 400 18.48 2.13
15_19 Wall Fan 292214 3956322 12.2 295 0.001 1.22
15_20 Wall Fan 292233 3956325 12.2 295 0.001 1.22
15_21 Fan Pump Silo 292234 3956329 12.2 295 0.001 0.91

PPRTO Proposed Press RTO 291954 3956854 9.14 402 15.4 1.29

G- P modeled fugitive sources using the VOLUME source type. The VOLUME source type applies two dimensions and a square base to represent the emission source. In cases where the m odel cannot approximate a fugitive emission source as a s ingle s quare ba se m odel s ource, G

- P di vided t he emission source into multiple identical sources. G

- P divided the emission rate equally among the model sources. Table D-10 presents the fugitive emission source parameters for VOLUME sources.

Table D

- 10 Roads Railcar

Unload Coal

Stacker Coal

Crusher Coal Grizzly Bunker

Transfer

Model ID Various RCUN STKER CRUSHER GRIZZLY BNKXF Source ht (m) 7.3 5.0 1.0 11.4 3.0 1.0 Release Ht (m) 3.7 2.5 14.6 5.7 1 .5 31.4

Surface Based or Elevated Surface Surface Elevated Surface Surface Elevated Side Length (m) 14.1 7.5 14.1 11.8 3.5 1.0 Initial Lateral dim. (Σy) (m) 6.6 3.5 6.6 5.5 1.6 0.5 Source ht (m) 7.3 5.0 1.0 11.4 3.0 1.0 Initial Vertical dim (Σz) (m) 3 .4 1.2 0.2 2.7 0.7 0.2PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 40

“Volume Source Inputs” in the EPA’s User’s Guide for the Industrial Source Complex (ISC3) Dispersion

Models Volume I - User Instructions (EPA -454/B-95-003a)

Receptor Locations All analyses will use screening and refined Cartesian r eceptor grids. The receptors are spaced at

25- m i ntervals a long t he f enceline, a t 100

- m i ntervals w ithin 3 km of t he M ill, and at 500

- m intervals beyond 7.5 km of the Mill. G- P inspected the analysis results to determine if predicted impacts at t he edg es of the most coarse r eceptor g rid were de creasing. T he ana lysis w as supplemented with additional r efined receptor s ets if the receptor spacing at the maximum impact location was more than 100 m . T he analysis modeled all areas, including our property

outs ide the fence, as ambient air. G- P compiled the terrain and source elevations using USGS Digital Elevation Model 7.5

- minute series data. G

- P used the AERMAP program to interpolate the raw USGS DEM data into the uniform receptor grids. The raw datasets w ere prepared by the

USGS with a resolution of 30 m for the 7.5

- minute data. G

- P inspected the resultant grid files for accuracy. G-P used the fine resolution dataset (i.e., 7.5 minute series) to extract terrain data.

D.2.7 NAAQS MODELING ANALYSIS Purpose and Methodology As discussed in the result section, preliminary m odeling of t he pr oposed pr oject i ndicated a significant impact ( i.e., maximum impact at or above the PSD significance levels) for NO 2 , SO 2 , and P M 10 . T herefore, PSD r eview r equires G

- P to perform a f ull a ir qua lity a nalysis to demonstrate compliance with the NAAQS. The NAAQS impact analysis predicts the maximum ambient air concentration due to 1) a ll M ill s ources e mitting a t ma ximum pot ential e mission rates, 2) of f

- site s ources a t ma ximum permitted r ates, a nd 3) na tural a nd ba ckground s ources. The t otal of t hese c oncentrations m ust be l ess t han the NAAQS. Table D

- 11 summarizes the NAAQS.

Table D -11

Pollutant Averaging

Time NAAQS (μg/m 3 ) Form of Standard

PM 10 24

- hour 150 High

- sixth

- highest for 5 years

Annual 50 Annual Mean

NO 2 Annual 100 Annual Mean

SO 2 3

- hour 1,300 High

- second

- highest for each year

24-hour 365 High

- second

- highest for each year

Annual 80 Annual Mean

Back ground Concentrations Background concentrations ar e ne cessary t o determine t otal am bient ai r qua lity impacts to demonstrate compliance with the NAAQS. “ Background c oncentrations” a re de fined a s concentrations due t o s ources ot her t han t hose s pecifically i ncluded i n t he m odeling a nalysis. For example, background concentration would account for other small point sources not included in the m odeling, f ugitive e mission s ources, a nd na tural ba ckground s ources ( e.g., mobile sources).PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 41

ODEQ r ecommended conservat ive values for background c oncentrations c onsidering m onitor locations, t heir pr oximity t o t he M uskogee M ill, da ta qua lity, a nd how r ecent t he da ta was

collected. T able D

- 12 pr esents t he ba ckground c oncentrations i n m icrograms pe r c ubic m eter (μg/m 3 ) used for the analyses.

Table D

- 12

Pollutant Monitor and Data Description Averaging

Period Background Concentration (ppm) (μg/m 3 )

SO 2 Muskogee – 2004 High Second High for 3- hour and 24-hour; 2004 Annual mean 3

- hr 0.061 159.8

24

- hr 0.016 41.9

Annual 0.0026 6.8

NO 2 Tulsa

- 2004 Annual Mean Annual 0.0054 10.2

PM 10 Muskogee – 2002-2004 High Fourth High

and 2004 Annual mean 24

- hr

-- 72

Annual

-- 23.2
Note: ODEQ recommended these values in an e- mail from E

. Milligan to M. Aguilar, 2/2/2005

Inventory – G-P For the NAAQS impact analysis, t he m odel i nventory i ncludes a ll e mission s ources f rom t he entire M ill a t t heir pot ential e mission r ates. T he i nventory doe s not i nclude a ny of fset or negative emission sources. Table D

- 13 summarizes the emission rates for the NAAQS analyses. The modeled emission rates are identical to the rates in the current Title V permit application (with exceptions noted).

Table D -13

Model ID Source Description Emission Rates (g/s)

PM 10 SO 2 NO X 1112_7 PM 11 Yankee Dry End Exh. Maximum 0.103 0.003 0.363 1112_8 PM 11 Yankee Wet End Exh.Maximum 0.103 0.003 0.363 1112_20 PM12 Yankee Exh

- Maximum 0.257 0.0064 0.4990 13_13 PM13 Yankee Economizer

- Maximum 0.232 0.0047 1.0584 14_13 PM14 Yankee Wet End Exh. - Maximum 0.116 0.0032 0.6615 14_17 PM17 Yankee Dry End Exh.

- Maximum 0.116 0.0032 0.6615 15_13 PM15 Yankee Wet End Exh.

- Maximum 0.110 0.0032 0.378 15_18 PM15 Yankee Dry End Exh.

- Maximum 0.110 0.003 0.378 1112_20 PM12 Yankee 0.243 0.0021 1.0584 1112_1 Building Ex haust 0.018

-- -- 1112_2 Building Exhaust 0.018

-- -- 1112_3 Building Exhaust 0.018

-- -- 1112_4 Building Exhaust 0.018

-- -- 1112_5 Building Exhaust 0.018

-- -- 1112_9 Building Exhaust 0.018

-- -- 1112_10 Building Exhaust 0.018

-- -- 1112_11 Buildi ng Exhaust 0.018

-- -- 1112_13 Building Exhaust 0.018

-- -- 1112_14 Building Exhaust 0.018

-- -- 1112_15 Building Exhaust 0.018

-- -- 1112_17 After Dryer Exh. 0.015

-- --PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 42

Table D

- 13

Model ID Source Description Emission Rates (g/s)

PM 10 SO 2 NO X 1112_18 After Dryer Exh. 0.015

-- -- 1112_19 After Dryer Exh. 0.015

-- -- 1112 _22 Vacuum Pump 0.009

-- -- 1112_23 Vacuum Pump 0.009

-- -- 1112_24 Former Exh 0.019

-- -- 1112_25 Fan Pump Silo 0.002

-- -- 1112_26 Wall Exh. 0.009

-- -- 1112_28 Wall Exh. 0.009

-- -- 1112_29 Fan Pump Silo 0.002

-- -- 1112_30 Former Exh 0.018

-- -- 1112_31 Wall Exh. 0.009

-- -- 1112_27 Wall Exh. 0.009

-- -- 1112_32 Wall Exh. 0.009

-- -- 13_13 Yankee Economizer 0.218 0.0024 1.0584 13_1 Roof Exhausts 0.013

-- -- 13_2 Roof Exhausts 0.013

-- -- 13_3 Roof Exhausts 0.013

-- -- 13_4 Roof Exhausts 0.013

-- -- 13_5 Roof Exhausts 0.013

-- -- 13_6 Roof Exhausts 0.013

-- -- 13_7 Roof Exhausts 0.013

-- -- 13_10 After Dryer Hood Exh 0.025

-- -- 13_14 Fan Pump Silo 0.003

-- -- 13_17 Vacuum Pump 0.011

-- -- 13_18 Former Exh 0.018

-- -- 13_19 Wall E xh. Fan 0.009

-- -- 13_20 Wall Exh. Fan 0.009

-- -- 14_13 Yankee Wet End 0.109 0.0014 0.5292 14_17 Yankee Dry End 0.109 0.0014 0.5292 14_1 Vacuum Pump exh. 0.007

-- -- 14_2 Building exh. 0.014

-- -- 14_3 Building exh. 0.014

-- -- 14_4 Building exh

. 0.014

-- -- 14_5 Building exh. 0.014

-- -- 14_6 Building exh. 0.014

-- -- 14_7 Building exh. 0.014

-- -- 14_8 Building exh. 0.014

-- -- 14_9 Building exh. 0.014

-- -- 14_10 Fan Pump Silo Exh. 0.012

-- -- 14_11 Former Exh. 0.013

-- -- 14_20 Wall E xh. Fan 0.012

-- -- 14_21 Wall Exh. Fan 0.012

-- --PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 43

Table D

- 13

Model ID Source Description Emission Rates (g/s)

PM 10 SO 2 NO X 14_22 Wall Exh. Fan 0.012

-- -- 15_13 Yankee Wet End 0.103 0.0015 0.5292 15_18 Yankee Dry End 0.103 0.0015 0.5292 15_11 Riffler Roof Exhaust 0.009

-- -- 15_12 Former Exhaust w/ separator 0.021

-- -- 15_2 Roof Exh. 0.012

-- -- 15_3 Roof Exh. 0.012

-- -- 15_4 Roof Exh. 0.012

-- -- 15_5 Roof Exh. 0.012

-- -- 15_6 Roof Exh. 0.012

-- -- 15_7 Roof Exh. 0.012

-- -- 15_8 Roof Exh. 0.012

-- -- 15_9 Roof Exh. 0.012

-- -- 15_22 Roof Exh. 0.012

-- -- 15_1 Vacuum Pump Silo 0.014

-- -- 15_19 Wall Fan 0.010

-- -- 15_20 Wall Fan 0.010

-- -- 15_21 Fan Pump Silo 0.006

-- -- PPRTO Proposed RTO 0 0 0.063

Stack1 Boilers 1 and 2 (a) 9.45 74.34 46.62

Stack3 Boilers 3 and 4 (a) 14.04 168.44 98.25

RCUN Rai lcar Unload 0.00521

-- -- STKER Coal Stacker 0.00521

-- -- GRIZZLY Coal Grizzly 0.00521

-- -- CRUSHER Coal Crusher 0.0675

-- -- BNKXF Bunker Coal Transfer 0.450

-- -- RDA1..A39 Main Gate to 1st intersection 0.00866

-- -- RDB1..B57 1st Intersection to Coal Pile 0.00059

-- -- RDC1..C28 1st Intersection to Shipping/Rcv 0.00635

-- -- RDD1..D300 Ash Management 0.01459

-- -- Additional Source For NAAQS Analysis

RESIN Resin Material Baghouse 0.025

-- -- Total for NAAQS Analysis 26.2 191.61 a 150.23 (a) Muskogee M ill pr oposes to restrict tot al S O 2 emissions f rom B oilers 1 t hrough 4 combined to 191.6 grams/second.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 44

Table D

- 14 summarizes the modeling parameters for the RESIN source, which was not affected by the project and thus not included in the signifi cant impact analysis.

Table D -14

Parameter Value Easting (m) 291920 Northing (m) 3956855 Stack Ht (m) 20.74 Exit Temp K Ambient Exit Velocity (m/s) 17.7 Exit Diameter (m) 0.298

Inventory – Competing Sources A full analysis mus t inc lude the e missi ons of c ompeting s ources. G

- P c onsidered c ompeting sources within the screening area. The screening area is unique for each pollutant, and is the area within a circle centered on the project with a radius equal to the significant impact distance plus

50 km, but not to exceed 100 km. The screening areas for NO 2 , PM 10 , and SO 2 , are 55, 52.5 and 58 km, respectively. Table D

- 15 presents a summary of competing sources within 60 km of the Mill provided by ODEQ.

Table D -15

Facility

ID Facility Site City Dista nce From Mill (km) Direction

From Mill (degrees) Potential Emissions (lb/hr)

SO 2 NO 2 PM 10 13665 American Foundry Group Muskogee 1.0 278 0.02 3.26 3.95

9943 OG&E Fort Gibson 3.3 357 19808 11844 463

9987 Owens Brockway Glass Cntr Muskogee 5.5 322 29 .6 160.7 20.4

10113 Sintertec Div Of BPI Inc Muskogee 5.8 352 9.5 15.8 5.9

8668 Boral Bricks Of Texas LP Muskogee 11.6 244 18.8 29.9 24.4

10242 Global Stone St Clair Inc Marble City 44.4 111 256.8 149.8 36.4

18787 Calpine Corp Coweta 47.9 312 11.72 361 55.68

9257 Grand River Dam Auth Chouteau 51.2 2 9334 6239.7 660.6

G- P included all competing sources within 60 km in the NAAQS modeling analysis. Table D -16 presents the individual stack parameters for sources at these facilities. In cases of missing stack parameters in the data, the following assumptions were made. For point sources, stack temperature set to ambient (293 K), stack diameter set to 0.001 m, exit velocity set to 0.001 m/s, and stack height set to 10 feet. For fugitive sources, release h eight set to 10 meters, vertical extent set to 10 m, initial vertical dispersion coefficient ( **σ** z ) of m, lateral extent set to 5 m, and initial lateral dispersion coefficient ( **σ** y ) set to 1.16 m or based on footprint of source area.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 45

Table D -16 (page 1)

F acility / Source Description Model

ID Potential Emissions (gram/sec) Stack Ht (m) Stack Diam (m) Stack Temp

K Exit Velocity

m/s Volume

Source

Dimensions (m)

SO 2 NO 2 PM 10 S ig y Sig z

AMERICAN FOUNDRY GROUP

Electric Induction Furnaces 13665 0 0 (a) 3.0 NA NA NA 1.16 2.33 Pouring and Casting 13666 0 0 (a) 3.0 NA NA NA 1.16 2.33 Casting Cleaning 13667 0 0 (a) 3.0 NA NA NA 1.16 2.33 Charge Handling 13668 0 0 (a) 3.0 NA NA NA 1.16 2.33 Casting Cooling 13669 0 0 (a) 3.0 NA NA NA 1.16 2.33 Sand Grinding 13670 0 0 (a) 3.0 NA NA NA 1.16 2.33

Ladle Heaters 13673 0.0025 0.411 0.498 10 NA NA NA 11.62 9.31

OG&E (per permit)

Unit #3 9943 10.04 71.49 5.52 53.6 4.7 422 9.3

Unit #4 9944 828.58 483.34 13.04 106.7 7.3 402 14.1

Unit #5 9945 828.58 483.34 13.04 106.7 7.3 402 14.1

Unit #6 9946 828.58 454.23 26.71 152.4 6.6 402 25.2 Coal Crushing, Loading, and Handling 9947 0 0 0.068 10.0 NA NA NA 5 8.3

OWENS BROCKWAY GLASS

Glass Melti ng Furnace #4 9987 0.9702 7.65 0.781 45.7 1.6 765 8.9 Glass Melting Furnace #42 9988 2.76 12.60 1.79 24.4 2.1 471 9.0

SINTERTEC DIV OF BPI INC Kiln #1 (Shuttle) 10113 1.197 1.99 0.315 10.1 0.4 505 19.1

Raw Mill 10117 0 0 0.2 14 10.1 0.4 294 19.1 Crushing (Primary,Secondary,Tertiary) 10118 0 0 0.214 10.1 0.4 294 19.1PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 46

Table D -16 (Page 2)

Facility / Source Description Model

ID Potential Emissions (g/sec) Stack Ht (m) Stack Diam (m) Stack Temp

K Exit Velocity

m/s Volume

Source

Dimensions (m)

SO 2 NO 2 PM 10 S ig y Sig z

BORAL BRICKS OF TEXAS LP

Tunnel Kiln 8668 2.37 3.77 3.07 8.5 1.5 533 12.4

GLOBAL STONE ST CLAIR INC Rotary Lime Kiln #1

- KVS 10242 11.94 6.97 1.76 29.3 2.1 341 9.5 Rotary Lime Kiln #2

- Fuller 10243 20.41 11.91 2.82 30.5 2.1 341 14.4

CALPINE CORP Power Block 1, #1

- 1 18787 0.738 22.74 3.51 43.9 6.1 355 14.4 Power Block 2, #2

- 1 18789 0.738 22.74 3.51 43.9 6.1 355 14.4

GRAND RIVER DAM AUTH

Electric Power Generation Unit #1 9257 775.78 452.55 64.65 153.9 6.1 408 27.6

Electric Power Generation Unit #2 9258 400.30 333.65 18.59 153.9 6.1 344 26.4

(a) PM 10 Emissions for all American Foun dry Group sources modeled as a single source - 13673PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 47

Table D -17 presents UTM locations and estimated base elevation from an AERMAP analysis.

Table D -17

Facility

ID Facility Base Elevation (m) UTM (m) Easting Northing

13665 American Foundry Grou p 165 291620 3956280

9943 OG&E Muskogee Generating 154 292335 3959747

9987 Owens Brockway Glass Cntr 182 289175 3960751

10113 Sintertec Div Of BPI Inc 157 291741 3962143

8668 Boral Bricks Of Texas LP 182 282067 3951391

10242 Global Stone St Clair Inc 211 334047 3940559

18787 Calpine Corp 213 257093 3988582

9257 Grand River Dam Auth 191 294073 4007568

Receptors For the NAAQS analyses, G

- P used receptor spacing identical to the spacing for the significant impact analysis. For each pollutant, these receptors extended out to the SID. The SID for PM, NOx, and SO 2 are 0.8, 4.5, a nd 5.25 km, respectively. If the maximum impact location is in an area with receptor spacing greater than 100 m, then G

- P also performed a refined analysis with

additional rece ptors spaced apart at 100 m intervals.

D.2.8 PSD CLASS II INCREMENT ANALYSIS Purpose and Methodology As discussed in the result section, preliminary m odeling of t he pr oposed pr oject i ndicated a significant impact ( i.e., maximum impact at or above the PSD significance levels) for NO 2 , SO 2 , and P M 10 . T herefore, PSD r eview r equires G

- P to perform a f ull a ir qua lity a nalysis to demonstrate com pliance w ith the P SD C lass I I I ncrements. T he I ncrement i mpact analysis predicts the ma ximum a mbient a ir c oncentrati on due t o a ll M ill s ources a nd of f

- site s ources within the screening areas that affect or consume increment. The total of these concentrations must be less than the PSD Increment, as listed in Table D -18.

Table D -18

Pollutant Averaging Time Allowable PSD Increment (μg/m 3 ) Form of Standard

PM 10 24

- hour 30 High

- second

- highest for each year

Annual 17 Annual Mean

NO 2 Annual 25 Annual Mean

SO 2 3

- hour 512 High

- second

- highest for each year

24

- hour 91 High

- second

- highest for each year

Annual 20 Annual Me an

Inventory – G-P In contrast to the N AAQS/AAQS a nalysis, t he I ncrement i nventory i ncludes i ncreases or

decreases i n actual em issions for non

- major sources only after the minor source baseline date, and increases or decreases in emissions f or m ajor s ou rces due t o a c hange i n t he m ethod of operation after the major source baseline date. Because the Mill is a m ajor source, all emission increases after the major source baseline due to a change in the method of operation consumePERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 48

increment. The Mill was constructed after the major source baseline date for SO 2 and PM 10 , 1975. Thus, the N AAQS i nventory f or P M 10 and S O 2 emissions from the Muskogee Mill are also the complete inventory of increment

- affecting emissions from the Mill. Table D

- 13 above lists the NAAQS inventory emission rates for these pollutants.

In contrast, the PSD major source baseline date for NO X is March 1988. Table D- 19 summarizes the NO 2 emission calculations for increment

- affecting emissions.

Table D -19

Model ID Source Description S ource Modified

Since 1988? Emission Rates

Baseline Maximum Increment

(g/sec) (g/sec) (g/sec) (lb/hr) 1112_8 PM 11 Yankee Wet End No 0 0.5292 0.431 3.42
1112_7 PM 11 Yankee Dry End No 0 0.5292 0.431 3.42
1112_20 PM12 Yankee No 0 1.0584 0.718 5.70
13_13 Yankee Economizer No 0 1.0584 0.783 6.21
14_13 Yankee Wet End No 0 0.5292 0.433 3.43
14_17 Yankee Dry End No 0 0.5292 0.433 3.43
15_13 Yankee Wet End Yes 0 0.5292 0.529 4.2
15_18 Yankee Dry End Yes 0 0.5292 0.529 4.2

PPRTO Proposed RTO No 0 0.063 0.063 0.5

Stack1 Boilers 1 and 2 No 31.67 46.620 14.750 118.68

Stack3 Boilers 3 and 4 No 67.95 98.255 30.305 240.51
Analysis Total 100.6 150.2 49.4 392.1

The inventory reflects the following conservative assumptions. Baseline emissions for all Y ankee dryer

emissions are set to zero. Actual emissions on the PSD baseline date were above zero for sources 11 through 14 a s t hese s ources e xisted i n 1988. T he a nalysis i ncluded the proposed RTO and did not

include the credit f rom t he s hut

- down of t he e xisting RTO. P SD Baseline emissions f or S tack 1 a nd Stack 3 s ources reflect the average of 2002 a nd 2003 f uel usage. In 1988, a ll boilers were burning fuel oil. Emission factors for fuel oil are greater than natural gas emission factors. By assuming he at input for B oiler 1 ( one of t wo boi lers e xhausting t hrough S tack 1) w as pr ovided by g as instead of oil, the estimated baseline emissions are conservatively low, yielding a hi gher amount of em issions that affect

increment.

Inventory – Competing Sources

A full analysis must include the emissions of competing sources. In contrast to the NAAQS analysis, the PSD Increment analysis includes emissions only from competing sources that affect increment. ODEQ

identified several sour ces w ithin 60 km of t he Mi ll t hat c onsume i ncrement. G- P modeled all PSD

- consuming competing sources. Table D

- 20 presents m odeling pa rameters of com peting sour ces identified by ODEQ included in the analysis. As a conservative measure, the analysis used the potential emission rates for each pollutant affected by increment, regardless of source status during the baseline.

Receptors For t he P SD I ncrement ana lyses, G

- P used receptor spacing identical to the spa cing f or t he N AAQS analyses.PERMIT MEMORANDUM No. 99 -113- C (M -4 )(PSD) 49

Table D -20

Facility / Source Description Model

ID Increment Emissions (gram/sec) Stack Ht (m) Stack Diam (m) Stack Temp

K Exit Velocity

m/s Volume Source Dimensions (m)

SO 2 NO 2 PM 10 Sig y Sig z

AMERICAN FOUNDRY GROUP

-- 0 0 0 NA NA

OG&E

Unit #6 9946 828 .58 0 26.71 152.4 6.6 402 25.2 Coal Crushing, Loading, and Handling 9947 0 0 0.068 10.0 NA NA NA 5 8.53

OWENS BROCKWAY GLASS

-- 0 0 0 NA NA NA NA

SINTERTEC DIV OF BPI INC Kiln #1 (Shuttle) 10113 1.197 1.9908 0.315 10.1 0.4 505 19.1

Raw Mill 10117 0 0 0.214 10.1 0.4 294 19.1 Crushing 10118 0 0 0.214 10.1 0.4 294 19.1

BORAL BRICKS OF TEXAS LP

Tunnel Kiln 8668 2.37 0 3.07 8.5 1.5 533 12.4

GLOBAL STONE ST CLAIR INC Rotary Lime Kiln #1

- KVS 10242 11.94 6.97 1.76 29.3 2.1 341 9.5 Rotary Lime Kiln #2

- Fuller 10243 20.41 11.91 2.82 30.5 2.1 341 14.4

CALPINE CORP Power Block 1, #1

- 1 18787 0.738 22.74 3.51 43.9 6.1 355 14.4

Power Bloc k 2, #2

- 1 18789 0.738 22.74 3.51 43.9 6.1 355 14.4

GRAND RIVER DAM AUTH

Electric Power Generation Unit #1 9257 775.78 0 64.65 153.9 6.1 408 27.6

Electric Power Generation Unit #2 9258 400.30 0 18.59 153.9 6.1 344 26.4PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 50

D.2.9 SOURCE IMPACT ANALYSIS RESULTS

Significant Impact Analysis

Carbon Monoxide By modeling the emissions that would result from the project, G

- P determined that the proposed project will not have a s ignificant C O impa ct. T able D

- 21 pr esents t he m aximum pr edicted impacts from the significant impact analysis.

Table D -21

Averaging

Period Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor

Location UTM

Zone 15 (m) Period Ending

YYMMDDHH Significant Impact

Level ( **μ** g/m 3 ) Monitoring

De minimis

Conc

., ( **μ** g/m 3 ) East North

1-hour High 1st High 1986 323 291715 3956388 86080904

2000

-- 1987 318 291714 3956338 87090301

19 88 322 291714 3956338 88062323

1990 319 291714 3956338 90082206

1991 320 291715 3956363 91081204

8-hour High 1st High 1986 95 293900 3955300 86041524

500 575 1987 100 293500 3954600 87090908

1988 101 291715 3956388 88091024

1990 88 291 714 3956313 90082208

1991 97 291715 3956463 91060708

The maximum 8

- hour CO impact due to the project is below the SIL and monitoring de minimis concentrations. I n a ddition, t he m aximum 1

- hour impact va lue i s a lso be low t he m odeling significance l e vel for that averaging pe riod. T herefore, G

- P di d not pe rform a f ull N AAQS analysis for CO.

Nitrogen Dioxide By modeling the emissions that would result from the project, G

- P determined that the proposed project will have a significant NO 2 impact out to approximately 4.5 km from the Mill. Table D

22 presents the maximum predicted impacts from the significant impact analysis.

Table D

- 22

Averaging

Period Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor

Location UTM

Zone 15 (m) Period Ending

YYMMDDHH Significant Impact

Level ( **μ** g/m 3 ) Monitoring

De minimis

Conc

., ( **μ** g/m 3 ) East North

Annual 1986 3.7 292201 3957272 3.8

1 14 1987 3.1 292151 3957273 3.3

1988 3.0 292101 3957274 3.4

1990 3.9 292326 3957270 4.0

1991 3.6 292301 3957270 3.7PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 51

The maximum annual NO 2 impact due to the project is above the SIL but below the monitoring

de minimis c oncentration of 1 a nd 14 **μ** g/m 3 , respectively. T herefore, G

- P pe rformed a ful l NAAQS a nalysis for NO 2

.

Sulfur Dioxide By modeling the emissions that would result from the project, G

- P determined that the project will have a significant SO 2 impact out to 5.25 km. Table D

- 23 presents the maximum predicted impacts from the significant impact analysis.

Table D -23

Averaging

Period Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor

Location UTM

Zone 15 (m) Period Ending

YYMMDDHH Significant Impact

Level ( **μ** g/m 3 ) Monitoring

De minimis

Conc

., ( **μ** g/m 3 ) East North

Annual

Mean 1986 0.6 292300 395 8000

--

1

-- 1987 0.5 292200 3958000

-- 1988 0.5 292200 3957900

-- 1990 0.6 292500 3957700

-- 1991 0.7 292400 3958200

--

24-hour High 1st High 1986 4.7 296000 3954000 86041524

5 13 1987 4.2 294600 3954600 87011024

1988 5.3 294700 395 4600 88032624

1990 4.0 293700 3954500 90122924

1991 5.0 296500 3955000 91110324

3-hour High 1st High 1986 20.4 296500 3955500 86070124

25

-- 1987 20.7 296500 3955000 87042203

1988 24.2 294700 3954700 88030406

1990 21.2 296500 3955000 9 0050924

1991 14.3 296500 3955000 91120306

The maximum 24

- hour SO 2 impact due to the proposed project is 5.3 **μ** g/m 3 , which is above the SIL but below the monitoring de minimis concentrations of 5 a nd 13 **μ** g/m 3 , respectively. The

maximum 3

- hour a nd a n nual ave rage i mpacts ar e be low t he r espective modeling significance levels. Therefore, G

- P performed a full NAAQS analysis for SO 2

.

Particulate Matter By modeling the emissions that would result from the project, G

- P determined that the project

will have a significant PM 10 impact out to 2.1 km. Table D

- 24 presents the maximum predicted impacts from the significant impact analysis.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 52

Table D -24

Averaging

Period Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor

Location UTM

Zone 15 (m) Period Ending

YYMMDDH H Significant Impact

Level ( **μ** g/m 3 ) Monitoring

De minimis

Conc

., ( **μ** g/m 3 ) East North

24-hour High 1st High 1986 8.1 291897 3956770 86102824

5 10 1987 6.2 292391 3955890 87012424

1988 5.6 292441 3955890 88020324

1990 5.7 292391 3955890 90122 224

1991 5.9 292391 3955890 91030224

Annual 1986 1.33 292101 3957274

--

1

-- 1987 1.19 292101 3957274

-- 1988 1.20 292101 3957274

-- 1990 1.40 292351 3957270

-- 1991 1.29 292351 3957270

--

The maximum 24

- hour PM 10 impact due to the project is above the SIL but below the monitoring

de minimis concentration s of 5 a nd 10 **μ** g/m 3 , respectively. I n addition, the maximum annual impact al so slightly ex ceeds t he m odeling s ignificance l evel. Therefore, G

- P performed a full NAAQS analysis for PM 10

.

Summary The s ignificant i mpact ana lysis de termined that t he pr oject em ission increase w ould cause a maximum impact above the SILs and the EPA monitoring de minimis concentrations for several pollutants. Figures D

- 5, D

- 6, a nd D

- 7 i n t he a pplication present the ar rangement of t he significant impact areas for these pollutants. Table D

- 25 summarizes the significant increment diameter (SID) for each pollutant and indicates if the pr oject impa ct is a bove the de mini mis monitoring concentration.

Table D -25

Pollutant Averaging

Time SID (km) Exceed de minimis Monitoring Conc?

SO 2 24-hr 4.25 No

3

- hr 0

-- Annual 0

-- NO X Annual 4.8 No

PM 10 Annual 2.0

-- 24

- hr 2.5 No

NAAQS Analysis Nitrogen Dioxide

By modeling the tot al pot ential M ill e missions a n d c ompeting s ource e missions, t he a nalysis predicted the total impact to compare to the NAAQS. Table D

- 26 summarizes the NO 2 model

results.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 53

Table D -26

Year Annual Predicted Impact (ug/m 3 )(a) Receptor Location UTM Zone 15 (m)

East North

1986 27.2 291600 3956300

1987 28.3 291600 3956300

1988 29.8 291600 3956300

1990 23.6 291600 3956400

1991 25.0 291600 3956400 (a) maximum impact of two model runs with and without American Foundry Group

G-P added a background concentration of 10.2 **μ** g/m 3 to the modeling result. As summarized in

Table D -27, when adding the background concentrations, the annual concentration is 40.1 **μ** g/m 3

. This impact is less than the respective NAAQS of 100 **μ** g/m 3 . Therefore, G-P has demonstrated

that the Mill emissions that reflec t all project changes will not cause or contribute to a violation of the NAAQS.

Table D

- 27 Concentrations in **μ** g/m 3 Averaging Period Maximum Predicted Impact Background

Concentration Total

Concentration NAAQS

Annual 29.8 10.2 40.1 100

Sulfur Dioxide By modeling the total potential Mill emissions and competing source emissions, G

- P determined

that the maximum SO 2 predicted impacts are 4

, 915, 133, and 14.5 μg/m 3 , for the 3

- hour, 24 -hour and annual averaging times, respectively. The maximum impact locations were in an area that did not require additional refined receptor grids. Table D-28 summarizes the SO 2 model results.

Table D -28 Averaging

Period Yea r Maximum Predicted Impact ( **μ** g/m 3 ) Receptor Location Period Ending (YYMMDDHH) East (m) North (m)

Annual 1986 13.0 292400 3957700

-- 1987 12.7 292700 3954100

-- 1988 11.8 292200 3957600

-- 1990 14.4 292500 3957700

-- 1991 14.5 292500 395770 0

-- 24-Hour High Second High 1986 122 292700 3954100 86022024

1987 133 292600 3954100 87080424

1988 110 296500 3954000 88031324

1990 109 292700 3954100 90062224

1991 114 292700 3954100 91041924

3-Hour High Second High 1986 373 289700 3954100 860 60815

1987 433 292700 3954100 87062412

1988 445 296000 3954000 88090403

1990 360 292700 3954100 90062218

1991 491 291500 3954100 91060921PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 54

G-P added background concentrations of SO 2 to the modeling results. As summarized in Table D-29, when adding the background concentrations, the 3-hour, 24-hour, and annual concentrations are less than the respective NAAQS. Therefore, G -P has demonstrated that the

Mill -wide emissions will not cause or contribute to a violation of the NAAQS.

Table D

- 29 Concentr ations in μg/m 3

Averaging Period Maximum Predicted Impact Background

Concentration Total

Concentration NAAQS

Annual 14.46 6.8 21.3 80.0

24

- Hour High 2 nd High 132.5 41.9 174.4 365.0

3

- Hour High 2 nd High 490.5 159.8 650.3 1300.0

Particulate Matter

– PM 10 The analysis predicted exceedances of the 24

- hour NAAQS for PM 10 on a single receptor on the American Foundry Group property when modeling all sources, including the American Foundry Group source, Model ID 13673. The placement of receptors was automati cally set by a Cartesian grid and included one receptor w ithin a s hort di stance of t he m odeled e mission s ource. G

- P further analyzed for NAAQS by using two analyses. T he first analysis includes all sources and excludes the one receptor on A merican Foundry Group property. T he second analysis includes all r eceptors a nd e xcludes m odel s ource 13673. T able D

- 30 pr esents t he r esults of these analyses.

Table D -30

Averaging Period Year Maximum Predicted Impact ( **μ** g/m 3 ) Receptor Location UTM Zone 15(m) Period E nding (YYMMDDHH) East North Maximum Impact on All Receptors Including American Foundry Group Property (a)

Annual 1986 4.9 292301 3957270

-- 1987 4.6 292226 3957272

-- 1988 4.5 292201 3957272

-- 1990 4.4 292301 3957270

-- 1991 4.3 292326 3957 270

-- 24

- Hour High

6 th High 1986

- 1991 17 292391 3955890 86102524

Maximum Impact off American Foundry Group Property (b)

Annual 1986 12.5 291600 3956500

-- 1987 11.6 291600 3956500

-- 1988 11.1 291600 3956500

-- 1990 11.2 291600 3956500

-- 1991 11.4 291600 3956500

-- 24

- Hour High

6 th High 1986

- 1991 42 291712 3956013 86102424

(a) I mpacts on A merican F oundry G roup P roperty e xclude t he model source on the property [ISC files PMAQS*_2] (b) I mpacts of f t he A merican F oundry Group Property only exclud e r eceptor ( 291600, 3956300) [ ISC f ile PMAQS*_1]PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 55

G- P added background concentrations to the modeling results. Table D

- 31 summarizes the total concentrations f or bot h a nalyses. With these tw o sets of da ta, the a nalysis pr edicted that the NAAQS woul d not b e exceeded. Further, the modeling output files for the significant impact analysis of P M 10 demonstrate that the project emissions w ill not c ause a ny s ignificant impa ct near the American Foundry Group property.

Table D

- 31 Concentrations in μg/m 3

Averagin g Period Annual 24

- Hour High 6 th High Maximum Predicted Impact 12.54 42
Background Concentration 23.2 72

Total Concentration 35.74 114.40
NAAQS 50 150

PSD Class II Increment Analysis

Nitrogen Dioxide By m odeling t he i ncrement

- affecting e missions from t he M ill a nd c ompeting s ource, G

- P

determined that the maximum annual mean NO 2 increment predicted impact is 14.3 μg/m 3 . The maximum impact l ocation i s i n a n a rea t hat di d not r equire a dditional r efined r eceptor g rids.

Table D

- 32 summarizes the NO 2 model results. This impact is less than the allowable increment

of 25 **μ** g/m 3 . T here fore, G

- P ha s de monstrated that the M ill e missions w ill not c ause or

contribute to a violation of the PSD Class II Increment.

Table D -32 Averaging

Period Year Maximum

Predicted Impact ( **μ** g/m 3 ) Receptor Location UTM Zone 15 (m) Allowable

Increment

(μg/m 3 ) East North

Annual 1986 14.0 92326 3957270

25 1987 12.8 92326 3957270

1988 12.9 92201 3957272

1990 14.3 92500 3957700

1991 14.1 92500 3957700

Sulfur Dioxide By m odeling t he i ncrement

- affecting e missions f rom the M ill a nd competing source s, G

- P

determined that maximum SO 2 increment predicted impacts for the 3

- hour, 24

- hour and annual averaging times. The maximum impact locations were in an area that did not require additional refined receptor grids. Table D

- 33 summarizes the SO 2 model re sults. These impacts are less than t he r espective a llowable i ncrements of 512, 91, a nd 20 **μ** g/m 3 . T herefore, G

- P ha s

demonstrated that the Mill emissions will not cause or contribute to a violation of the PSD Class

II Increment.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 56

Table D -33 Averaging

P eriod Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor Location UTM Zone 15 (m) Period Ending (YYMMDDHH) Allowable

Increment

(μg/m 3 ) East North

Annual 1986 11.7 292300 3958000

--

20 1987 10.3 292300 3957800

-- 1988 10.3 292200 3957700

-- 1990 13.2 292500 3957700

-- 1991 13.5 292500 3957700

--

24-Hour

High

Second

High 1986 75 292800 3954000 86030324

91 1987 74 292600 3954100 87080424

1988 70 294700 3954700 88030424

1990 65 293700 3954500 90071224

1991 68 294600 3954600 91110324

3-Hour

High

Second

High 1986 266 296000 3954500 86102321

512 1987 301 294700 3954600 87092906

1988 373 294700 3954600 88030406

1990 255 296500 3955000 90012103

1991 245 296500 3955000 91110303

Particulate Matter

– PM 10 By m odeling t he i ncrement

- affecting e missions f rom t he M ill a nd c ompeting s ource, G

- P

determined that the ma ximum P M 10 increm ent pr edicted i mpacts f or t he 24

- hour a nd a nnual averaging t imes, are l ess t han the r espective al lowable i ncrements of 30 and 17 **μ** g/m 3

. Therefore, G

- P ha s de monstrated that the M ill e missions w ill not c ause or contribute to a

violation of the PSD Class II Increment.

Table D -34 Averaging

Period Year Maximum

Predicted

Impact ( **μ** g/m 3 ) Receptor Location

Period Ending (YYMMDDHH) Allowable

Increment

( **μ** g/m 3 ) East (m) North (m)

Annual 1986 5 292301 3957270

--

17 1987 4 292201 3957272

-- 1988 4 292101 3957274

-- 1990 5 292426 3957268

-- 1991 5 292351 3957270

--

24-Hour High 2 nd

High 1986 20 291897 3956770 86102724

30 1987 17 292391 3955890 87110924

1988 15 291715 3956413 88091024

1990 16 292476 3957268 90092724

1991 16 292466 3955890 91122824PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 57

D.3. GOOD ENGINEERING PRACTICE STACK HEIGHT ANALYSIS

D.3.1 INTRODUCTION PSD r eview r ules r equire t hat c ontrols r equired f or e mission s ources us ing the Best Available Control Technology Analysis (see Attachment E) cannot be af fected by a s tack height t hat exceeds G ood Engineering P ractice ( GEP) or any ot he r di spersion t echnique. I n other words, emission rates specified in a source impa ct a nalysis mus t de monstrate c ompliance w ith stack heights at or below GEP, even if the physical height of the stack is greater. O n July 8, 1985, EPA de fined GEP s tack heigh t in the final stack height r egulations ( see 40 C FR 51.100( hh)). GEP stack height is defined as the greater of the following.

(1) 65 meters, measured from the ground- level elevation at the base of the stack. (2) (i) For stacks in existence on January 12, 1979, a nd for which the owner or operator had obtained all applicable permits or approvals required under 40 CFR parts 51 and 52, Hg = 2.5H, provided the owner or operator produces evidence that this equation was actually relied on in establishing an emission limitation, where Hg = good engineering practice stack height, measured from the ground

- level elevation at the base of the stack, and H = height of nearby structure(s) measured from the ground

- level elevation at the base of

the stack. (ii) For all othe r stacks, Hg = H + 1.5L, where L = lesser dimension, height or projected width, of nearby structure(s) provided that the EPA, State or local control agency may require the use of a field study or fluid model to verify GEP stack height for the source. (3) T he height demonstrated by a fluid model or a field study approved by the EPA, State or local c ontrol a gency, w hich e nsures t hat t he e missions f rom a stack do not result in excessive concentrations of any air pollutant as a result of atmospheric downwash, w akes, or eddy effects created by the source itself, nearby structures or nearby terrain features.

“ Nearby ” is defined as a distance up t o five times the lesser of the height or projected width dimensions of a structure or terrain feature but not greater than 0.8 kilometer (km).

The proposed project includes one ne w s tack: M odel ID P PRTO. T o de termine i f t he s tack meets G EP r egulations, G

- P a ssembled s tack he ight a nd bui lding i nformation f rom the source impact analysis.

D.3.2 GEP CALCULATIONS

Table D -35 presents a s ummary of s tack c onstruction da te a nd c omputed G EP value for the proposed s ource m odeled a t t he M ill. For this s tack, t he a pplicable G EP e quation i s G EP = (Height of structure) + 1.5 **×** (Lesser of structure height or width).

Table D

- 35

Stack Description Model ID Stack

Construction

Date GEP Calculations (meters)

Structure Height (a) Structure Width (a) GEP Height Computed by 40 CFR 51.100(hh) Proposed RTO PPRTO 2006 15.24 42.29 38.10 (a ) BPIP program selected the critical structure that produces the largest GEP value. H eight and width

shown is for the critical structure.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 58

The proposed stack height is 20.7 m. This value is less than the computed GEP height; therefore, the proposed stack at its physical height complies with GEP regulations.

D.4. AMBIENT AIR QUALITY ANALYSIS

Rule 40 CFR 52.21(m) de scribes t he a nalyses of a mbient a ir qua lity da ta r equired by P SD review. These requirements include pre

- application and post

- application analyses. Both of these requirements ar e ex empted by R ule 40 C FR 52.21( i)(8) i f t he source impact analysis demonstrates that the emissions increase from the modification would cause air quality impacts less than the de minimis monitoring concentrations in all a reas. T he s ource impa ct a nalysis (Section D. 3) for the Muskogee Mill concluded that the maximum impacts from the project for

SO 2 , NO 2 , a nd P M 10 would not e xceed t his c oncentration. Therefore, t he r ule e xemption is applicable. The following section describes the current air quality.

D.4.1 PRE

- APPLICATION ANALYSIS The Mill is located in an area generally free from the impact of other sources (except for OGE Muskogee G enerating S tation). F or t hese c onditions, E PA g uidance recommends that monitoring da ta f rom a ‘ regional’ s ite m ay be us ed as r eprese ntative data. T o determine if existing da ta i s appr opriate, EPA g uidance r ecommends three criteria: monitor l ocation, da ta quality, and currentness of the data. Table D

- 36 summarizes the criteria for the available recent data collected in the vicinity o f the Muskogee Mill.

Table D

- 36

Station ID County City Location Years of

Available

Data Distance

to Mill

(km)

SO 2 Monitors

400219002 Tahlequah Cherokee Co Residential

– Rural 2002

- current 31

401010167 Muskogee Muskogee Co Residential

– Rural 2002

- curr ent 6.8

401430175 Tulsa Tulsa Industrial

– Suburban 2002

- current 80

401430235 Tulsa Tulsa Industrial

– Urban 2002

- current 77

PM 10 Monitors

400219002 Tahlequah Cherokee Co Residential

– Rural 2002

- current 31

401010167 Muskogee Muskogee Co Residential

– Rural 2002

- current 6.8

NO 2 Monitors

400219002 Tahlequah Cherokee Co Residential

– Rural 2002

- current 31

401010167 Muskogee Muskogee Co Residential

– Rural 2002

- 2003 6.8

401430174 Glenpool Tulsa Agricultural

– Rural 2002

- 2003 68PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 59

Table D -37 summarizes the ambient monitored values among these monitors as recommended by ODEQ for use in an air quality analysis.

Table D -37

Pollutant Monitor and Data Description Averaging

Period Background Concentration Recommended by ODEQ (ppm) (μg/m 3 )

SO 2 Muskogee – 2004 High Second High for 3-hour and 24-hour; 2004 Annual mean 3

- hr 0.061 159.8

24

- hr 0.016 41.9

Annual 0.0026 6.8

NO 2 Tulsa

- 2004 Annual Mean Annual 0.0054 10.2

PM 10 Muskogee – 2002-2004 24-hour High Fourth High and 2004 A nnual Mean 24

- hr

-- 72

Annual

-- 23.2

D.4.2 POST

- APPLICATION ANALYSIS The pos t

- application a nalysis de termines pos t

- construction ambient monitoring ne eds, s uch a s quantifying the effect of the Mill

- wide emissions on air quality. EPA guidance recommends that

post- construction monitoring is appropriate when t he N AAQS i s t hreatened, or w hen t he modeling da tabases c ontain s ignificant unc ertainties. G

- P be lieves t hat ne ither of t hese conditions exists for this project. Therefore, G

- P believes that no p ost- application monitoring is

necessary.

D.5. ADDITIONAL IMPACT ANALYSIS IN CLASS II AREAS

D.5.1 IMPACTS UPON SOILS AND VEGETATION Predicted impacts that will result from the project are less than the NAAQS and state AAQS. As such, G

- P expects that the increase in emissions due to the project will not adversely impact the areas adjacent to the Muskogee Mill.

D.5.2 IMPACTS DUE TO ADDITIONAL GROWTH No significant increase in additional personnel will be added to the current plant staff because of the project. Therefore, there will be no significant effects on the residential, commercial, and industrial growth in the Mill area.

D.5.3 IMPACTS ON VISIBILITY The M uskogee M ill i s i solated f rom t he t own a nd ot her s ensitive a reas. T he distance to t he nearest significant recreational area ( e.g., state parks) is 28 km to the Sequoyah State Park. The distance to the nearest airport is approximately 28 km at the same state park. In the area of the airport and park, the Mill does not cause a significan t impact for any pollutant. With these low levels of pr edicted impacts, G

- P expects that the vi sibility a t the pa rk and airport w ill not be adversely affected.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 60

D.6. AMBIENT IMPACT ANALYSIS IN CLASS I AREAS

D.6.1. INTRODUCTION Generally, if th e facility undergoing the modification is within 200 kilometers of a PSD Class I area, then a significant impact analysis is also performed to evaluate the impact due to the project

alone at the PSD Class I areas. The three nearest PSD Class I areas to th e Mill are the Upper Buffalo National Wilderness Area (NWA), 166 km northeast of the Mill, the Caney Creek NWA, 178 km east of the Mill, and the Hercules-Glades NWA, 233 km northeast of the Mill.

The analysis compared the maximum predicted impacts due to the project at these Class I areas to EPA’s pr oposed significant i mpact l evels f or P SD C lass I ar eas. T hese r ecommended significant impact l evels ha ve ne ver be en promulgated as r ules, but ar e t he cur rently accept ed criteria f or de termining w hether a pr opo sed project w ill inc ur a s ignificant impa ct on a PSD

Class I area.

If t he pr oject

- only i mpacts at t he P SD C lass I ar ea ar e above t he pr oposed EPA PSD Class I significant impa ct le vels, then an analysis is pe rformed to demonstrate compliance with

allowable PSD C lass I i mpacts at t he P SD C lass I ar ea. T he pr oposed project ’ s ma ximum emission increases are also evaluated at the PSD Class I area to support the air quality related values (AQRV) analysis, which includes an evaluation of regional haze degradation.

For predicting maximum impacts at all three P SD C lass I areas, G

- P used the California Puff (CALPUFF) modeling system. C ALPUFF, Version 5.711a (EPA, 2004), is a Lagrangian puff model t hat i s r ecommended by t he U SEPA, i n c oordination w ith t he F ederal La nd Manager (FLM) for the NWAs, for predicting pollutant impacts at PSD Class I areas that are beyond 50 km from a project site. The following sections present a description of the CALPUFF model methodology.

D.6.2 GENERAL AIR MODELING APPROACH The genera l modeling approach was based on using the long

- range transport model, California Puff model (CALPUFF, Version 5.711a). The methods and assumptions used in the CALPUFF model were based on the l atest r ecommendations f or a r efined analysis as pr esented in t he IWAQM Phase 2 Summary Report and the FLAG document.

The following sections present the methods and assumptions used to assess the impacts of the proposed project. The a nalysis i s c onsistent w ith a “ refined a nalysis” s ince i t w as pe rformed using t he de tailed weather da ta f rom m ultiple s urface and upper ai r s tations as w ell as t he MM4/MM5 prognostic with fields.

Model Selection And Settings CALPUFF was used to a ssess t he pr oposed pr oject ’ s i mpacts at t he P SD C lass I ar eas.

CALPUFF i s a non

- steady s tate Lagrangian G aussian puf f long

- range t ransport m odel t hat includes algorithms for building downwash e ffects a s w ell a s c hemical t ransformations (important f or vi sibility c ontrolling pol lutants), a nd w et/dry de position. The CALPUFF meteorological and geophysical data preprocessor (CALMET, Version 5.53a), a preprocessor toPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 61

CALPUFF, is a diagnostic meteorological model that produces a three

- dimensional field of wind and temperature and a two

- dimensional field of other meteorological parameters. CALMET was

des igned t o pr ocess r aw m eteorological, t errain a nd l and

- use da tabases t o be us ed in the air modeling analysis. The CALPUFF modeling system uses a number of FORTRAN preprocessor programs t hat ex tract da ta f rom l arge da tabases and convert t he da ta i nto format s s uitable f or input t o C ALMET. T he pr ocessed da ta pr oduced f rom C ALMET was input to CALPUFF to assess the pollutant specific impact. Both CALMET and CALPUFF were used in a manner that is recommended by the IWAQM Phase 2 and FLAG reports.

CALPUFF Model Approaches And Settings The IWAQM has recommended approaches for performing a Phase 2 refined modeling analyses that are presented in Table D

- 38. These approaches involve use of meteorological data, selection of r eceptors a nd di spersion c onditions, a nd pr ocessing of m odel out put. T he s pecific s ettings used in the CALPUFF model are presented in Table D-39.

Table D -38

Model Input/Output Refined Modeling Analyses Recommendations a Description Meteorology Use CALMET (minimum 6 to 10 layers in the vertical; top layer must extend above the maximum mixing depth expected); horizontal domain extends 50 to 80 km beyond outer receptors and sources being modeled; terrain elevation and land

- use data is resolved Receptors Within Class I area(s) of concern; obtain reg ulatory concurrence on coverage. Dispersion 1. CALPUFF with default dispersion settings.

2. Use MESOPUFF II chemistry with wet and dry deposition.

3. Define background values for ozone and ammonia for area. Processing 1. For PSD inc rements: use highest, second highest 3

- hour and 24

- hour average SO 2 concentrations; highest, second highest 24- hour average PM 10 concentrations; and highest annual average SO 2 , PM 10 , and NO

x concentrations. 2. For haze: process, on a 24-hour basis, compute the source extinction from the

maximum increase in emissions of SO 2 , NO

x , and PM 10 ; compute the daily relative humidity factor [f(RH)], provided from an external disk file; and compute the maximum percent change in extinction using the FLM supplied background

extinction data in the FLAG document. 3. For significant impact analysis: use highest annual and highest short

- term averaging time concentrations for SO 2 , PM 10 , and NOx.

a IWAQM Phase II report (December, 1998) and FLAG document (December, 2000)

Table D

- 39 CALPUFF Model Settings

Parameter Setting Pollutant Species SO 2 , SO 4 , NO

x , HNO 3 , NO 3 , PM 10 Chemical Transformation MESOPUFF II scheme including hourly ozone data Deposition Include both dry and wet deposition, plume depletion Meteorologic al/Land Use Input CALMET

Plume Rise Transitional, Stack

- tip downwash, Partial plume penetration Dispersion Puff plume element, PG /MP coefficients, rural mode, ISC building

downwash schemePERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 62

Terrain Effects Partial plume path adjustment Output Create bin ary concentration file including output species for SO 4 , NO 3 , PM 10 , SO 2 , and NO

x ; process for visibility change using Method 2 and FLAG background extinctions Model Processing For haze: highest predicted 24

- hour extinction change (%) for the year

For s ignificant impact analysis: highest predicted annual and highest

short

- term averaging time concentrations for SO 2 , NO

x , and PM 10

. Background Values Ozone: 50 ppb; Ammonia: 1 ppb

Emission Inventory and Building Wake Effects

The C ALPUFF m odel i ncluded t h e facility’s emission, stack, and operating da ta as w ell as building di mensions t o a ccount f or t he e ffects of building

- induced downwash on t he emission sources. D imensions f or a ll s ignificant bui lding s tructures w ere pr ocessed w ith t he B uilding

Profile In put Program modified to process additional direction

- specific building information, and were included in the CALPUFF model input. T he modeling presents a listing of the facility’s emissions and structures included in the analysis.

Receptor Locations

All Class I receptor grids were obtained from the National Park Service.

Meteorological Data

G- P developed a wind field for 3 three years domain that included all PSD Class I areas that were evaluated in this analysis. A de tailed de scription of t he dom ain i s provided i n t he f ollowing

sections.

Modeling Domain A rectangular modeling domain extending 380 km in the east

- west (x) direction and 420 km in

the north -south (y) direction was used for the refined modeling analysis. The southwest corner of the domain is the origin and is located at 36.612 north latitude and 96.149 west longitude. Forthe processing of meteorological and geophysical data, the domain contains 95 grid cells in the xdirection and 105 g rid c ells i n t he y

- direction. T he dom ain g rid r esolution i s 4 km . T he a ir modeling analysis was developed in the Lambert Conformal Conic System.

Mesoscale Model – Generations 4 and 5 (MM4 and MM5) Data Pennsylvania State University in conjunction with the NCAR Assessment Laboratory developed

the MM4 and MM5 data set, a prognostic wind field or “guess” field, for the United States. The hourly m eteorological va riables us ed t o c reate t his da ta s et ( wind, temperature, dew point depression, and geopotential height for eight standard levels and up t o 15 s igni ficant levels) are extensive and are available for 1990, 1992, and 1996. T he analysis used the MM4 and MM5

data to i nitialize t he C ALMET w ind f ield. T he M M4 a nd M M5 da ta a vailable f or 1990 a nd 1992, respectively, have a horizontal spacing of 80 km a nd a r e us ed to simulate a tmospheric variables within the modeling domain. T he MM5 data are also available for 1996 a nd have a horizontal spacing of 36 km.

The MM4 and MM5 data us ed i n t he C ALMET, a lthough a dvanced, l ack t he f ine de tail of specific t emporal an d spatial meteorological va riables and geophysical da ta. T hese va riablesPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 63

were processed into the appropriate format and introduced into the CALMET model through the additional data files obtained from the following sources.

Surface Data Stations and proc essing The surface station data processed for the CALPUFF analyses consisted of data from up to three

NWS stations. The surface station parameters include wind speed, wind direction, cloud ceiling height, opaque cloud c over, dr y bul b t emperature, r elative humidity, s tation pr essure, a nd a precipitation c ode t hat i s ba sed on c urrent w eather c onditions. T he surface station data were processed into a SURF.DAT file format for CALMET input.

Upper Air Data Stations and Processing Upper air data from NWS statio ns at Oklahoma City and Norman, based on the availability of the upper air data, were used in the modeling analysis.

Precipitation Data Stations and Processing Precipitation data were processed from a network of hourly precipitation data files collected f rom primary a nd s econdary N WS pr ecipitation

- recording s tations l ocated w ithin t he l atitude a nd longitudinal limits of the modeling domain. Data for 128 stations were obtained in NCDC TD

3240 variable format and converted into a fixed

- length format. The u tility programs PXTRACT and PMERGE were then used to process the data into the format for the PRECIP.DAT file that is used by CALMET.

Geophysical Data Processing Terrain elevations for each grid cell of the modeling domain were obtained from 1

- degree Digi tal Elevation M odel ( DEM) f iles obt ained f rom t he U.S. Geographical Survey (USGS) Internet website. T he DEM data was extracted for the modeling domain grid using the utility program

TERREL. L and

- use da ta w ere al so extracted from 1

- degree U SGS f iles and p rocessed us ing utility programs CTGCOMP and CTGPROC. Both the terrain and land use files were combined into a GEO.DAT file for input to CALMET with the MAKEGEO utility program.

D.6.3 METHODOLOGY AND MODEL RESULTS The f ollowing pa ragraphs s ummarize t he p rocessing m ethods f or de position, vi sibility, a nd ambient impact.

Deposition As part of the AQRV analyses, total nitrogen (N) and sulfur (S) rates were predicted for the proposed project at each PSD Class I area evaluated. The deposition analysis criteri on is based on the annual averaging period.

Estimates of dr y ( SO 2 , S O 4 , NO

x , HNO 3 and N O 3 ) and wet ( SO 2 , S O 4 , HNO 3 and N O 3 ) deposition were obtained by selecting the options in CALPUFF to calculate and output dry and wet f luxes of t he pol lutants m odeled. Generally, AQRV analyses r equire va lues of t otal deposition (background plus modeled impact) to be g iven i n uni ts of ki logram/hectare/year (kg/ha/yr). T he m odeled de position f lux of e ach of t he oxides of sulfur and nitrogen fromPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 64

CALPUFF m ust be a djusted f or t he di fference of m olecular w eights of t heir ox ides a nd the element and the various forms must be summed to yield a total deposition.

The CALPUFF model was instructed to output both dry (*.DRY) and wet (*.WET) flux files, which t hen w ill be i nput i nto CALPOST to produce hourly deposition estimates of SO 2 , SO 4 , NO

x , HNO 3 and N O 3 . The results from C ALPOST a re a djusted t o nor malize t he m olecular weight to a common compound ( Sulfur or N itrogen) a nd t hen c onverted f rom t he de fault CALPOST units of gram/met er 2 /second (g/m 2 /s) to kg/ha/yr. These procedures were performed in a ccordance w ith S ection 3.3 of t he I WAQM

– Phase I I g uidance doc ument. Finally, the adjusted sulfur and nitrogen CALPOST values are summed using the POSTUTIL utility program to predict total sulfur and total nitrogen deposition values.

The deposition analysis t hreshold ( DAT) f or N a nd S of 0.01 kg /ha/yr w as pr ovided by t he USFWS (January 2002). A DAT is the additional amount of N and S deposition within a Class I area, below w hich estim ated impacts from a proposed ne w or m odified s ource a re c onsidered insignificant. The maximum N a nd S de position pr edicted f or t he pr oposed G

- P pr oject i s, therefore, compared to the DAT.

Table D

- 40 compares the maximum nitrogen deposition predicted for the proposed project only at each evaluated PSD C lass I ar ea. T he pr edicted impacts ar e l ess t han the cr iterion of 0.01 kg/ha/yr.

Table D

- 40

Class I Area and Species Total wet and dry deposition Deposition Analysis

Threshold b
(kg/ha/yr) 1990 1992 1996

(g/m 2 /s) (kg/ha/yr) a (g/m 2 /s) (kg/ha/yr) a (g/m 2 /s) (kg/ha/yr) a Caney Creek NWA

Nitrogen (N) 1.012E

- 12 0.0003 7.722E

- 13 0.0002 7.98E

- 13 0.0003 0.01 Sulfur (S) 2.538E

- 12 0.0008 2.891E

- 12 0.0009 3.86E

- 12 0.0012 0.01

Hercules Glades NWA

Nitrogen ( N) 1.051E

- 12 0.0003 1.290E

- 12 0.0004 8.6E

- 13 0.0003 0.01 Sulfur (S) 2.893E

- 12 0.0009 3.398E

- 12 0.0011 2.1E

- 12 0.0006 0.01 Upper Buffalo NWA

Nitrogen (N) 9.048E

- 13 0.0003 1.569E

- 12 0.0005 9.21E

- 13 0.0003 0.01 Sulfur (S) 2.470E

- 12 0.0008 4.568E

- 12 0.0014 2.42E

- 12 0.0008 0.01

a Conversion factor is used to convert g/m 2 /s to kg/hectare is 1 g/m 2 /s = 3.1536E+08 kg/ha/yr.

b Deposition analysis thresholds (DAT) for nitrogen and sulfur deposition provided by the U.S. Fish and Wildlife Service, January 200 2.

Visibility Based on the F LAG doc ument, current r egional ha ze g uidelines cha racterize a cha nge i n visibility by the c hange in the lig ht

- extinction coefficient ( b ext ). T he b ext is t he a ttenuation of light pe r uni t di stance due t o t he scattering and abs orption by g ases a nd pa rticles i n t he atmosphere. A change i n t he e xtinction c oefficient pr oduces a pe rceived vi sual c hange. A n index that simply quantifies the percent change in visibility due to the operation of a source is

calculated asPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 65

**∆** % = (b exts / b extb ) **×** 100, where

b exts is the extinction coefficient calculated for the source, and

b extb is the background extinction coefficient.

The purpose of the visibility analysis is to calculate the extinction at each receptor for each day (24

- hour period) o f the year due to the proposed project. The criteria to determine if the project’s impacts are potentially significant are based on a change in extinction of 5 percent or greater for any day of the year.

The analysis pr ocessing of vi sibility impa irment f or t his s tudy w as pe rformed w ith t he CALPUFF model a nd t he C ALPUFF pos t

- processing pr ogram C ALPOST. T he a nalysis w as conducted in accordance with the most recent guidance from the FLAG report (December 2000). The C ALPUFF pos tprocessor m odel C ALPOST i s us e d to calculate the combined visibility effects from the di fferent pol lutants tha t a re e mitted from the pr oposed project. D aily background extinction coefficients are calculated on an hour -by- hour basis using hourly relative humidity da ta f rom C ALMET a nd hy groscopic a nd non

- hygroscopic extinction c omponents specified in t he F LAG doc ument. T able D

- 41 compares the ma ximum vi sibility impa irment predicted for the proposed project at each evaluated PSD Class I area. The predicted impacts are

all below the crit erion of 5 percent.

Table D

- 41 Visibility Impairment (%) a Visibility Impairment Criterion (%)

Class I Area 1990 1992 1996 Caney Creek NWA 1.26 1.37 0.55 5.0

Hercules

- Glades NWA 0.78 0.53 0.54 5.0 Upper Buffalo NWA 2.35 1.29 0.65 5.0

a Concentration s ar e hi ghest predi cted using C ALPUFF model and a refined CALMET domain for years 1990, 1992 and 1996. Background extinctions calculated using FLAG Document (December 2000) values and hourly relative humidity data.

Ambient Impact

Table D

- 42 compares the maximum concentrations predicted for the proposed projects at each

evaluated PSD Class I area with EPA ’ s proposed PSD Class I significance levels. The maximum concentrations were predicted to be below the significant impact levels at each PSD Class I area

. Therefore, a full PSD Class I increment analysis was not required for these pollutants.

Table D

- 42

Pollutant Averaging

Time Maximum Concentrations (μg/m 3 ) a Significant Impact Level (μg/m 3 ) 1990 1992 1996 Caney Creek NWA

SO 2 Annual 0.001 0.002 0.0 02 0.10

24

- Hour 0.047 0.056 0.043 0.20

8

- Hour 0.109 0.081 0.091 NA

3

- Hour 0.148 0.121 0.131 1.00

1

- Hour 0.157 0.126 0.137 NAPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 66

Table D -42

Pollutant Averaging

Time Maximum Concentrations (μg/m 3 ) a Significant Impact Level (μg/m 3 ) 1990 1992 1996

PM 10 Annual 0.0002 0.0003 0.0003 0.20

24

- Hour 0.007 0.009 0.006 0.30

8

- Hour 0.013 0.013 0.010 NA

3

- Hour 0.015 0.018 0.014 NA

1

- Hour 0.016 0.035 0.018 NA

NO 2 Annual 0.001 0.001 0.001 0.10

24

- Hour 0.026 0.024 0.025 NA

8

- Hour 0.074 0.058 0.060 NA

3

- Hour 0.087 0.078 0.085 NA

1

- Hour 0.095 0.090 0.120 NA

CO Annual 0.001 0.001 0.001 NA

24

- Hour 0.028 0.041 0.025 N A

8

- Hour 0.052 0.054 0.050 NA

3

- Hour 0.074 0.080 0.079 NA

1

- Hour 0.097 0.086 0.119 NA

SAM Annual 0.0002 0.0002 0.0002 NA

24

- Hour 0.005 0.007 0.004 NA

8

- Hour 0.012 0.016 0.009 NA

3

- Hour 0.019 0.022 0.016 NA

1

- Hour 0.026 0.023 0.025 NA

Hercul es

- Glades NWA

SO 2 Annual 0.001 0.001 0.001 0.10

24

- Hour 0.019 0.038 0.015 0.20

8

- Hour 0.030 0.060 0.041 NA

3

- Hour 0.055 0.089 0.086 1.00

1

- Hour 0.095 0.106 0.133 NA

PM 10 Annual 0.0001 0.0001 0.0001 0.20

24

- Hour 0.003 0.006 0.003 0.30

8

- Hour 0 .005 0.007 0.008 NA

3

- Hour 0.010 0.011 0.013 NA

1

- Hour 0.016 0.025 0.036 NA

NO 2 Annual 0.0002 0.0002 0.0001 0.10

24

- Hour 0.005 0.013 0.007 NA

8

- Hour 0.016 0.031 0.021 NA

3

- Hour 0.027 0.046 0.046 NA

1

- Hour 0.047 0.054 0.073 NA

CO Annual 0.001 0.001 0.0004 NA

24

- Hour 0.016 0.016 0.006 NA

8

- Hour 0.031 0.030 0.016 NA

3

- Hour 0.061 0.035 0.031 NA

1

- Hour 0.077 0.046 0.042 NA

SAM Annual 0.0002 0.0002 0.0001 NA

24

- Hour 0.003 0.004 0.005 NA

8

- Hour 0.006 0.007 0.013 NA

3

- Hour 0.010 0.011 0 .017 NA

1

- Hour 0.018 0.017 0.018 NAPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 67

Table D -42

Pollutant Averaging

Time Maximum Concentrations (μg/m 3 ) a Significant Impact Level (μg/m 3 ) 1990 1992 1996 Upper Buffalo NWA

SO 2 Annual 0.001 0.001 0.001 0.10

24

- Hour 0.044 0.036 0.035 0.20

8

- Hour 0.093 0.095 0.092 NA

3

- Hour 0.132 0.134 0.148 1.00

1

- Hour 0.162 0.147 0.294 NA

PM 10 Annual 0.0002 0.0002 0.0001 0.20

24

- Hour 0.005 0.001 0.005 0.30

8

- Hour 0.014 0.012 0.012 NA

3

- Hour 0.025 0.020 0.019 NA

1

- Hour 0.031 0.029 0.029 NA

NO 2 Annual 0.0003 0.0007 0.0003 0.10

24

- Hour 0.019 0.026 0.02 NA

8

- Hour 0.050 0.066 0.058 NA

3

- Hour 0.069 0.097 0.117 NA

1

- H our 0.080 0.123 0.141 NA

CO Annual 0.001 0.001 0.001 NA

24

- Hour 0.038 0.025 0.017 NA

8

- Hour 0.072 0.045 0.042 NA

3

- Hour 0.126 0.079 0.077 NA

1

- Hour 0.162 0.104 0.096 NA

SAM Annual 0.0002 0.0002 0.0001 NA

24

- Hour 0.011 0.006 0.008 NA

8

- Hour 0. 030 0.010 0.009 NA

3

- Hour 0.044 0.024 0.013 NA

1

- Hour 0.046 0.027 0.018 NA

a Concentrations are highest predicted using CALPUFF model and refined CALMET wind fields for 1990, 1992, and 1996.

D.7. ADDITIONAL IMPACTS ANALYSIS FOR NATIONAL WIL DLIFE AREAS

The analysis addresses the potential impacts on vegetation, soils, and wildlife of the Class I area due t o t he pr oposed pr oject. I n a ddition, pot ential i mpacts upon vi sibility r esulting f rom t he proposed project are assessed.

Ambient Impact The maximum pollutant concentrations predicted for t he pr oject i n t he N WAs a re pr esented above. The results were compared with effect threshold limits for both vegetation and wildlife as reported in the scientific literature. T hreshold information is no t available for all species found in the Class I area, although studies have been performed on a few of the common species and on other s imilar s pecies t hat can be us ed as i ndicators of effects. All predicted impacts were far

below thresholds.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 68

Impacts t o soils For soils, the potential and hypothesized effects of atmospheric deposition include increased soil acidification, alteration in cation exchange, loss of base cations, and mobilization of trace metals.

The potential sensitivity of specific soils to atmospheric inputs is related to two factors. First, the physical ability of a soil to conduct w ater ve rtically thr ough the s oil pr ofile is impor tant in influencing the int eraction with deposition. S econd, the a bility of the soil to resist chemical

chan ges, as measured in terms of pH and soil cation exchange capacity (CEC), is important in determining how a soil responds to atmospheric inputs.

The relatively low sensitivity of the soils to atmospheric inputs coupled with the extremely low ground- level p ollutant concentrations due to the project precludes any significant impact on soils.

Impacts to Vegetation The phytotoxic effects from the project’s emissions are minimal. It is important to note that the elements w ere cons ervatively m odeled with the as sumption that 100 percent was available for plant uptake. This is rarely the case in a natural ecosystem.

Impacts To Wildlife The ma jor a ir qua lity r isk to wildlife in the United States is from continuous exposure to pollutants above the National AAQS. This occurs in non

- attainment areas ( e.g., Atlanta). Risks to wildlife a lso may oc cur f or w ildlife livi ng in the vi cinity of a n emission source that experiences f requent ups ets or e pisodic c onditions r esulting f rom m alfunctioning e quipment, unique meteoro logical conditions, or startup operations (Newman and Schreiber, 1988). U nder these conditions, chronic effects ( e.g., particulate contamination) and acute effects ( e.g., injury to health) have been observed (Newman, 1981).

A wide range of physiological and ecological effects to fauna has been reported for gaseous and particulate pollutants (Newman, 1981; Newman and Schreiber, 1988). The most severe of these effects ha ve be en obs erved a t c oncentrations a bove t he s econdary A AQS. Physiological and

behavio ral effects have been observed in experimental animals at or below these standards.

Based on the very low level of impacts, G -P does not expect any effects on wildlife AQRVs from

SO 2 , NO 2 , a nd pa rticulates. T he pr oposed pr oject ’ s c ontribution t o c umulati ve impa cts is expected to be negligible.

Research with primates s hows t hat O 3 penetrates de eper i nto non

- ciliated peripheral pa thways and can cause lesions in the respiratory bronchioles and alveolar ducts as concentrations increase from 0.2 t o 0.8 ppm (Paterson, 1997). T hese bronchioles are the most common site for severe damage. In rats, the Type I cells in the proximal alveoli (where gas exchange occurs) were the primary site of action at concentrations between 0.5 a nd 0.9 ppm (Paterson, 1997). W ork with rats and rabbits s uggest t hat t he m ucus l ayer t hat l ines the large airways does not protect completely against the effects of O 3 , and desquamated cells were found from acute exposures at 0.25, 0.5, a nd 1.0 ppm . I n animal research, O 3 has been found t o increase the susceptibility to bacterial pne umonia ( Paterson, 1997) . D uring t he l ast de cade, t here ha s a lso be en growingPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 69

concern w ith t he pos sibility t hat repeated or long

- term ex posure t o elevated O 3 concentrations may be causing or contributing to irreversible chronic lung injury.

The project’s contribution to ground level O 3 is expected to be low and dispersed over a l arge area. Coupled with the historical ambient data, mobility of wildlife, the potential for exposure of wildlife to the facility’s i mpacts that lead to high concentration is unlikely.

SELECTED REFERENCES

Holzworth, G .C., 1972. M ixing H eights, W ind S peeds a nd P otential f or U rban A ir Pollution Throughout t he C ontiguous U nited S tates. P ub. N o. AP

- 101. U .S. E nvironmental P rotection Ag ency.

Mandoli, B.L. and P.S. Dubey. 1988. The Industrial Emission and Plant Response at Pithampur (M.P.). Int. J. Ecol. Environ. Sci. 14:75-79.

Newman, J.R. 1981. E ffects of A ir P ollution on A nimals a t C oncentrations a t or B elow

Ambient Air Standard s. P erformed for Denver Air Quality Office, National Park Service, U.S. Department of the Interior. Denver, Colorado.

Newman, J .R. a nd R .K. S chreiber. 1988. Air Pollution and Wildlife Toxicology. Environmental Toxicology and Chemistry. 7:381-390.

( End material from application )

SECTION VI. INSIGNIFICANT ACTIVITIES

The list of activities in the pending Part 70 permit will not be affected by the current project. The Part 1b form submitted with the current application lists two items not included in the list. After discussion with the f acility a nd with the pe rmit writer responsible for the operating permit, agreement has been reached and no further discussion is needed here.

SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 e numerates t he pr imary a nd s econdary a mbient a ir qua lity s t andards a nd t he significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these standards. In addition, m odeled e missions f rom t he pr oposed f acility de monstrate t hat t he facility would not have a significant impact on air quality.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 70

OAC 252:100- 4 (New Source Performance Standards) [Applicable] Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, a nd 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These requirements are covered in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Ap plicable] Subchapter 5 requires sources of a ir c ontaminants to register w ith Air Q uality, file e mission inventories annually, and pay annual operating fees ba sed upon t otal a nnual e missions of regulated pollutants. E mission inventories were submitted and fees paid for pr evious years as required.

OAC 252:100- 8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes t he g eneral a dministrative r equirements f or P art 70 pe rmits. A ny planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the “Insignificant A ctivities” or “ Trivial A ctivities” thr esholds r equire pr ior notification to AQD and may require a permit modification. Insignificant activities refer to those

individual emission units eith er listed in Appendix I or whose actual calendar year emissions do not exceed the following limits.

**•** 5 TPY of any one criteria pollutant

**•** 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure c ompliance w ith all applicable requirements for all sources are taken from existing and pending permits, the current permit application, or are developed from the applicable requirement.

OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] In t he e vent of a ny r elease w hich r esults i n e xcess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/ Title V s ources m ust r eport a ny e xceedance t hat pos es a n i mminent and substantial danger to public health, safety, or t he e nvironment a s s oon a s i s pr acticable. U nder no

circumstances shall notification be more than 24 hours after the exceedance.

OAC 252:100

- 13 (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the c onditions listed in this subchapter.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 71

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

Section 19

- 4 r egulates e missions of P M f rom ne w a nd e xisting f uel

- burning equipment, w ith emission limits based on maximum design heat input rating. Appendix C s pecifies PM emission limitations for all equipment at this facility. Fuel -burning equipment is defined in OAC 252:100- 1 as “combustion devices used to convert fuel or wastes to usable heat or power.” Boilers B -1,

B- 2, B

- 3, and B

- 4, Paper Machine Drying Hoods PM

- 11, PM

- 12, PM

- 13, PM

- 14, and PM -15, and t he P oly P rinter T unnel D ryers a re s ubject t o t he requirements of this subchapter. AP

- 42 (7/98) Table 1.4

- 1 lists natural gas Total Particulate Matter (TPM) emissions to be 7.6 lbs/million

scf or about 0.0076 lbs/MMBTU. Stack tests conducted on January 7, 8, 9, 2003 for B -2, on May 20 & 21, 2003 for B

- 3, and on April 15 & 16, 2003 for B-4, established emission factors for coal. Converting these factors to units of lbs/MMBTU yields the values illustrated in t he tables below, which demonstrate compliance with the allowable. I t should be noted that these emission factors are uncontrolled factors, i.e., they do not take emission controls into account.

E mission

U nit Heat Input

MMBTUH Coal Factor,

Lb/MMBTU NG Fac tor,

Lb/MMBTU APP “C” Allowable

Lb/MMBTU

Boiler B

- 1 310 NA 0.0076 0.27

Boiler B -2 440 0.032 * 0.0076 0.24

0.027 ** 0.0076 0.24

Boiler B

- 3 557 0.005 0.0076 0.23

Boiler B

- 4 557 0.015 0.0076 0.23
* High

- BTU sub

- bituminous coal

** Low

- BTU bituminous coal

Emission Unit Heat Input

MMBTUH NG Emission Factor,

Lb/MMBTU APP “C” Allowable,

Lb/MMBTU Paper Machine PM

- 11 75 0.0076 0.37 Paper Machine PM

- 12 75 0.0076 0.37 Paper Machine PM

- 13 75 0.0076 0.37 Paper Machine PM

- 14 75 0.0076 0.37 Paper Machine P M

- 15 50 0.0076 0.41

PO

- 1 RTO 11.4 0.0076 0.58

Section 19

- 12 limits particulate emissions from new and existing directly fired fuel

- burning units and emission points in a n i ndustrial pr ocess based on process w eight r ate, as s pecified in Appendix G . H ourly t hroughputs w ere c alculated by di viding t he a nnual r ates s tated i n the Emissions Section above by 8,760 hour s per year and using emission factors from that section. The following table illustrates the calculated hourly rates of PM emissions. All emis sion points

will be in compliance with the Subchapter 19 limits.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 72

Paper Machines

Emission Unit Throughput,

TPH Emissions (lbs/hr) App. G Limit (lbs/hr)

PM

- 11 10.42 2.13 19.71

PM

- 12 14.58 2.97 24.69

PM

- 13 12.50 2.55 22.27

PM

- 14 12.50 2.55 22.27

PM -15 11.51 2.35 21.07

Coal Preparation Plant

Emission Unit Coal Throughput

TPH Emissions (lbs/hr) App. G Limit (lbs/hr) Railcar Unloading, Radial Stacker, Grizzly Feeder 59.29 5.09 46.2

Coal Sizer/Crusher 59.29 11.86 46.2 Conveying 59.29 1.18 46.2

Coal Bunkers 59.29 1.18 46.2 Coal Feeders, Pulverizers Closed Process, No emissions

FS

- 1 Coal Pile Emissions included with above

OAC 252:100- 25 (Visible Emissions and Particulates) [Applicable] No discharge of g reater t han 20% opa city i s allowed except fo r s hort

- term oc currences t hat

consist of not m ore t han one s ix

- minute pe riod i n a ny c onsecutive 60 m inutes, not t o e xceed three such periods in any consecutive 24 hour s. I n no c ase shall the average of any six

- minute period e xceed 60% opa city. B oilers B

- 1, B

- 2, B

- 3, a nd B

- 4 a re not s ubject t o S ubchapter 25 since they are subject to an opacity limitation in NSPS Subpart D. O ther combustion units are units fired with natural gas and are t herefore not l ikely t o e xceed t his s tandard. E quipment subject to Su bpart Y at the Coal Preparation plant is also not subject to Subchapter 25 since those items are subject to an opacity limitation.

OAC 252:100-29 (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emis sions beyond the property line on which the emissions originated in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate thi s r equirement ; t herefore i t i s n ot n ecessary t o r equire s pecific precautions to be taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxi de emissions from new fuel

- burning equipment (constructed after July 1, 1972). The limits, based on heat input, are 0.2 lbs/MMBTU for gaseous fuels, 0.8 lbs/MMBTU for liquid fuels, and 1.2 lbs/MMBTU for solid fuels. The averaging time for the emission li mits is 3 hour s unl ess a s olid f uel s ampling a nd a nalysis m ethod i s us ed t o de termine e mission compliance , in which case the averaging time is 24 hours. Testing was done for emissions fromPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 73

coal combustion that demonstrated emissions from this fuel were we ll within the limits. Specific conditions in the permit limiting fuel sulfur content for the various fuels will ensure compliance with t he l imits w hen t hese f uels a re us ed. T he t able be low i llustrates c ompliance based on

calculations from the Emissions S ection above.

Emission Unit Heat Input

MMBTUH NG Factor,

Lbs/MMBTU (1) Coal Factor,

Lbs/MMBTU (2)

B

- 1 310 0.0006 NA

B-2 440 0.0006 0.644 (3)

0.267 (4)

B

- 3 557 0.0006 0.403

B

- 4 557 0.0006 0.631

PM -11 75 0.0006 NA

PM

- 12 75 0.0006 NA

PM

- 13 75 0.00 06 NA

PM

- 14 75 0.0006 NA

PM

- 15 50 0.0006 NA
(1) AP

- 42, Table 1.4

- 2 (7/98) (2) Stack tests conducted on January 7

- 9 for B

- 2, May 20 & 21 for B

- 3, and April 15 &

16 for B

- 4, all 2003. (3) Low

- BTU sub

- bituminous coal (4) High

- BTU bituminous coal

OAC 252:100-33 (Nitrogen Oxides) [Applicable] This subchapter limits new gas

- fired, liquid

- fired, and solid fossil fuel

- burning equipment with rated he at i nput g reater t han or e qual t o 50 M MBTUH to emissions of 0.20, 0.30, and 0.70 respectively, lbs of NO X per MMB TU, three

- hour average. Only boilers B

- 1, B

- 2, B

- 3, and B -4 exceed t he 50 M MBTUH t hreshold a nd a re s ubject t o t hese s tandards. T he table below illustrates compliance based on calculations from the Emissions Section above.

Emission Unit Heat Input

MMBTUH NG Factor,

Lbs/MMBTU Coal Factor,

Lbs/MMBTU (2)

B

- 1 310 0.138 (5) NA

B-2 440 0.19 (1) 0.52 (3)

0.38 (4)

B

- 3 557 0.187 (6) 0.27

B

- 4 557 0.19 (1) 0.41
(1) AP

- 42, Table 1.4

- 1 (7/98) (2) Stack tests, co nducted J anuary 7

- 9, 2003, for B

- 2, M ay 20

- 21, 2003, for B

- 3, and April 15

- 16, 2003, for B -4 (3) Low BTU sub

- bituminous coal (4) High BTU bituminous coal (5) 20% contingency added to B

- 1 stack test result of June 1980. (6) 10% contingency added to AP

- 42, Table 1.4

- 1 (7/98)

.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 74

OAC 252:100-35 (Carbon Monoxide) [Not Applicable] None of t he f ollowing af fected processes ar e l ocated at t his f acility: gray iron cupola, blast furnace, basic oxygen furnace, petroleum cat alytic cr acking uni t, or pe troleum cat alytic reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Part 7 Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 ps ia to be equipped with a permanent s ubmerged f ill pi pe or w ith an organic vapor recovery s ystem. A n e xisting aboveground 10,000-gallon gasoline tank is equipped with a submerged fill pipe.

Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not normally c onduct c oating or painting ope rations e xcept f or r outine m aintenance of t he f acility and equipment, which is exempt.

Part 7 requires fuel

- burning equipment to be operated and maintained so as to minimize VOC emissions. T emperature a nd available a ir mus t be s ufficient to provide e ssentially c omplete

combustion. A ll f uel

- burning equipment a t t his f acility i ncluding t he boi lers, pa per m achine drying hoods , P O

- 1 tunnel dryers, a nd r egenerative t hermal ox idizer a re de signed t o pr ovide essentially complete combustion of organic materials.

OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants) [Applicable]

Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on September 1, 2004, with the exception of Subparts B, H, I, K, Q, R, T, W a nd A ppendices D a nd E , a ll of w hich a ddress r adionuclides. I n a ddition, General Provisions a s f ound i n 40 C FR P art 63, S ubpart A , a nd t he M aximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC , DDDD, EEEE, FFFF, GGGG, HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE, FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, RRRRR, SSSSS a nd TTTTT ar e he reby adopt ed by r eference as t hey exist on September 1, 2004. T hese s tandards a pply t o bot h e xisting a nd ne w s ources of H APs. T hese requirements are covered in the “Federal Regulations” section.

Part 5 is a state -only requirement governing tox ic air contaminants. Part 5 regulates sources of toxic ai r cont aminants t hat ha ve em issions ex ceeding a de minimis level. However, Part 5 of Subchapter 41 ha s be en s uperseded by O AC 252: 100

- 42. T he A ir Q uality C ouncil a pproved Subchapter 42 f or permanen t rulemaking on April 20, 2005. T he Environmental Quality Board approved S ubchapter 42 a s bot h a pe rmanent a nd e mergency r ule on J une 21, 2005. The emergency Subchapter 42 was sent for Gubernatorial signature on J une 30, 2005, a nd became effective by em e rgency A ugust 11, 2005. S ubchapter 42 i s expected to become permanently effective on J une 15, 2006. B ecause S ubchapter 41, P art 5 has been superseded, the requirements of Part 5 will not be reviewed in this memorandum. Should Subchapter 42 fail to

take effect, this permit will be reopened to address the requirements of Subchapter 41, Part 5.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 75

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable] All pa rts of O AC 252: 100

- 41, w ith t he e xception of P art 3, s hall be superseded by this subchapter. A ny work practice, material substitution, or c ontrol e quipment r equired by t he Department prior to June 11, 2004, t o control a TAC, shall be retained, unless a modification is approved by the Director.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for t esting, m onitoring a nd r ecordkeeping a nd applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require t he ow ner or ope rator of a ny s ource i n t he s tate of O klahoma t o i nstall, m aintain a nd operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice -of- intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method st ack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an appl icable rule, or permit requirement. Data from any required testing or m onitoring not c onducted i n a ccordance w ith t he pr ovisions of t his subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of a ny c redible evidence or information relevant to whether a source would have been in compliance w ith applicable r equirements i f t he appr opriate pe rformance or compliance test or procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not a pplicable to this facility:

OAC 252:100

- 7 Permits for Minor Facilities not in source category

OAC 252:100

- 11 Alternative Emissions Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100

- 17 Incinerators not type of emis sion unit

OAC 252:100

- 23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevators not in source category

OAC 252:100

- 35 Carbon Monoxide not in source category

OAC 252:100

- 39 Nonattainment Areas not in area category

OAC 252:100

- 47 Landfills not in source category

SECTION VIII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable] As noted in the table at the end of S ection I V ( Emissions) a bove, t he c urrent pr oject c auses increases in the emissions of many pollutants. The following t able compares the actual

- to

- potential increases with the PSD significance thresholds.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 76

Pollutant NO X CO SO 2 PM 10 VOC H 2 SO 4 mist Lead

Increase 377 437 387 114 487 5.47 0.0026

Threshold 40 100 40 15 40 7 0.6 Significant? Y Y Y Y Y N N

There are no cont emporaneous decreases to consider, so pollutants NO X , CO, SO 2 , PM 10 , and VOC require s tudy. T he f ollowing t able r eviews w here t hese e mission i ncreases will occur, showing which equipment will be added (new), and showing which existing equipment is to be m odified. Certain EUGs relate to only a single pollutant, so that pollutant has been indicated in the column

labeled EUG. Note that emissions for EUG 4 and EUG 5 are treated in EUG 6. As the reader may recall, the only reason for establishing EUG 5 was to describe equipment subject to NSPS Subpart

KK. E missions from EUGs 4 and 5 a re very similar to sources included in EUG 6. The BACT review following the table is taken from the applicant’s submittal, and has been edited for length

and reformatted. The t erm “G

- P” in this document refer s to Georgia

- Pacific, the parent company

of Fort James.

EUG Equipment New? Modified? Actual

- to

- potential increases?

1 Boilers N N Y

2 PM

- 11, 12, 13, & 14 burners N Y Y

PM

- 15 burner N N Y Tunnel dryer #1 N N N/A

Tunn el dryers #2, 3, & 4 Y N Y Poly printer #1 N N N/A Poly printers #2, 3, & 4 Y N Y

3 PM Coal prep plant N N Y

4 Subpart S units N N N/A

5 Paper printers N N Y

6

VOC Pulping units N Y (only #5) Y

PM

- 11, 12, 13, 14, & 15 N Y Y

PM additives N N Y PM solvent cleaning N N Y Poly extruder #1 N N N/A Poly extruders #2, 3, & 4 Y N Y Corona treaters (existing) N N N/A New corona treaters (3) Y N Y Plate making N Y Y Poly printer #1 N N N/A Poly printers #2, 3, & 4 Y N Y Paper printers N N Y

7

PM Paper machines (5) N N Y Coal pile N N N Poly plant N N YPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 77

( From the application ) EPA and ODEQ require that BACT be applied to control emissions from a proposed new or modified source that triggers review under PSD regulations. T he propose d project w ill i ncrease t he act ual pa per pr oduction rate on the pa per m achines and allow more flexibility to use low er qua lity w astepaper s upplies. T he pr oject w ill a lso increase the actual production rate a t S ystem 5 pulping to allow mor e f lexibility w it h lower qua lity w astepaper supplies. The project will expand the polyethylene plant by adding 3 e xtruders, 3 f lexographic presses, and a new in

- line plate cleaner for related platemaking. The project will not modify or

debottleneck other areas of the Mil l, such as the boilers or paper printing. Such sources affected by the project may realize an increase in utilization.

The emissions sources subject to BACT review in this permit application are:

**•** Nos. 11, 12, 13, and 14 Paper Machine Drying Hoods

**•** Nos. 11, 12, 13, 14 and 15 Paper Machine Process Emissions

**•** Converting Area Baghouse

**•** Proposed Nos. 2, 3, and 4 Polyethylene Flexographic Printing Presses

**•** Proposed Nos. 2, 3, and 4 Extruders

**•** Platemaking

**•** System 5 Pulping

BACT ANALYSIS METHODOLOGY

BACT requireme nts are intended to ensure that the control systems incorporated in the design of a pr oposed or m odified f acility r eflect t he l atest i n c ontrol t echnologies us ed in a particular industry and take into consideration existing and future air quality in the vi cinity of the facility. BACT must, at a mini mum, demonstrate c ompliance w ith the N ew S ource P erformance Standards (NSPS) for a source (if applicable). A cost

- benefit analysis of the materials, energy, economic penalties, and the environmental benefits ass ociated with a control system may also be necessary. A decision on B ACT i s t o be ba sed on s ound j udgment, ba lancing e nvironmental benefits with energy, economic, and other impacts (EPA, 1978).

The guidelines for a BACT analysis state that the applicant m ust demonstrate that each emission unit to be constructed, reconstructed, or modified in a PSD permit will receive BACT. BACT is to be applied to all regulated pollutants from such emission units and include fugitive as well as

stack emissions. In select ing one of the alternatives in technology, the applicant is to consider application of flue gas treatment, fuel treatment and processes, and techniques that are inherently low polluting and are economically f easible. I n c ases w here t echnological or e conom ic limitations on the application of measurement t echniques w ould m ake t he i mposition of a n emission limitation infeasible, a design, operating, equipment, or work practice standard can be provided by t he s ource. A ccording t o t he r egulations, t he B ACT a na lysis s hall inc lude the following steps.

(1) Identify all potential control strategies. (2) Determine t echnical f easibility of c ontrol opt ions i dentified i n a bove s tep. Explain availability ve rsus a pplicability f or t echnologies i dentified i n a bove step. EliminatePERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 78

technically infeasible options. The demonstration of technical infeasibility should be clearly documented and should show, based on phy sical, chemical, and engineering principles, that the t echnical di fficulties w ould pr eclude t he s uccessful us e of t he c ontrol opt ion on t he

emission unit under review. (3) Rank remaining control technologies by control effectiveness. The ranking should include the f ollowing r elevant i nformation i ncluding c ontrol e ffectiveness, expected emission rate, expected em ission reduction, energy impacts, environmental impacts, and economic impacts. (4) Evaluate the most e ffective c ontrols a nd doc ument r esults. T he e valuation s hould i nclude

case -by- case consideration of energy, environmental and economic impacts. If the top option is not s elected a s B ACT, t he e valuation s hould c onsider t he ne xt m ost effective control option. (5) Select BACT. BACT is the most effective option not rejected in Step 4.

BACT FOR NOs. 11, 12, 13 AND 14 PAPER MACHINE DRYER BURNERS

S OURCE DESCRIPTION Paper Machines 11, 12, 13, and 14 produce tissue, napkins, and paper towel products. The Mill is proposing to replace/modify the dryer hoods and/or burners for each of these paper machines. Hoods that are replaced will include both hot air recirculating and “once through” hot air designs. The exact size of the new burners for each paper machine has not yet been determined, however, the maximum heat input for both burners will not exceed 70 MMBTUH for each paper machine (note that Paper M achine 15 burners will not be modified). The new hoods will enable the paper machines to increase actual drying rates, closer to the machine design rate, and have less natural gas c onsumption. T hese pr ojects w ill not c hange t he pot ential production rates for t he pa per machines. This section of the BACT analysis will only address burner emissions.

These conventional paper machines utilize Yankee dryers or after dryers to complete the drying process for tissue, towel, and napkin manufacturing. Yankee dry ers are a s pecific kind of dryer that combines large steam cylinders with an air hood that contains two natural gas

- fired burners. The Yankee dryer is a large cylinder heated internally by steam and externally by a hot air hood (hot air generated by gas or propane- fired burners).

While a detailed scope for the five paper machine modifications has not been fully developed as of the time of submittal of this permit application, the project will increase the drying capacity of all five paper machines. T he pa st a ctual a verage da ily pr oduction i s 948 A DT/day, a nd t he proposed projects are expected to yield an average actual increase of 50 tons per day combined.

Step 1 – Identify Control Technologies To i dentify t he c urrent t echnologies i n us e t oday f or r educin g PM /PM 10 , S O 2 , NO

x , C O, a nd VOC emissions from paper machine bur ners, i nformation w as c ollected e ither f rom ve ndor literature f rom t he I nternet or f rom t he ve ndors di rectly. A dditionally, a r eview of t he technologies i n us e a t G

- P’s ot her pa per m anufactu ring operations was conducted. T he m ost recent paper machines that have been permitted with new burners include G

- P’s paper mills in Wauna, Oregon; Port Hudson, Louisiana; Crossett, Arkansas; and Green Bay, Wisconsin. The permitted paper machines at the Wauna, Port Hudson, and Crossett locations are unique in dryingPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 79

technology ( i.e., through- air dr ying). T he ana lysis com pared these em ission rates w ith the Muskogee paper machines, even though these are not configured in a common design.

The technologies described below are for emissions generated by the combustion of natural gas in pa per m achine dr yer bur ners. W ithin t he c ompany, a n example technology is the Maxon

Crossfire burner. This burner utilizes low- NO X burner technology and is similar to some of the

burners used in G- P’s paper mills in the United States.

Particulate Matter Typically, when discussing the issue of minimizing PM/PM 10 emissions from natural gas

- fired burners in a BACT analysis, the only control used is “clean fuels”. N atural gas is the cleanest burning fuel available for combustion burners used in the United States. The use of natural gas for the dryer burners in the paper machines will result in very low emissions of PM/PM 10

. Based

on a PM/PM 10 emission factor of 7.6 lb s /MM ft 3 gas burned from AP-42 (EPA) and a 20% safety factor, the potential emissions for PM/PM 10 are 0.00912 lbs /MMBTU.

Control technologies such as a baghouse or wet scrubber would not normally be considered for reducing PM/PM 10 emissions when burning natural gas due to the very low emissions generated.

Sulfur Dioxide (SO 2 ) Natural gas a nd pr opane a re t he c leanest bur ning f uel a vailable f or c onsideration of S O 2 emissions. The use of natural gas/propane for the dryer burners will result in very low emissions

of S O 2

.

Vendor data and company operations do not identify control technologies such as a wet scrubber for na tural g as/propane bur ning due t o t he ve ry l ow e missions g enerated. The estimated SO 2 emission rate from the two dryer burners rated for a maximum of 70 MMBTUH heat input, using

emission factors from AP

- 42 (with a 20% contingency) and a heat content of natural gas of 1,000

Btu/ft 3 is only 0.00072 lb s /MMBTU or 0.22 tons per year, assuming 8,760 hours of operation per

year.

The es timated concentration of SO 2 in t he f lue g as e xhaust f rom t he dr yer bur ners from the combustion of na tural g as w ould be l ess t han 3 ppm v ( based on a typical 3,100 ft 3 /min combustion air flow for burner, operating temperature of 400 ° F, and 0.05 l b s /hr emission rate).

Add

- on pollution control device s could not reduce SO 2 emissions with such a low concentration in the flue gas exhaust.

Volatile Organic Compounds (VOC)

When combustion equipment is operated properly, by maintaining the correct combustion chamber temperature an d o xyge n content, VOC emissions a re m inimized. G ood c ombustion pr actices include operator practices an d m aintenance p ractices, an d f ollowing t he m anufacturer’s recommended pr actices. G ood c ombustion pr actices w ill m aintain t he correct combustion temperature and oxygen content to support complete combustion. T his ensures minimization of

VOC emissions.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 80

The actual level of VOC r eduction a chieved by us ing c ombustion c ontrol ve rsus not us ing combustion control is hard to predict since most facilities utilize good co mbustion practices to maintain efficient operations and so fuel is not wasted. However, an estimate for the reduction in V OC e missions f rom t he us e of g ood c ombustion pr actices on pa per machine burners can range from 30 -60% over poor combustion practices.

Other control technologies to reduce VOC emissions, such as the use of an oxidation catalyst, would not be c onsidered w hen bur ning na tural g as due t o t he ve ry l ow e missions generated.

Based on a VOC emission factor of 5.5 l b s /MM ft 3 of gas burned, a 20% safety factor, and a maximum he at i nput r ating of 70 M MBTUH, t he V OC emission rate i s 2.0 t ons pe r y ear, assuming 8,760 hours of operation per year.

The estimated concentration of VOCs (as propane) in the flue gas exhaust from the dryer exhaust

from the c ombustion of natural gas will be about 30 ppm v (based on 3,100 f t 3 /min combustion air flow for burner, operating temperature of 400 ° F, and 0.4 l b s /hr emission rate). No pollution control device could work effectively in reducing VOC emissions with such a low concentration in the flue gas exhaust.

Carbon Monoxide (CO)

The CO emission rate from a natural gas

- fired burner depends on the efficiency of the burner and whether or not nitrogen oxide controls have been designed into the burner (e.g., low- NO X or u ltra

low- NO X burners). W hen g as

- fired bur ners i ncorporate l ow

- NO X (or ul tra l ow

- NO X ) bur ner technology a s pa rt of t he de sign, C O e missions m ay be higher than they would otherwise be without the use of such technology. This occurs because low

- NO X burners require the use of low excess oxygen in the first stage of the burner compared to a conventional burner. Reducing the oxygen content i n t he f irst s tage of t he bur ner w ill t end t o i ncrease C O e missions due t o l ess efficient combustion in this stage of the burner.

Other control technologies to reduce CO emissions, s uch a s t he us e of a n ox idation c atalyst, would not be considered when burning natural gas due to the very low emissions generated. AP

42 l ists a C O e mission f actor of 84 lb s /MM f t 3 for na tural g as. I n pr eparing t his pe rmit application, the Mill reviewed recent data from the burner manufacturers. T he burner

- specific emission factor es timate i s m ore accur ate t han using t he A P

- 42 emission factor e stimate f or

boilers since it is based on actual ven dor test data for similar applications (not at the Muskogee Mill) of these Yankee dryer burners. T he CO emission factor (from the manufacturer) for the existing Maxon burners in the paper machines varies from 0.29 to 0.44 lbs /MMBTU.

The us e of g ood c ombu stion practices as sures t hat C O em issions f rom a bur ner ar e ke pt t o a minimum. Good combustion practices include operator practices and maintenance practices, and following the manufacturer’s recommended practices. Good combustion practices will maintain the correct combustion temperature and oxygen content to support complete combustion.

The c ontrol e fficiency a chieved f or c ombustion c ontrol va ries de pending upon a num ber of factors, i ncluding t he a ge of t he bur ner a nd c ontrol s ystem ut ilized f or m ixing fuel w ithPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 81

combustion air (manual vs. automatic), how c losely m anufacturer’s ope rating pr ocedures a re followed, and maintenance practices. The a ctual l evel of C O r eduction a chieved by us ing combustion control versus not using combustion control is hard to predict since most facilities utilize g ood c ombustion pr actices t o m aintain e fficient ope rations a nd s o f uel i s not wasted. However, an estimate for t he r eduction i n C O e missions f rom t he us e of g ood c ombustion practices can range from 30

- 60% compared to not using good combustion practices for a paper

machine burner.

Nitrogen Oxide (NO

x )

NO

x emissions are generated in three ways ; thermal NO

x , prompt NO

x , and fuel NO

x . Thermal

NO

x occurs in the high temperature zone near the burner itself. The formation of thermal NO

x is affected by ox ygen concentration, peak flame t emperature, and time of ex posure at peak temperatures. As t hese t hree f actors i ncrease, NO

x emissions al so increase. T he s econd

mechanism of NO

x formation, prompt NO

x , occurs in the flame i tself and results from the early reactions of nitrogen molecules in t he c ombustion a ir a nd hy drocarbon r adicals i n t he f uel. Prompt NO

x is usually negligible when compared to the amount of NO

x formed from the thermal

NO

x mechanism. T he t hird m echanism of NO

x formation, c alled f uel N O

x , r esults f rom t he

reaction of f uel

- bound ni trogen c ompounds w ith ox ygen. S ince na tural gas has very low nitrogen content, NO

x formation through the fuel NO

x mechanism is insignificant compared to

thermal NO

x formation.

Ther e are two approaches to control the emissions of nitrogen oxides in combustion gases: either modify the combustion operation to prevent the formation of NO

x or treat the combustion gas chemically, after the flame, to convert NO

x to elemental nitrogen. Lo w- NO X burners and flue gas recirculation modify the combustion operation.

Low- NO X methods The technique normally used to control NO

x emissions from natural gas

- fired burners in paper

machine burners is the use of low

- NO X or ultra low

- NO X burners

. These b urners employ either air s taging or f uel s taging or a c ombination of a ir/fuel staging techniques and specialized

combustion controls to minimize the formation of NO

x emissions. A ir staging is performed by introducing 50

- 75% of the combustion air into the primary combustion zone with all of the fuel. This pr oduces a r ich flame z one t hat r educes N O

x emissions due t o s ubstoichiometric combustion conditions (low oxygen content). T he remainder of the air is injected downstream, forming a secondary f lame z one w here c ombustion i s c ompleted. N O

x emissions in the secondary flame zone are reduced because the inerts from the primary flame zone reduce flame

temperature.

Fuel staging is the reverse condition of air staging. Generally, 30

- 50% of the fuel is injected into the combustion air to form a lean primary flame zone. NO

x emissions are minimized by the low flame temperatures that are generated due to the lean combustion conditions. The remainder of the f uel i s t hen i njected dow nstream f orming a s econdary f lame zone w here c ombustion is completed. NO

x formation rates in this zone are low because the inerts from the primary flame zone lower the flame temperature and oxygen concentration.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 82

Low

- NO X burners will r educe N O

x emissions by a t l east 30% c ompared t o N O

x em issions generated by c onventional bur ners, de pending upon t he s ize of t he bur ner, t he physical configuration of t he pa per m achine dr yer, a nd t he t ype of f uel be ing us ed. U ltra low

- NO X burners can also be used in paper machine dryer applications according to North American, who is t he onl y bur ner m anufacturer of fering t his t echnology f or Y ankee dr yers. U ltra low

- NO X burners can reduce NO

x emissions by 50% c ompared t o N O

x emissions g enerated by

conventional burners.

According to the manufacturer in 2005, t he NO

x emission rate from the existing Maxon LV -85 Line burners is approximately 0.12

- 0.15 lb s /MMBTU. Estimates for NO

x emissions from low

NO X burners r ange f rom 0.036

- 0.06 l b s /MMBTU ba sed on i nformation f rom s everal pa per

machine bur ner ve ndors. E stima tes for NO

x emissions for ultra low

- NO X burners range from

0.015-0.05 lbs/MMBTU based on information from North American.

Flue Gas Recirculation (FGR) FGR involves recirculating part of the combustion gases back to the burners in order to reduce

the f lame temperature and the ava ilable ox ygen content. Reducing the temperature and the available oxygen reduces the formation of NO

x emissions. FGR can reduce NO

x emissions by approximately 15-25%, depending upon specific operating conditions.

Selective Cataly tic Reduction (SCR) SCR is a post combustion control technology that uses the injection of ammonia followed by a catalyst to convert a ll N O

x to e lemental ni trogen. T ypically, va nadium ox ide i s us ed a s t he catalyst. The flue gas directed over the catalyst must be maintained within a specific temperature range, us ually be tween 600 and 1,100 ° F, or the c atalyst w ill not pe rform c orrectly. I f the temperature is too high, then the catalyst will be destroyed. SCR can reduce NO

x emissions by as

much as 90%.

Se lective Non -Catalytic Reduction (SNCR) SNCR is another pos t c ombustion c ontrol t echnology f or N O

x reduction. T his t echnology i s similar to SCR in that ammonia injection is required to convert all NO

x to elemental nitrogen. However, SNCR operates in the ab sence of a catalyst and requires a much higher temperature for the r eaction t o t ake pl ace, us ually i n t he r ange of 1,700 -2,100 ° F. S NCR can reduce N O

x emissions by 25-50%, depending upon specific operating conditions.

Review of EPA RACT/BACT/LAER Clearing house

Searches of the RACT/BACT/LAER Clearinghouse (RBLC) were conducted to identify control technologies f or t he c ontrol of P M/PM 10 , S O 2 , NO

x , C O, a nd V OC e missions f rom pa per machine dryer burners. Searches were only conducted for RBLC determinations a dded during or after January 1994. Any entries listing LAER as the basis for permit issuance were deleted since this pr oject i s not s ubject t o L AER. The s pecific E PA R BLC cat egories s earched are l isted

below. The que ry e xcluded t wo dr ying t echnologies t hat a re not a ppropriate f or t issue pa per manufacturing: Infrared and Flotation drying. These types of dryers are not commercially used to dr y t issue, na pkin, or t owel pr oducts. F lotation dr yers are normally used to dry solvent

PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 83

containing coatings used on pa per substrate surfaces while infrared dryers are normally used on grades he avier t han t issue or t owel pr oducts. T he bur ners us ed i n bot h f lotation and infrared dryers are designed specifically for use only in these dryers and cannot be used in Yankee dryers.

To the best of G

- P’s knowledge, there are no f lotation or infrared dryers in use or available for use to manufacture tissue paper products. Therefore, the burners in these two types of dryers and their respective emission rates will not be compare d to Yankee dryers in a BACT analysis.

11.05: External Combustion-Natural Gas Combustion 30.002: Kraft Pulp Mills 30.004: Pulp & Paper Production Other than Kraft

Several pages of the application are used to list all references found, but this analysi s lists only the salient points. Five companies in four states listed 15 units for the PM/PM 10 review. These units ranged in size from 12 to 117 MMBTUH and all of them listed natural gas or “clean fuel” as the control description. For the 13 units speci fying an emission rate in units of lb s /MMBTU, the range of values was from 0.004 to 0.024 lb s /MMBTU. Three companies in three states listed

11 units for the SO 2 review. These units ranged in size from 12 t o 117 M MBTUH and all of them listed natural gas o r “clean fuel” as the control description. For the six units specifying an

emission rate in units of lb s /MMBTU, the range of values w as f rom 0.0007 t o 0.0018

lb s /MMBTU. F ive c ompanies i n f ive s tates l isted 13 uni ts f or t he N O X review. T hese units ranged in size from 18 to 117 MMBTUH and 10 of them listed low- NO X burners as the control description. The control for three units in Wisconsin operated by Inter Lake Paper (18.2, 60.0, and 116.6 MMBTUH) showed “Conventional Dryer (modified)” as the control des cription

. For

the seven low- NO X units specifying an emission rate in units of lb s/MMBTU, the range of values

was f rom 0.0913 t o 0.115 l b s /MMBTU. A ll t hree of t he Inter Lake uni ts were listed at 0.12

lb s /MMBTU. Five companies in f ive s tates l isted 16 uni ts f or t he C O r eview. T hese uni ts ranged in size from 12 t o 117 M MBTUH and all but one of them listed natural gas or “Good Combustion Practices” as the control description. The excepted unit showed “No controls.” For the 12 uni ts specifying an emission rate in units of lb s /MMBTU, the range of values was from

0.1139 t o 0.26 lb s /MMBTU. T he e xcepted uni t di d not s how a n e mission f actor. F our companies in five states listed 12 units for the VOC review. These units ranged in size from 21

to 90 MMBTUH and all of them listed “No Controls” or “Good Combustion Practices” as the control description. For the nine units specifying an emission rate in units of lb s /MMBTU, the range of values was from 0.019 to 0.0564 lbs /MMBTU.

Step 2 - Technical Feasibility Analysis

PM/PM 10 Clean Fuel The use of clean fuel such as natural gas is technically feasible for the paper machine burners.

SO 2 Clean Fuel The use of cl ean fuel s uch as na tural g as i s t echnically f easible f or t he pa per m achine dr yer

burners.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 84

CO and VOC Oxidation Catalyst The use of a n ox idation c atalyst w ould not be f easible f or us e w ith t he pa per m achine dr yer burner exhaust after the gases have left the hood section of the paper machine since the exhaust temperature is approximately 400

- 450°F. This temperat ure range is well below the temperature requirement for an oxidation catalyst system to work efficiently, which is a minimum of 600°F. While t he pa per m achine dr yer e xhaust g ases c ould be heated back up to the optimum temperature range for the oxidation ca talyst to work, this would negate the effect of minimizing energy c onsumption a nd r ecovering he at f rom t he dr yer e xhaust. A dditionally, t he PM/PM 10 emissions f rom t he pa per m achine pr ocess ( not f rom the burners) would coat the oxidation catalyst, thereby significantly r educing its e ffectiveness. For t hese r easons, t he us e of a n oxidation catalyst is not technically feasible for controlling CO or VOC emissions from the paper

machine burners.

Low- NO

x and Ultra Low- NO

x Burners

The us e of l ow

- NO X or ultra lo w- NO X burners i n the pa per m achines dr yer i s t echnically feasible. T hese t ypes of bur ners ha ve C O and VOC em ission rates t hat ar e l ower than conventional burners that do not employ the low- NO X technology.

Combustion Control Through the use of good combustion practices, combustion control, is feasible for the control of CO and VOC emissions from the paper machine dryer burners.

NO

x Low-NOX or Ultra low- NOX Burners

The us e of l ow

- NO X or ul tra l ow

- NO X burners i s t echnically f easible f or t he pa per m achines

d ryer burners.

Flue Gas Recirculation Flue g as r ecirculation ( FGR) i nvolves r ecirculating pa rt of t he c ombustion g ases f or us e a s combustion air, in order to reduce the available oxygen, which in turn limits the generation of

NO

x . This means that the combustion gases from the paper machine dryer burners would need to
contain significantly higher oxygen content in order for FGR to be a usable source of combustion air. Since this is not possible, FGR with the existing Maxon burners would not be able to lowe r NO

x emissions. In addition, FGR presents other complications. The recirculated combustion gas from t he pa per m achine hood w ould c ontain s uspended particulate matter (from the paper machine process) that could foul the burner air passages. This, in tur n, would create a f uel rich condition, r esulting i n a pot entially s erious s afety ha zard. For these reasons, FGR is not technically feasible for controlling NO

x emissions from the existing paper machine burners.

Selective Catalytic Reduction

SCR w ould not be t echnically f easible f or r educing N O

x emissions from t he pa per m achines dryer burners for several reasons. F irst, the exhaust temperature would be too low (400 -450°F) for the SCR cat alyst t o react and convert N O

x emissions to elemental ni trogen. T he use of additional heat to raise the temperature of the exhaust gases would waste energy since the newPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 85

hood for the paper machines includes a design to recover the dryer heat for preheating the intake air. S econd, even if t he ex haust t emperature were raise d to the proper level for SCR to work effectively, particulate m atter em issions f rom t he pa per m achine pr ocess ( not f rom the dryer) would coat the SCR c atalyst. T his w ould s ignificantly r educe t he e ffectiveness of t he S CR system. Lastly, there is no room inside the dryer hood (where the burner is located) to install an SCR system. G

- P i s not a ware of a ny pa per m achine bur ners i n t he U .S. t hat e nlist S CR technology to c ontrol N O

x emissions. F or t hese r easons, S CR i s not t echnically feasible f or

controlli ng NO

x emissions from the paper machine dryer burners.

Selective Non

- Catalytic Reduction SNCR would not be technically feasible for reducing NO

x emissions from the paper machines dryer burners for one of the same reasons stated above for an SCR system – t he temperature of the paper machine exhaust is too low for attempting to treat the burner exhaust after it has left the hood s ection of t he pa per m achine. F urthermore, S NCR s ystems r equire t emperatures i n the range of 1,700

- 2,000°F t o ope rate e ffectively. Also, the S NCR pr ocess act ually r equires t he injection of ammonia in the zone above the paper machine dryer burner. This would contaminate the pa per pr oduct. G

- P c annot r isk c ontaminating t he pa per pr oduct w ith a mmonia and still

ensure that it conforms to customer specifications for sale to the general publ ic. There are no paper m achines i n t he U .S. t hat G

- P i s a ware of t hat us e S NCR t echnology t o c ontrol NO

x emissions. For these reasons, SNCR is not technically feasible for controlling NO

x emissions from the paper machines dryer burners.

Step 3 - Ranking the Technically Feasible Control Alternatives The f ollowing t able pr esents t he c ontrol t echnologies not e liminated i n t he previous step for paper machine burners using natural gas as the fuel, ranked by control efficiency.

Pollutant Technology Control Efficiency (%)

PM/PM 10 Clean Fuel/Use of Natural Gas N/A

SO 2 Clean Fuel/Use of Natural Gas N/A

NO

x low

- NO X Burners 30

- 75

Ultra low

- NO X Burners 50

- 95

CO/VOC Combustion Control 30-60

Step 4

– Cont rol Effectiveness Evaluation This step of the BACT process is necessary when the top control is not selected as BACT. Step 4 determines the economic impact of the feasible control options listed in Step 3 and then selects the most appropriate technology a s BACT for the paper machine burners. The economic analysis is based on c ost data supplied by the equipment suppliers and the use of EPA ’ s Office of Air Quality Planning & Standards (OAQPS) Control Cost Manual, 6 th edition, June 2003 (Chapter 2

- Cost Estim ating Methodology). Typical values were selected from the OAQPS Manual for the various parameters used to determine the cost effectiveness for reducing pollutant emissions.

Particulate Matter Since the Mill will only be burning natural gas in the paper m achine burners, which is equal to

the best level of control for PM/PM 10 emissions, an economic analysis is not required.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 86

SO 2 Since the Mill will only be burning natural gas in the paper machine burners, which is equal to

the best level of control for SO 2 emissions, an economic analysis is not required.

VOC As stated earlier in this analysis, due to the very low level of VOC emissions generated by paper machine burners, no control equipment can be justified to reduce VOC emissions any further. Therefore, cost effectiveness calculations have not been prepared.

NO

x The only feasible control technologies to reduce NO

x emissions are the use of either low

- NO X or ultra low

- NO X burners in the paper machine dryer. For cost estimating and emission estimating

purpos es, G

- P has first cal culated the cos t ef fectiveness of N orth American’s ul tra l ow

- NO X burner since it has the lowest NO

x emission rate of several different burners investigated, which

are listed below:

**•** North American Ultra low

- NO X burner (Model 4213 LEx)—0.015 lbs NO

x /MMBTU

**•** Maxon Crossfire low- NO X burner—0.036 lbs NO

x /MMBTU

**•** Maxon Kinedizer low- NO X burner—0.04 lbs NO

x /MMBTU

**•** North American low- NO X burner (Model 4096)—0.05 lbs NO

x /MMBTU

**•** Coen low- NO X burner (Model THE- QL) —0.06 lbs NO

x /MMBTU

North American informed G

- P that is has signed confidentiality agreements with the customers

who ha ve i nstalled t he ul tra l ow

- NO X burner and therefore G

- P c annot ve rify t he ope rational reliability or performance of the North American ultra low

- NO X burner. The capital equip ment
cost da ta a nd installation cost da ta f or North American’s ultra low

- NO X burner w as obt ained from Andritz Fiber Drying, an engineering firm that has worked with North American’s burners on paper machine projects.

G- P Engineering Department estimated t he startup and testing costs and also suggested the use of 30% of the direct capital costs for project contingencies. G-P used 30% as a contingency because of uncertainties with the use of a new type of burner that has never been used in any of G

- P’s

pape r mills and the fact that the cost estimate for North American’s burner is based on a plus or minus 30% accuracy. This is i n l ine w ith t he i nstructions c ontained i n E PA’s N ew S ource Review Workshop Manual (Draft October 1980, page B.35). T he cost for dir ect labor for the operation of the new burner system was also estimated by G

- P’s Engineering Department. G

- P used standard EPA Cost Control Manual factors for the following parameters.

**•** Freight charges – 5% of basic equipment cost

**•** 30-day working capital cost – direct operating costs divided by 12 months

**•** Supervisory labor costs for new burner system – 15% of direct labor costs

**•** Maintenance l abor and material cos ts

– equal t o di rect l abor c osts f or the operation of the new burner system

**•** Overhead costs – 60% o f direct operating labor and maintenance costs

**•** Property taxes

– 1% of total capital investmentPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 87

**•** Insurance
- 1% of total capital investment

**•** Administration

- 2% of total capital investment

**•** Cost recovery factor

– 0.1424 based on a 10

- year life of the equipment and a 7% interest rate for capital monies

The following table presents the annualized costs for the top two burners.

Table C

- 4. Summary of Annualized Costs for Burners for Paper Machines 11

- 14, Muskogee Mill

Cost Items Cost Factor 2004 dollars

NA U ltra low

NO X Maxon Crossfire

low

- NO X DIRECT CAPITAL COSTS (DCC):
(1) Purchased Equipment Cost
(a) Basic Equipment Based on Vendor Quote $542,000 $112,000

(b) Freight 0.05 x (1a) $27,100 $5,600

(c) Subtotal (1a + 1b) $569,100 $117,600

(2) Direct Installation outside engineering estimate $69,900 $47,805

Total DCC: (1) + (2) $639,000 $165,405

INDIRECT CAPITAL COSTS (ICC):
(3) Indirect Installation Costs
(a) Engineering & Supervision incl. w/1a $10,107

(b) Construct ion & Field Expenses incl. w/1a $10,107

(c) Construction Contractor Fee incl. w/1a incl. w/1a (d) Contingencies Ultra Low
NOx (0.30) x (DCC) (G

- P estimate) $191,700

(d) Contingencies Low NOx (0.15) x (DCC) (G

- P estimate) $24,811

(4) Othe r Indirect Costs
(a) Startup & Testing G

- P Engineering Estimate $5,000 $5,000

(b) Working Capital 30

- day DOC $1,463 $1,463

(c) Spare parts $30,000 $15,000

Total ICC: (3) + (4) $228,163 $66,488

TOTAL CAPITAL INVESTMENT (TCI): DCC + ICC $86 7,163 $231,893

DIRECT OPERATING COSTS (DOC):
(1) Operating Labor
Operator 1 hr/d x $22.37/hr x 365 d/yr $8,165 $8,165

Supervisor 15% of operating labor cost $1,225 $1,225

(2) Maintenance

Labor & Materials Equivalent to opera ting labor $8,165 $8,165

Total DOC: (1) + (2) $17,555 $17,555

INDIRECT OPERATING COSTS (IOC):

(3) Overhead 60% of oper. labor &
maintenance $10,533 $10,533

(4) Property Taxes 1% of total capital investment $8,672 $2,319

(5) Insurance 1% of total capital investment $8,672 $2,319

(6) Administration 2% of total capital investment $17,343 $4,638

Total IOC: (3) + (4) + (5) + (6) $45,219 $19,809

CAPITAL RECOVERY FACTOR (CRF)*: CRF 10 yrs @ 7% 0.1424 0.1424PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 88

Table C

- 4. Summary of Annualized Costs for Burners for Paper Machines 11

- 14, Muskogee Mill

Cost Items Cost Factor 2004 dollars

NA U ltra low

NO X Maxon Crossfire

low

- NO X CAPITAL RECOVERY COSTS (CRC ): CRF x TCI $123,464 $33,016

ANNUALIZED COSTS (AC): DOC + IOC + CRC $186,239 $70,380

Cost effectiveness is equal to the tons of pollutant removed divided by annual cost ($). The tons of pollutant removed can reflect either the emissions associated wi th the baseline throughput or the emissions associated with the potential throughput . T he uncertainty for the “tons removed” term reflects the fact that the burners are not usually operated at their maximum design heat input rates. While the grade of pa per product and consistency (water content) of stock determine the amount of drying needed, the paper machine uses heat exchangers, and steam in addition to the burners to dry the paper. T hus, t he M ill de termined t he c ost e ffectiveness us ing bot h

methodol ogies f or de termining the “ tons r emoved” te rm. The table immediately following presents the calculations for the amount of tons removed for each of these two burners. The next table calculates the range of cost effectiveness for both burners using the “t ons removed” term

from the first table.

PM11 PM12 PM13 PM14

North American Ultra Low NO X Burner @ 0.015 lb/MMBTU
Baseline heat input (MMBTU/yr) 113627 197251 159772 111735

Existing Burner NO X TPY (baseline) 6.8 11.8 9.6 8.4

ULNOX Burner NO X TPY (bas eline heat input) 0.85 1.48 1.20 0.84

Tons removed 6.0 10.4 8.4 7.5

Potential Burner heat input (MMBTU/yr) 613200 613200 613200 613200

Existing Burner NO X TPY PTE 25.2 17.3 17.3 25.2

ULNOX Burner NO X TPY (PTE heat input) 4.60 4.60 4.60 4.60

Tons removed 20.6 12.7 12.7 20.6

Cross Fire Low NOx Burner @ 0.036 lb/MMBTU
Baseline heat input (MMBTU/yr) 113627 197251 159772 111735

Existing Burner NO X TPY (baseline) 6.8 11.8 9.6 8.4

Lo NOX Burner NO X TPY (baseline heat input) 2.05 3.55 2.88 2.01

Tons removed 4.77 8.28 6.71 6.37

Potential Burner heat input (MMBTU/yr) 613200 613200 613200 613200

Existing Burner NO X TPY PTE 25.2 17.3 17.3 25.2

Lo NO X Burner NO X TPY (PTE heat input) 11.04 11.04 11.04 11.04

Tons removed 14.19 6.31 6.31 14.19PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 89

Cost Effectiveness Summary

NA Ultra Low NOx PM11 PM12 PM13 PM14

Annualized Cost $186,239 $186,239 $186,239 $186,239

Baseline heat input tons removed 5.97 10.36 8.39 7.54 Cost Effectiveness ($/ton) $31,220 $17,984 $22,203 $24,693

PTE heat i nput tons removed 20.6 12.7 12.7 20.6 Cost Effectiveness ($/ton) $9,028 $14,612 $14,612 $9,028

CrossFire Low NOx

Annualized Cost $70,380 $70,380 $70,380 $70,380

Baseline heat input tons removed 4.77 8.28 6.71 6.37 Cost Effectiveness ($/ton) $14 ,748 $8,495 $10,488 $11,051

PTE heat input tons removed 14.19 6.31 6.31 14.19 Cost Effectiveness ($/ton) $4,959 $11,159 $11,159 $4,959

Based on the ranges of cost effectiveness values, the Mill believes that the North American’s ultra

low- NOX burner i s not cost

- effective. T he CrossFire Low NOx burner can be considered cost

effective.

CO

The use of low

- NO X burners will affect CO emissions, and in some instances, installing low

- NO

x burners will increase CO emissions as discussed earlier in this analysis. Based on a review of a

number of l ow

- NO X and ultra l ow

- NO X burners a vailable i n t he m arketplace, a nd a s s hown below, the best level of CO emissions attainable for burners that can be used in Yankee dryers is

0.15 lbs /MMBTU.

**•** North American Ultra low

- NO X burner (Model 4213 LEx)—0.15 lbs CO/MMBTU

**•** Maxon Crossfire low- NO X burner—0.184 lbs CO/MMBTU

**•** Maxon Kinedizer low- NO X burner—0.3 lbs CO/MMBTU

**•** North American low- NO X burner (Model 4096)—0.15 lbs CO/MMBTU

**•** Coen low- NO X burner (Model THE- QL) —0.15 lbs CO/MMBTU

The Maxon Crossfire low

- NO X burner generates slightly higher CO emissions than the lowest burner available, which is 0.15 l b s /MMBTU. H owever, the primary purpose of installing low

NO

x burners i s t o r educe N O

x emissions. T o a ccomplish l ow N Ox technology, each burner manufacturer designs e quipment t hat m eets s lightly di fferent s tandards. S ince t he M axon

Crossfire low

- NO X burner is more cost effective than the North American ultra low

- NO X burner,

and s ince M axon’s C rossfire l ow

- NO X burner ha s l ower NO

x emi ssions t han a ny of t he ot her burners i nvestigated, G

- P be lieves t he M axon C rossfire low

- NO X burner r epresents t he be st

choice for CO emissions. It should be not ed t hat t he M axon C rossfire l ow

- NO X burner onl y generates a bout 60% of t he C O e missions t hat t h e burners currently in t he pa per m achines
generate.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 90

Step 5

– Select BACT For all of the reasons discussed in Step 4 above, G

- P believes that BACT for the paper machines

should be the use of Maxon’s Crossfire low

- NO X burner. Based on North American’s u ltra low

NO X burner cos t ef fectiveness, G

- P doe s not be lieve t hat t hese bur ners m eet B ACT. Additionally, to the best of G

- P’s knowledge, North American’s ultra low

- NO X burner has not been installed i n a ny Y ankee dr yer hood a s t he r esult of a BACT a nalysis required by a P SD application.

The following paragraphs present G

- P’s proposed BACT emission limits for Maxon’s Crossfire

low- NO X burner for each of the criteria pollutants:

PM/PM 10 BACT for PM/PM 10 emissions should be the use of natural gas as a clean fuel. G

- P agrees to a permit limit of 0.0091 lb s/MMBTU heat input.

SO 2 BACT for SO 2 emissions should be the use of natural gas as clean fuel. G

- P agrees to a permit

limit of 0.00072 l b s /MMBTU heat input. T his value is equal to the lowest values contain ed in the RBLC summary above.

VOC BACT for VOC emissions should be combustion control through the use of good combustion practices. G

- P agrees to a permit limit of 0.0066 lb s/MMBTU heat input.

NO

x For individual paper machines that replace the burner, B ACT for NO

x emissions is the use of a

low- NO X burner. G

- P a grees to a pe rmit limit of 0.04 lb s /MMBTU, which is e quivalent t o Maxon’s emission factor guarantee for the Crossfire low

- NO X burner. T his value is lower than the range of values contained in the RBLC summary above.

CO For individual paper machines that replace the burner, BACT for CO emissions is the use of a

low- NO X burner. G

- P agrees to a permit limit of 0.184 lb s /MMBTU heat input for the burner, which i s e quivalent t o M axon’s e mission f actor guarantee for the C rossfire l ow

- NO X burner. This value is within the range of values contained in the RBLC summary above, which is 0.06 to

0.214 lb s /MMBTU. Reducing the CO limit any further would most likely result in a higher NO

x value, which is undesir able.

BACT FOR PAPER MACHINE NOs. 11, 12, 13, 14, AND 15 PROCESS OPERATIONS

SOURCE DESCRIPTION The paper machine process operations emit only VOC and PM among the pollutants subject to PSD. The purpose of this analysis is to perform a BACT review of emissions from each paper machine, excluding those emissions from the bur ners, w hich w ere a ddressed a bove. V OC emissions a re e qual t o t he a mount of V OC c ontained i n c hemical a dditives us ed to enhancePERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 91

product quality and make the process more efficient. E xa mples of additives are softeners, wet strength r esins, c onditioners, de foamers, a nd r etention a ids. I n a ddition to these chemicals, release agents help keep the paper product from sticking to the process equipment. Additional VOC emissions from the paper machine area are from the cleaning solvents used to periodically clean the wire fabric of the paper machine. However, the cleaning solvent use is not modified as part of this project, and thus not subject to BACT.

Step 1 – Identify Control Technologies Review of Vendor Data and Other Operations Within the Company

VOC To identify the current technologies in use today for reducing VOC emissions from the addition of pr ocess c hemical a dditives a nd c leaning s olvents for paper machines, information was

collec ted from vendor literature found on the Internet or directly from the vendors. The analysis also reviewed technology in use at G

- P’s other paper manufacturing operations. The most recent paper machine project permitted at a G

- P facility is the No. 1 Pape r Machine at the Green Bay, Wisconsin Broadway Mill ( final P SD pe rmit is sued this y ear a vailable a t http://dnr.wi.gov/org/aw/air/permits/APM_toc.htm ). A nother pe rmit w as i ssued in April 200 3 for the No. 10 Paper Machine, also located at the Green Bay, Wisconsin Broadway Mill.

As indicated above, VOC emissions are primarily generated by the paper machine process from

VOC

- containing compounds that are added to the pulp at the “wet

- end” of the paper machine. For potential emission calculations, the very conservative assumption was made that all of the

VOC

- containing portion of t he che mical addi tives ar e r eleased to the at mosphere, either as fugitive emissions at the wet

- end of the paper machine , through building roof vents, or as point source emissions picked up off of the paper sheet through the Yankee Dryer exhausts (dry

- end of paper machine).

Based on VOC stack testing performed by N CASI a t t he M uskogee M ill ( Nos. 12 a nd 14, December 1995), the “dry end” of both paper machines emitted 62% of the VOCs measured and the “wet end” of the two paper machines emitted the other 38% of the VOCs measured. The testing performed by NCASI doe s not a ccount f or l osses a ttributable t o a ll f ugitive e missions from chemical additives and manual cleaning activities with VOC

- containing cleaners.

Based on a comparison of emission factors developed for paper machines by NCASI versus the use of material balance to calculate VOC emission rates, G

- P has determined th at considerably higher VOC emission rates are estimated based on the material balance approach. G

- P believes

that one of the reasons for this di fference i n VOC em ission estimates i s because t he em ission factors developed by NCASI are based on stack testin g conducted through point sources and do not capture all of the fugitive VOC emissions that escape through other portions of a building enclosure, s uch a s r oof ve nts, door ways, e tc. A dditionally, t he stack testing conducted by NCASI doe s not “capt ure” al l VOC

- emitting m aterials be cause of i naccuracies w ith the test methodology. B ecause of these previous findings by G

- P, the more conservative technique of using a material balance appr oach to calculate t otal V OC em issions f rom pa per m achine operations has been used in this BACT analysis.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 92

Within the last few years, three paper machines have been permitted at G

- P’s facilities in Wauna, Oregon, Port Hudson, Louisiana, and Crossett, Arkansas. However, the paper machines at these three f acilities ar e uni que in d rying t echnology ( through a ir dr ying) a nd a re not c onfigured

similar to the Muskogee Mill paper machines.

Typical control technologies for the c ontrol of V OC e missions f rom m anufacturing pr ocesses within the c ompany a re limite d to use of l ow

- VOC c ontainin g chemicals or w ater -borne

chemical additives. The use of low

- VOC containing chemicals or water

- borne chemicals with little or no V OC content in place of currently used VOC

- containing chemicals are methods that will reduce VOC emissions when applied prope rly. The amount of VOC emission reduction that can be achieved is highly variable depending on the specific application.

Particulate Matter

PM/PM 10 emissions ar e g enerated in the pa per m achine pr imarily on the “dry end” of the machine as fugitive dust. Some of this dust is picked up by the paper machine hood exhausts and is e mitted t hrough s tacks t o t he a tmosphere. Based on s tack t esting c onducted at the FJOC Savannah River Mill (Paper Machine No. 19), it is known that a significant percentage (50% or

m ore) of the overall PM/PM 10 emissions generated by a paper machine are emitted as fugitive dust through the roof vents of the building that houses the paper machine. This information was used when calculating the potential PM/PM 10 emission rates for the p aper machine and in this BACT analysis. PM/PM 10 emissions from the “wet end” of the paper machine are considered insignificant w hen c ompared t o P M/PM 10 emissions f rom t he “ dry e nd” of a paper machine based on the following reasoning:

The fan pump transports a large amount of water to the “wet end” of the paper machine. This water is a carrier of the fiber (stock) that is formed into a sheet and dried to make our tissue and toweling products. The water that is removed from the sheet is returned to the pr ocess to be reused again to transport stock. Since the paper machine is running at a very high rate of speed when making product (4 ,500-5, 000 feet per minute), there is some spray and water droplets generated inside the paper machine room. The spray and water droplets fall back onto the process and do not exit the paper machine room and are returned to the water recycle loop or are routed to the wastewater treatment system. The only vapor from the “wet end” of the paper

machine that exits the machine roo m is through the vacuum pump exhaust. The vacuum pump assists in the removal of water from the fibers in the wire and felt sections of the “wet end” (forming section). These vapors would not contain any fibers but may contain insignificant trace amounts of suspended material from the water loop.

Because of t his r easoning, G

- P ha s not r outinely c onducted s tack t ests t o de termine t he particulate matter emissions from the “wet

- end” of paper machines. A search for “wet end” stack

test data at all of G

- P’s r ecycle paper mills indicated that there has only been one “wet end” stack test for particulate matter emissions performed, which was at the Port Hudson, Louisiana Mill on the pulper exhaust for Paper Machine No. 5 (test conducted in September 2001). The results of that testing indicated a particulate matter emission rate of 0.14 pounds per hour (lbs/hr) or 0.01 pounds per air

- dried ton (lbs/ADT). While this represents only one exhaust point from the “wet end” of a paper machine, the results confirm that p articulate matter emissions from the “wet

- end”PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 93

of a paper machine are quite low when compared to the particulate matter emissions from the “dry end” of a paper machine.

The N o s . 11, 12, a nd 13 P aper M achines a re c onsidered a “ wet c repe” paper machine. An explanation of the word “crepe” used in paper machine manufacturing is provided below:

The continuous sheet of paper leaves the forming section (“wet

- end”) of the machine where water has been drained from the formed sheet to approximately 50% moisture. The paper sheet then goes through the Yankee drying section where it actually sticks to the hot surface of the Yankee cylinder. The sheet must then be scraped off of the cylinder with a doctor blade. This removal of the sheet by the doctor blade causes t he sheet to "crepe" off, (e.g., come off in a wrinkled state) giving the sheet a bulk texture that makes it softer and more absorbent. A "dry crepe" process doctors the sheet off the Yankee after the sheet is fully dry. A "wet crepe" process

doctors the sheet off while it is still slightly moist (10

- 20% moisture) and then further dries the sheet in an after

- dryer that follows the Yankee. The "wet creping" sheet better retains its

bulkiness and absorbent characteristics.

Based on t his e xplanation, dr y c r epe pa per m achines cr eate m ore dus t t han wet cr epe pa per machines. For example, one of the primary points of dust generation, the doctor knife blade that removes the tissue (or towel) sheet from the Yankee Dryer, would be expected to have higher

PM e missi ons w hen t he t issue s heet i s a t a m uch l ower m oisture c ontent (approximately 5% moisture content).

Typical control t echnologies f or t he c ontrol of P M/PM 10 emissions f rom m anufacturing processes within the company include baghouses and wet scrubbers. A br ief explanation of these control technologies is provided below.

Baghouses A baghouse, or fabric filter, is one of the most efficient devices for removing particulate matter. Baghouses ha ve t he c apability of m aintaining c ollection e fficiencies above 99% f or pa rticles down to 0.3 micrometers ( **μ** m) in diameter. The basic components of a fabric filter unit consist of woven or felted fabric, usually in the form of bags that are suspended in a housing structure (baghouse), an induced draft or forced draft fan; and a blow

- back fan, reverse air fan, pulse

- jet fan, or a m echanical s haking m echanism. T he e mission s tream i s di stributed by means of specially designed entry and e xit pl enum c hambers, pr oviding e qual g as f low t hrough t he filtration medium. T he pa rticle collection mechanism f or f abric f ilters inc ludes ine rtial impaction, Brownian diffusion, gravity settling, and electrostatic a ttraction. T he pa rticles a re collected in dry form on a cake of dust supported by the fabric or on the fabric itself. The proce ss occurs with a relatively low

- pressure drop requirement (usually within the range of 2

- 6” water column pressure). Periodically, most of the cake dust i s r emoved f or di sposal. C ake dus t i s removed by shaking or a “rapping” system, with the use of revers e air, or with the use of a pulse jet of air. Dust is collected in a hopper at the bottom of the baghouse and is removed through a valve a nd dum ped i nto a s torage c ontainer. U sually, t he dus t i s di sposed of at an industrial

landfill.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 94

Wet Scrubbers

Wet s crubbers are collection devices that trap wet particles in order to remove them from a g as stream. They ut ilize ine rtial impa ction and/or B rownian diffusion as the pa rticle c ollection mechanism. W et s crubbers g enerally us e w ater as the cleaning liquid. Water us age and wastewater di sposal r equirements ar e i mportant f actors i n the eva luation of a scrubber alternative. T ypes of s crubbers i nclude s pray s crubbers, c yclone s crubbers, pa cked -bed scrubbers, plate scrubbers, and venturi scrubbers. The most comm on particulate matter removal scrubber is the venturi scrubber be cause of i ts s implicity ( i.e., no m oving pa rts) a nd hi gh collection efficiency. In this type of scrubber, a gas stream is passed through a venturi section, before which, a low

- pressure liqui d (usually water) is added to the throat. The liquid is atomized by the turbulence in the throat and begins to collect particles impacting the liquid as a result of differing velocities for the gas stream and atomized droplets. A separator is used to rem ove the particles or liquid from the gas stream. The most important design consideration is the pressure drop across the venturi. Generally, the higher t he pr essure dr op, t he hi gher t he c ollection efficiency.

Review of EPA RACT/BACT/LAER Clearinghouse

V OC Additional t ypical t echnologies f or t he c ontrol of V OC e missions f rom general manufacturing processes i nclude c arbon a dsorption, bi ofiltration, i ncineration ( e.g., recuperative t hermal oxidation, recuperative catalytic oxidation, regenerative thermal ox idation, etc.). H owever, none

of these add -on control devices have been determined as BACT by EPA or Oklahoma DEQ. Thus no additional technologies are considered available.

Searches of the RACT/BACT/LAER Clearinghouse (RBLC) were conducted to identify c ontrol technologies for the control of VOC emissions from the paper machine manufacturing process. Searches w ere onl y c onducted f or R BLC de terminations a dded during or after January 1994 to determine the latest technologies in use.

The specific EPA RBLC categories searched are listed below:

30.002 Kraft Pulp Mills 30.004 Pulp & Paper Production Other than Kraft

Several pages of the application are used to list all references found, but this analysis lists only the salient points. T hree companies in thr ee states listed five units for the PM/PM 10 review. O nly three had capacity listed, and these ranged from 304 t o 806 t ons per day. O nly four of the five manufacture t issue or t oweling. C ontrol de scriptions i ncluded “good operating practices,” wet

scrubb er, ve ntur i scrubber ( dry e nd), a nd c yclone ( wet e nd). E mission r ates were specified in many ways. One scrubber had emissions specidied as 0.0035 grains/acfm, while another scrubber specified 0.24 l bs/ADT. T he ve ntur i specified 95% reduction a nd t he c yclone s pecified 90%

reduction. Fifteen companies in eight states listed 39 units for the VOC review.

The vast majority of the lis ted units a re f or f acilities tha t ma nufacture pa per pr oducts tha t a re significantly different from the tis sue/toweling pr oduct s t hat t he M uskogee M ill m anufactures. These other paper products include coated board, containerboard, specialty papers, fine printingPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 95

and writing papers, baby diapers, school and office papers, corrugated containers, and paperboard. All of these types of products have different properties that are specific for their designated end

use.

The two most important differences in the paper making process related to this BACT analysis are the “basis weight” characteristic and the additive chemistry. The “basis weight” on the Muskogee Machines is generally much lower than the “basis weight” for the majority of the products listed in the RBLC review. The “basis weight” for the Muskogee Mill machine products varies from

9.3- 13.1 pounds pe r 3,000 s quare feet while the “ basis w eight” f or t he ot her t ypes of pr oducts listed i n t he R BLC r eview i s s everal t imes hi gher. T he pr oducts m ade on the Muskogee Mill paper m achines ha ve s pecial end

- use cha racteristics t hat r equire t he us e of cer tain types of

chemical additives to produce these specific qualities.

For these two reasons, the majority of the paper machines listed in the RBLC review cannot be considered t o be “ similar s ources” t o t he M uskogee Mill machine s for pur poses of t his BACT analysis. Only those five units th at manufacture tissue or toweling and can be considered to be “similar sources” are discussed in Step 2 of this analysis. T he five units to be considered listed control descriptions that involved limiting tot al V OC or limiting the VOC content of materials

used.

Step 2 - Technical Feasibility Analysis

VOC Use of Water -Borne or Low VOC-Containing Chemical Additives

The use of water

- borne chemicals or low VOC

- containing chemicals in place of currently used

VOC

- containing chemicals is a method that will redu ce VOC emissions when applied properly. The reduction in VOC emissions, of course, depends on the VOC content of the chemical being replaced. Not all water

- borne or low VOC

- containing chemicals can perform as effectively as those chemicals with a higher V OC content. The paper manufacturing process is very sensitive to different chemicals since the final product must meet stringent customer specifications for sale to the general public.

The Muskogee Mill machines make a number of different types of tissue /toweling products that require the use of a wide range of chemical addi tives t o meet cus tomer s pecifications. I t i s important t hat t he M uskogee pa per m achines be abl e t o use the different types of chemical additives, in order to continue to make the many different types of tissue/toweling products for its

customers.

The e ntries lis ted in the R BLC r eview tha t ma ke pr oducts similar to those made by the five machines at the Muskogee Mill are the No. 8 Tissue Machine at G

- P’s Crossett, Arkansas Mill,

the Nos . 9 and 10 Paper Machines at the Green Bay Broadway Mill, and Proctor & Gamble’s four paper machines located in Missouri. BACT for the No. 8 Tissue Machine was considered to be no control because controlling the VOC emissions from the paper machine was not considered to be cost effective due to the relatively low VOC emissions and the high airflow from the paper machine. This selection of BACT resulted in an emission rate of 0.046 lbs VOC/ton paper.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 96

This value w as de rived from a s imilar s ource lis ted in a NCASI t echnical bul letin (Technical Bulletin No. 681, O ctober 1994, T able V.C.1). T he No. 8 T issue Machine application did not incorporate VOC emission estimates using a material balance for the chemical additives used on the pa per m achine as ha s be en do ne f or t he M uskogee pa per m achines. If a m aterial balance calculation had been used, then the BACT limit would have been considerably higher than the

0.046 lbs VOC/ton value.

The overall BACT limit for G

- P’s No. 10 Paper Machine at the Green Bay Mill was listed as 2.9 lbs VOC/ton paper while the overall BACT limit for the No. 9 Paper Machine at the Green Bay Mill was listed as 2.7 lbs V OC/ton paper. T hese BACT limits are based on using a material

balance for the chemical additives to determine the VOC em ission rate from the paper machines. BACT for both of these paper machines a lso e stablished s pecific V OC l imits i n t he uni ts of pounds per month for cleaning solvent and chemical additive usage.

BACT for Proctor & Gamble’s four paper machines was listed a s “VOC emissions limited to 2%

of the chemical additives content” and use of low

- VOC content additives consistent with product quality and equipment operation. It should be noted that the P&G paper machines use “through air dr y” ( TAD) t echnology, w hich i s different f rom a c onventional pa per m achine that uses Yankee D ryer t echnology. T he di fference be tween T AD technology and conventional technology primarily involves the drying section of the paper machine, where TAD allows the evaporation of large quantities of water prior to the Yankee drying section, imparting optimum quality with high bulk and great softness. In the TAD drying section, the formed sheet travels on a felt fabric and a release aid (containing VOC) is needed to assist in removing the sheet off the fabric. T he che mical addi tive pa ckage f or t he T AD t echnology i s ve ry di fferent from the chemical additive package used for the Muskogee Mill paper machines.

Particulate Matter Baghouses The use of a B aghouse for this process is technically feasi ble if the combined air flow from all “dry end” point sources of the paper machine and the building roof vents were collected as one large source and then directed to a baghouse. As stated earlier in this report, the majority of the

PM/PM 10 emissions from the paper machine are generated in the “dry end” of the unit, as well as from roof vents that collect fugitive dust. Based on tests conducted on the No. 19 Paper Machine at the FJOC Savannah River Mill, about 50% of the PM/PM 10 is generated from “dry end ” point sources of the paper machine and the other 50% of the PM/PM 10 is generated as fugitive dust from the paper machine operation and is emitted to the atmosphere through room vents in the roof of the building. T he cost effectiveness of using a baghous e to control PM/PM 10 emissions from all of the “dry end” point sources and roof vents is presented later in this analysis.

A baghouse could not be used to control emissions from only the “wet end” of a paper machine since t he hi gh m oisture c ontent of t he exhaust gases generated from t his s ection of a pa per machine makes the baghouse collection ineffective.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 97

Wet Scrubbers

A wet scrubber could also be us ed t o c ontrol P M/PM 10 emissions f rom t he s ame “dr y end” exhaust points of the paper machine and from the roof vents. The cost effectiveness of doing this is presented later in this analysis. As stated earlier in this analysis, the “wet end” of the paper machine does not generate significant quantities of PM/PM 10 emissions and it would not be cost

effective to try to control small quantities of emissions from a source with very high air flow.

As not ed i n t he P M/PM 10 entries l isted for t he R BLC r eview, there ar e f our pa per m achine

sources w ith BACT de terminations f rom “ similar s ources

. ” E ach of t hese B ACT r esults i s discussed more fully below:

Crossett, Arkansas No. 8 Paper Machine

BACT for G

- P’s No. 8 Paper Machine at the Crossett Mill was determined to be a wet scrubber on the “dry end” of the paper machine. Paper Machine No. 8 is a dry crepe paper machi ne that primarily makes tissue products. As discussed above, dry crepe paper machines create more dust than wet crepe paper machines because one of the primary points of dust generation, the doctor

knife blade that removes the tissue sheet from the Yankee Dryer, is contacting a sheet that has a much lower moisture content (approximately 5% moisture content) than would be encountered for a wet crepe paper machine (up to 20% moisture content). T he wet scrubber at the Crossett Mill w as vol untarily ins talled by the Mill to reduce dust e xposure f or t he pa per m achine operators rather than for environmental permitting purposes. The wet scrubber was also installed as a safety measure to minimize the build -up of dust that could lead to a fire in the paper machine building. Additionally, the wet scrubber does not control all of the dust generated by the paper machine, because there are only a few points of dust generation that are “picked

- up” from the paper machine and directed to the w et s crubber. T here ar e addi t ional l osses of dus t t o t he atmosphere t hrough t he pa per m achine e xhaust s tacks, a s w ell a s t hrough t he pa per machine building roof vents.

P & G Paper Machines in Missouri BACT for the four P & G paper machines was determined to be a cyclone on the former section of the paper machines and a venturi scrubber on t he “dry end” section of the paper machines. The use of a cyclone on the former section of a paper machine is done primarily to reduce wet mist generated by that section of the paper machine and not to reduce PM/PM 10 emissions . The wet m ist c an be a nui sance f or t he ope ration of a pa per machine by causing corrosion on the structure of the paper machine and the paper machine building over time. Some paper machines have installed mist elimination sys tems that consist of a f an and a separation device, such as a mist eliminator or cyclone separator. A mist elimination system directs the wet mist outside of the paper machine building while the water collected by the separation device is either recycled or sent to the mill’s wastewater treatment system.

Green Bay, Wisconsin No. 10 Paper Machine BACT for Paper Machine No. 10 was determined to be good operating practices. No. 10 is a wet crepe paper machine that does not g enerate s ignificant qua ntities of dust w hen m anufacturing tissue/towel products. It does not require a scrubber or other type of control device to minimize employee exposure to dust in the workplace. Operators for Paper Machine No. 10 ut ilize goodPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 98

operating practices to minimize the gen eration of dust by routine cleaning of the paper machine and paper machine area with the use of air and water hoses to blow or wash the machine and

floor areas.

Green Bay, Wisconsin No. 9 Paper Machine BACT f or P aper M achine N o. 9 w as de termined t o be the use of a w et s crubber a nd g ood operating practices. No. 9 is a dr y crepe paper machine that generates significant quantities of dust when manufacturing tissue/towel products, therefore, it requires a wet scrubber to minimize employee e xposure t o dus t i n the workplace. O perators f or N o. 9 a lso ut ilize good ope rating practices to minimize the generation of dust by routine cleaning of the paper machine and paper

machine area with the use of air and water hoses to blow or wash the machine and floor areas.

S tep 3 - Ranking the Technically Feasible Control A lternatives t o E stablish a C ontrol Hierarchy

VOC The only technically feasible technology for paper machine process emissions is “Use of Low

VOC containing chemicals.” Thus, it is ranked as the top control.

Particulate Matter The only technically feasible technology for paper machine process emissions are a baghouse and wet scrubber for “dr y cr epe” m achines and wet s crubber f or “w et cr epe” and dry/wet cr epe

machines. Baghouses are ranked as the top control above wet scrubbers.

Step 4 – Control Effectiveness Evaluation This step of the BACT process is necessary when the top control is not selected as BACT. Step 4 determines the economic impact of the feasible control options listed in Step 3 and then selec ts the most appropriate technology as BACT for the paper machine manufacturing process. T he economic analysis is based on c ost da ta s upplied by t he e quipment s uppliers a nd t he us e of

EPA ’ s Office of Air Quality Planning & Standards (OAQPS) Control Cost Ma nual, 5 th Edition, February 1996 ( Chapter 2

- Cost Estimating Methodology). Typical values were selected from the O AQPS M anual f or t he va rious pa rameters us ed to determine t he cos t ef fectiveness for reducing pol lutant e missions. V arious e ngineering c alcu lations utilized to complete the da ta requirements for the spreadsheets were provided in the application.

VOC Use of Water -Borne or Low VOC-Containing Chemical Additives The M ill ha s a N ew S ubstance R eview pr ogram i n place t o review al l chemicals for

envi ronmental effects. B efore any ne w s ubstance can be pur chased at t he M ill, the M ill’s Environmental Department must make an assessment of t he V OC c ontent a nd de cide i f t here should be an alternative substance used that has a lower VOC content. T his program helps to

assure that the Mill can use the lowest VOC

- containing materials available in the marketplace, yet m aintain pr oduct qua lity. O ver t he pa st f ew y ears, this program has enabled the Mill to reduce the VOC c ontent of a num ber of c hemical a dditives. F or e xample, t he c onversion of some of t he w et s trength r esin us ed i n t he pa per m achines ha s r esulted in reducing the VOC content f rom 3.4% t o 1.5% . W et s trength r esins a ccount f or a l arge por tion of t he VOCPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 99

generated in the pa per m achines due t o the la rge quantities of resin used (not due to its VOC concentration). A third example is the conversion of the use of VOC

- containing inks used in the Mill’s printing operations to water -based printing inks, or printing inks with low VOC content.

A cost analys is for this section of the BACT analysis is not being performed since lowering the overall VOC content of the chemicals used as additives and cleaners is considered a pollution prevention technique and is considered the most effective choice.

Particulate Matter Baghouse Paper Machines 11, 12, and 13 are wet/dry crepe and a baghouse is not technically feasible for these 3 machines. To utilize a ba ghouse t o c ontrol pa rticulate m atter e missions f or pa per machines 14 and 15, the exhaust airflow from the vario us process sections of the paper machine and the roof vents must be tied together to reduce the moisture content and the temperature to an acceptable level. The analysis used the EPA’s cost control spreadsheet for baghouses. The total

airflow ra te for t h e building e xhausts f or pa per m achines 14 a nd 15 a re 385,200 a nd 445,400 acfm, respectively. T he m ost c onservative e stimate i s obt ained by us ing t he l owest f lowrate. Thus, the cost effectiveness analysis evaluated the flowrate for Paper Machine No. 14, bu t the conclusion is applicable to both Paper Machine 14 and 15. The equipment cost does not include

a site

- specific amount for auxiliaries. As this table indicates, the lowest estimated rate is over $6,000/ton and is not cost effective.

Total Annual Co st Spreadsheet Program

— Baghouse [1] COST BASE DATE: Second Quarter 1998 [2] VAPCCI (Fourth Quarter 1998

-- FINAL): [3] 122.0 Escalation from 4th quarter 1998 to 4th quarter 2002 (Estimated at 1.1)
INPUT PARAMETERS:

-- Inlet s tream flowrate (acfm): 385,200

-- Inlet stream temperature ( o F): 120

-- Inlet stream temperature, adj.

-- pulse jet only ( o F): 120

-- Dust type: Paper fiber

-- Inlet dust loading (gr/ft 3 ): (based on 5.9 tpy) 0.0078

-- Dust mass median diameter (microns) : 7

-- Filtration time (min): 10

-- Dust specific resistance (in.H 2 O/fpm/lb/ft 2 ): 15

-- G/C ratio factors (shaker & reverse -air): A: 2.0

B: 0.9
C: 1.0

-- G/C ratio factors (pulse

- jet):

--- dust type Material: 12.0

--- nuisance relief Application: 1 .0

--- G/C ratio factors(cartr. filters): A: 2.1

--- application B: 1.0

--- temperature C: 0.90

--- Dust fineness factor D: 0.9

--- Grain Loading E: 0.008

-- Cleaning pressure, psig (pulse

- jet only): 100

-- Fraction of bags cleaned (shaker & rev

- air): 0. 1

-- Insulation required? ('yes'=1;'no'=0): 1

-- Stainless steel required? ('yes'=1;'no'=0): 0

-- Bag material: Polyester

-- Fabric effective residual drag (in. H 2 O/fpm): 1.1PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 100

Total Annual Co st Spreadsheet Program

— Baghouse [1] Cleaning Mech Bag Diam. (in.) Price ($/ft2)

Pulse jet --BBR 4.5 to 5.125 1 .69

6 to 8 1.55

Pulse jet --cart. 4.875 0.00

6.125 0.00
Shaker

-- strap 5 0.00
Shaker

-- loop 5 0.00

Reverse air w/o rings 8 0.95

11.5 0.75

-- Cost of auxiliary equipment ($): [7] 50,000

-- Gas

- to

- cloth ratio (acfm/ft 2 cloth area): Shaker: 1.80

Re verse

- air: 1.80

Pulse

- jet: 13.81 Cartridge: 1.33E

- 02

-- Net cloth area required (ft 2 ): Shaker: 214,000

Reverse

- air: 214,000

Pulse

- jet: 27,898 Cartridge: 28,918,102

-- Gross cloth area required (ft 2 ): Shaker: 222,560

Reverse

- air: 222,560

Pul se

- jet: 27,898 Cartridge: 28,918,102

-- Area per bag

-- reverse

- air (ft 2 ) (8

- in. x 24

- ft): 50.3

-- Number of bags

-- reverse air: 4,428

-- Area per bag

-- shaker (ft 2 ) (5

- in x 8

- ft): 10.5

-- Number of bags

-- shaker 21,253

-- Area per bag

-- pulse jet (ft 2 ): Small (4.5

- in. x 8

- ft) 9.42 Large (5.125

- in. x 10

- ft) 13.42

-- Number of bags/cages (pulse

- jet only): Small bags 2,961 Large bags 2,080

-- Area per bag

-- cartridge (ft 2 ): 153

-- Number of bags

-- cartridge: 189,008

-- Bag pressure drop (in. w.c.): Sha ker 1.98

Reverse

- air 1.98

Pulse

- jet 4.24 Cartridge 0.01

-- Baghouse shell pressure drop (in. w.c.): 3.00

-- Ductwork pressure drop (in. w.c.): 4.00
CAPITAL COSTS Equipment Item: Cost ($): System type Shaker Rev

- air P

- J (mod) P

- J (com) Baghouse 0 1,066,625 261,416 202,143 Bags

-- small 0 166,920 47,148 47,148 Bags

-- large 43,242 43,242

Insulation 0 210,844 63,254 76,079
Stainless 0 0 0 0 Cages

- small [5] 0 0 17,718 17,718 Cages

- large 0 0 22,954 22,954

Auxiliaries 0 50,000 50,000 50,000

To tal

-- small[5a] 0 1,494,388 439,536 393,087

Total

-- large: 440,867 394,418 PEC($)

- base: 0 1,763,378 518,653 463,843 PEC($)

- esc.: 0 1,978,975 582,065 520,554 TCI ($): 0 4,294,375 1,263,081 1,129,602 ($/acfm): 0 11.15 3.28 2.93 Operating factor (hr /yr): 8,760 Operating labor rate ($/hr): 24.60 Maintenance labor rate ($/hr): 27.06 Operating labor factor (hr/shift): 2PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 101

Total Annual Co st Spreadsheet Program

— Baghouse [1] Maintenance labor factor (hr/shift): 1 Electricity price ($/kWhr): 0.0340 Compressed air ($/1000 scf): 0.11 Dust disposal ($/ton): 13.35 Annual interest rate (fraction): 0.07 Control system life (years): 10 Capital recovery factor: 0.1424 Bag life (years): 2 Capital recovery factor (bags): 0.5531 Taxes, insurance, admin. factor: 0.01

Item Shaker Reverse

- a ir P- J (modular) P- J (common) Oper. labor 0 53,874 53,874 53,874 Supv. labor 0 8,081 8,081 8,081

Maint. labor 0 29,631 29,631 29,631

Maint. matl. 0 29,631 29,631 29,631 Electricity 0 805,796 233,394 233,394 Compr. air 0 0 44,137 44,137 Bag repl. 0 1 26,217 50,564 50,564 Dust disposal. 0 1,512 1,512 1,512
Overhead 0 72,730 72,730 72,730 Tax,ins.,adm 0 42,944 12,631 11,296 Cap. recov. 0 578,931 166,818 147,813

Total Annual 0 1,749,346 703,002 682,663 ($/ton):[6] 0 $ 15,447 $ 6,208 $ 6,028 [1] P arameters and other input data needed for this program can be found in Chapter 5 (December 1998 revision) of the 'OAQPS Control Cost Manual' (5th edition). [2] Base equipment costs reflect this date. [3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for fabric filters) corresponding to year and quarter shown. Base equipment cost, purchased equipment cost, and total capital investment have been escalated
to this date via the VAPCCI. [4] These prices pertain to the bag material entered above. If this bag material is not available for a baghouse type, enter '0'. (See 'Manual,' Chapter 5, Table 5.8.) [5] Cage prices calculated from "500

- cage lots" cost equations [5a] Total equipment cost for "small" and "large" bags and cages cases, respectively. [ 6] Total annual cost ($/yr) divided by total particulate captured (tons/yr). [7] As a conservatively low estimate, the analysis included $50,000 for the cost of the large amount of ductwork needed to tie all paper machine exhaust stacks into one common duct that would direct emissions to the baghouse. The Mill believes that this estimate is much less than a site

- specific value would be.

Wet Scrubber The next most effective control device for al l P aper M achines i s a w et s crubber and it i s technically f e asible. T o de termine t he c ost e ffectiveness of us ing a w et ( venturi) s crubber t o

control P M/PM 10 emissions, t he a nalysis us ed E PA’s C ost C ontrol s preadsheet f or a ve nturi scrubber. The following table presents t he c ost c ontrol c alculations a nd a ssumption s. I t i s assumed that only the wet

- end and dry

- end Yankee Dryer exhaust stacks are controlled by the

wet scrubber. The flowrate for the Yankee exhausts alone are much lower than the other roof vents. T he Yankee exhaust flow rates and PM emissions (uncon trolled) for paper machines 14 and 15 are approximately 270,000 acfm and 7.3 tons per year for each.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 102

Cost Effectiveness Calculations for Paper Machine Yankee Exhausts [1]
COST BASE DATE: June 1988 [2]
VAPCCI (Fourth Quarter 2003

-- FINAL): [3] 120.6

I NPUT PARAMETERS

-- Inlet stream flowrate (acfm): 270,000

-- Inlet stream temperature ( o F): 260

-- Inlet moisture content (molar, fraction): 0.075

-- Inlet absolute humidity (lb/lb b.d.a.): [4] 0.10

-- Inlet water flowrate (lb/min): 1,378.0

-- Saturat ion formula parameters: [5] Slope, B 3.335
Intercept,,A 9.41E

- 09

-- Saturation absolute humidity (lb/lb b.d.a.): 0.10

-- Saturation enthalpy temperature term ( o F):[6] 260.0

-- Saturation temperature ( o F): 127.9

-- Inlet dust loading (gr/dscf) (based on 7.3 tpy) 0.00071

-- Overall control efficiency (fractional): 0.99

-- Overall penetration (fractional): 0.01

-- Mass median particle diameter (microns): [7] 7.0

-- 84th % aerodynamic diameter (microns): [7] 3.4

-- Particle cut diameter (microns): [7 ] 0.44

-- Scrubber liquid solids content (lb/lb H 2 O): 0.25

-- Liquid/gas (L/G) ratio (gpm/1000 acfm): 5.0

-- Recirculation pump head (ft of water): 100

-- Material of construction (see list below):[8] 1

DESIGN PARAMETERS

-- Scrubber pressure drop (i n. w.c.): [9] 24.73

-- Inlet dry air flow rate (dscfm): [10] 183,843.8

-- Inlet (= outlet) air mass rate (lb/min): 13,780.0

-- Water recirculation rate (gpm): 1,350.0

-- Outlet water mass rate (lb/min): 1,378.0

-- Outlet total stream flow rate (acfm) : 236,791.0

-- Scrubber liquid bleed rate (gpm): 0.01

-- Scrubber evaporation rate (gpm): 0.00

-- Scrubber liquid makeup rate (gpm): 0.01

CAPITAL COSTS Equipment Costs ($):

-- Scrubber (base) 177,544

-- Scrubber (escalated) 244,179

-- Total 244,1 79 Purchased Equipment Cost ($): 288,131 Total Capital Investment ($): 550,331

ANNUAL COST INPUTS Operating factor (hr/yr): 8,760 Operating labor rate ($/hr): 24.60 Maintenance labor rate ($/hr): 27.06 Operating labor factor (hr/shift): 2

Maintenan ce labor factor (hr/shift): 1.5 Electricity price ($/kWhr): 0.034 Chemicals price (specify) ($/ton): 0 Process water price ($/1000 gal): 0.810 Wastewater treatment ($/1000 gal): 0.86PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 103

Cost Effectiveness Calculations for Paper Machine Yankee Exhausts [1]
Overhead rate (fractional): 0.60 Annual interest rate (fractional): 0.07 Control system life (years): 10 Capital recovery factor (system): 0.1424
Taxes, insurance, admin. factor: 0.01

ANNUAL COSTS

Item Cost ($/yr)
Operating labor 53,874 Supervisory labor 8,081

Maintenance labor 44,446

Maintenance materi als 44,446
Electricity

-- fan 315,242
Electricity

-- recirculation pump 11,620

Chemicals 0

Process water 4

Wastewater treatment 4

Overhead 90,508
Taxes, insurance, administrative 5,503 Capital recovery 78,355 Total Annual Cost ($/yr) 652,084

Cost Eff ectiveness ($/ton) 89,327 [1] Data used to develop this program were taken from 'Estimating Costs of Air Pollution Control' (CRC Press/Lewis Publishers, 1990). [2] Base equipment costs reflect this date. [3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for wet scrubbers) corresponding to year and quarter shown. Base equipment cost, purchased equipment cost, and total capital investment have been escalated to this date via the VAPCCI and control equipment vendor data.[4] Program calculates from the inlet moisture content. [4] Program calculates from the inlet moisture content. [5] By assumption, the saturation humidity (hs)

- temperature (ts) curve is a power function, of the form: hs = A*(ts)^B. [6] To obtain the saturation temperature, iterate on the saturation humidity. Continue iterating until the saturation temperature and the saturation enthalpy term are approximately equal. [7] Both the 'mass median' and '84th percentile aerodynamic' diameters are obtained from a log

- normal distribution of the inlet stream particle diameters. The particle cut diameter is a graphical function of the penetration, the mass median diameter, and the standard deviation of the particle size distribution. (For detailed guidance in determining these particle sizes, see "Wet Scrubbers: A Practical Handbook" by K.C. Schifftner and H.E. Hesketh(CRC Press/Lewis Publishers, 1986). A condensed procedure is given in "Estimating Costs of Air Pollution Control" by W.M. Vatavuk (CRC Press/Lewis Publishers, 1990).) [8] Ente r one of the following numbers: carbon steel

-- '1'; rubber

- lined carbon steel

-- '1.6';

epoxy

- coated carbon steel

-- '1.6'; fiber

- reinforced plastic (FRP)

-- '1.6'. [9] The scrubber pressure drop is extremely sensitive to the particle cut diameter. Hence, the user must determine the cut diameter with great care. [10] Measured at 70 degrees F and 1 atmosphere.

The estimated rate for a wet scrubber on the Yankee exhausts is over $89,000/ton, and is not cost effective. The cost analysis is conservatively low beca use it did not include any auxiliaries for tying the two Yankee exhausts ( e.g., separate wet and dry end stack for a single paper machine)

into a common duct.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 104

The analysis methodology was also to calculate the scrubber cost effectiveness for the following

additional cases.

1. PM11 or PM12 Yankee dryer exhausts

2. PM13 Yankee dryer exhaust

3. PM11, PM12, PM13, PM14, and PM15 roof vents

The f ollowing ta ble s ummarizes the c alculations us ing the s ame f ormulas a nd cost f actors presented in the immediately preceding ta ble.

Wet Scrubber Cost Effectiveness Calculations, Muskogee Mill Paper Machine Process Emissions

Yankee Roof Vents

INPUT PARAMETERS PM 11/12 PM13 PM11/12 PM13 PM14 PM15

-- Inlet stream flowrate (acfm): 145,000 54,000 965,000 453,000 395,000 445,400

-- Inlet stream temperature ( o F): 265 260 70 70 70 70

-- Inlet water flowrate (lb/min): 734.9 275.6 6,690.7 3,140.8 2,738.7 3,088.1

-- Saturation enthalpy

t t t 265.0 260.0 70.0 70.0 70.0 70.0

-- Inlet dust loading (gr/dscf) 0.00065 0.0 0075 0.00033 0.00035 0.00041 0.00034

DESIGN PARAMETERS

-- Scrubber pressure drop (in. ) 24.73 24.73 24.73 24.73 24.73 24.73

-- Inlet dry air flow rate (dscfm): 98,050.0 36,768.

8 892,625.0 419,025

0 365,375

0 411,995

-- Inlet (= outlet) air mass rate (lb/ i ) 7,349.3 2,756.0 66,906.5 31,407.

9 27,386.

6 30,881

-- Water recirculation rate (gpm): 725.0 270.0 4,825.0 2,265.0 1,975.0 2,227

-- Outlet water mass rate (lb/ i ) 734.9 275.6 6,690.7 3,140.8 2,738.7 3,088

-- Outlet total stream flow rate ( f) 126,288.5 47,358.

2 1,149,702 539,704

7 470,603

4 530,650

CAPITAL COSTS
Equipment Costs ($):

-- Scrubber (base) 121,358 66,304 430,914 271,264 249,446 268,469

-- Scrubber (escalated) 166,906 91,188 592,642 373,073 343,067 369,230

-- Other

- install ductwork 0 0 0 0 0 0

-- Total 166,906 91,188 592,642 373,073 343,067 369,230 Purchased Equipment Cost ($): 196,949 107,602 699,317 440,226 404,819 435,691 Total Capital Investment ($): 376,172 205,520 1,335,696 840,832 773,204 83 2,170

ANNUAL COSTS

Item Cost ($/yr)
Operating labor 53,874 53,874 53,874 53,874 53,874 53,874
Supervisory labor 8,081 8,081 8,081 8,081 8,081 8,081

Maintenance labor 44,446 44,446 44,446 44,446 44,446 44,446

Maintenance materials 44,446 44,446 44,446 44,446 44,446 44,446
Electricity

— fan 168,129 63,048 1,530,611 718,515 626,519 706,460
Electricity

-- recirculation pump 6,240 2,324 41,532 19,496 17,000 19,169

Chemicals 0 0 0 0 0 0

Process water 2 1 8 4 4 4

Wastewater treatment 2 1 9 4 5 4

Overhead 90,508 90,508 90,508 90,508 90,508 90,508

Taxes, insurance, administrative 3,762 2,055 13,357 8,408 7,732 8,322
Capital recovery 53,558 29,261 190,173 119,715 110,087 118,482 Total Annual Cost ($/yr) 473,049 338,046 2,017, 045 1,107,4

99 1,002,7

03 1,093,797 Cost Effectiveness ($/ton) 64,801 46,308 276,308 151,712 137,357 149,835PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 105

The calculations above indicate that it is not cost effective to consider any attempt to control PM emissions from the wet and dry ends with a w et scrubber.

Step 5

– Select BACT

VOC The only l istings for paper machines that can be considered similar to the Muskogee Mill Paper Machines are the No. 8 Paper M achine at G

- P’s C rossett, A rkansas M ill, P & G ’s f our pa per machines at its mill in Cape Gir ardeau, Missouri, and the Nos. 9 and 10 Paper Machines at G

- P’s Green Bay Mill. B ACT f or t he N o. 8 Paper M achine at G

- P’s C rossett, Arkansas Mi ll w as determined to be no control while BACT for P & G ’s M ill i n C ape G irardeau, M issouri w as

determined t o be a VOC limit of 2% of t he c hemical a dditives us ed a nd t he us e of l ow

- VOC content additives consistent with product quality and equipment operation. B ACT for the paper

machines at G

- P’s Green Bay Mill was 2.9 lbs/ADT for Paper Machine No. 10 and 2.7 lbs/ADT for Paper machine No. 9.

The M ill doe s not be lieve a s pecific V OC l imit on t he c hemical a dditives us ed on t he paper machines i s a ppropriate f or B ACT. T he pr imary r eason t hat t he M ill pr esents t his position is based on the fact that a specific VOC limit takes away the Mill’s flexibility for developing new

VOC -containing additives that although might have a higher VOC content, but have a lower usage

rat e, which could result in lower overall VOC emissions from the paper machine.

In lieu of agreeing to a sp ecific “lb/ton of product” VOC limit on the chemical additives that are used for the Muskogee paper machine as BACT, the Mill proposes the continued use of its New Substance R eview P rogram. The Mill will utilize a lower VOC

- containing chemical whenever

on e is available as a substitute for the chemicals being used, as long as the substitute chemical will not change or degrade product quality. In those instances where necessary, the Mill will run trial tests with the substitute chemical to ensure that produ ct quality is not changed or degraded before incorporating the use of the substitute chemical. This program will continue to be monitored and enforced by the Mill’s Environmental Department.

As stated earlier in this analysis, this program has shown to b e cost effective in reducing VOC emissions at the Mill without the use of expensive pollution control equipment.

Particulate Matter The available control technologies f or c ontrol a re not c ost e ffective. T he M ill pr oposes no

additional controls.

BACT FO R CONVERTING AREA

SOURCE DESCRIPTION The Converting Department takes parent rolls from each paper machine, cuts or slices the roll into smaller widths, then prints, perforates, and attaches each product stream to a core, finally cutting t he pa per t o th e pr oper l ength f or t he pr oduct be ing m anufactured. E ach pr oduct i s packaged and sent to warehouses for later shipment to both commercial and retail customers, or for di rect s hipment t o ot her G

- P c ustomers. T he pr oject w ill not m odify any converting areaPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 106

paper printer, and thus paper printing is not subject to BACT. The Converting Department also makes paper cores for use in the final packages by gluing a paper substrate together. Each of the rewinding/slitting ma chines ha s a tr im c ollection system tha t picks up w aste f rom t he cutting operation and directs the waste to a cyclone for product recovery. The recovered waste paper is sent back to the Pulp Processing Department where it is made into recycled pulp. The dust from the cyclone is discharged to a baghouse to control emissions before clean air is discharged to the atmosphere.

Glues, pastes, and solvent cleaners are used throughout the Converting Department as necessary. These materials emit small quantities of VOC through evaporation as they are u sed. No VOC controls are used in any of t he C onverting D epartment ope rations s ince t he a mount of V OC emitted at any individual workstation is not significant and does not warrant controls. The use of VOC in the converting area is also not being modified. Thus the BACT analysis below addresses only PM.

STEP 1

- Review of Vendor Data and Other Operations Within the Company To i dentify t he c urrent t echnologies i n us e t oday f or r educing P M/PM 10 and V OC e missions from Converting Department operations, inform ation was collected from vendor literature from the Internet or directly from vendors. Additionally, the analysis reviewed the technologies in use

at G

- P’s ot her C onverting D epartment ope rations. T he only recent BACT analyses for Converting D epartment op erations that have been prepared due t o a P SD pe rmit a pplication include one for the No. 9 P aper Machine and associated converting equipment for G

- P’s Paper Mill in Crossett, Arkansas in April 2001 and another for the No. 6 Paper Machine and associated

con verting equipment at G

- P’s Port Hudson, Louisiana Paper Mill in August 2001. The Crossett Mill No. 9 P aper Machine was never constructed. T he Port Hudson No. 6 P aper Machine and associated converting equipment were constructed and began operation in 2002. The converting equipment for the No. 6 Paper Machine project included the use of wet scrubbers for dust control from the trim line operations.

The technologies identified below include those that either are being used or could be used for the particula te matter emissions generated by the type of trim collection system in the Muskogee Mill’s Converting Department. This is the only operation within the Converting Department that generates a sufficient quantity of dust to warrant the use of pollution cont rols.

Cyclone Separators Cyclone separators are devices that utilize centrifugal forces and low pressure caused by spinning motion to separate m aterials of di fferent de nsity, size and shape. G as cy clones ar e us ed to separate pa rticulate m atter ( including lead) from dust

- laden air s treams. C yclones are popul ar because they are simple to operate, inexpensive to manufacture, require little maintenance, have no moving parts, and operate at high t emperatures a nd pr essures. T here a re t wo t ypes of

separators a vailable, tangential and axial. Both types operate on the same principle; however, in axial f low c yclones t he g as s tream e nters f rom t he t op of t he uni t a nd i s f orced to move tangentially by a grate in the top of the cyclone. In tangential cyclones the gas stream enters from an inlet on t he side that is positioned tangentially to the body of the unit. Multi

- stage cyclones can increase the amount of particulate matter that is removed by connecting a num ber of singlePERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 107

stage cyclones in series. T he f irst s tage of a m ulti

- stage cyclone r emoves t he l arger pa rticles while the remaining stages remove smaller particles. The collection efficiency of cyclones vary anywhere f rom 25

- 95%, de pending upon w hether t he s ystem i s c omprised of a single

- stage cyclone or a m ulti

- stage cyclone system.

Baghouses(see previous description of technology)

Wet Scrubbers(see previous description of technology)

Electrostatic Precipitators (ESP) ESPs us e el ectrical energy t o charge and collect particles with a very high removal effi ciency. The classification of ESPs may be as w et or dr y s ystems a nd/or s ingle

- stage or t wo

- stage systems. Dry systems are the predominant type used in industrial applications. Wet systems are gaining in use today since they eliminate the possibility of f ires, which can sometimes occur in dry systems.

Dry Electrostatic Precipitator (DESP) The principal components of a DESP include the housing, discharge and collection electrodes, power s ource, c leaning m echanism, a nd s olids ha ndling s ystems. The housing is ga s

- tight, weatherproof, and grounded for safety. D ust particles entering the housing are charged by ions from the discharge electrodes. Dust is collected on the collection electrodes, also referred to as plates. The system vol tage and the di stance b etween the di scharge and collection electrodes govern t he e lectric f ield s trength a nd t he a mount of c harge on t he pa rticles. D ESPs a re most effective at collecting coarse, larger particles above the 1.0 micron ( **μ** m) size. Particles smaller

than this are d ifficult to remove because they can inhibit the generation of the charging corona in the i nlet f ield and thereby r educe col lection efficiency. R appers s erve as t he cl eaning mechanisms for DESPs. Dust hoppers collect the precipitated particles from a D ESP . D ust is removed continuously or pe riodically f rom t he hoppe r a nd s tored i n a c ontainer unt il f inal disposition. Collection efficiencies for DESPs are usually at or above 98-99%.

Wet Electrostatic Precipitator (WESP)

An ESP is a collection device that uses electromotive forces to drive particles out of a gas stream onto collector plates. Electrodes in the center of the gas stream are maintained at a high voltage, which charge the particles. Wet ESPs operate a w et w all on the ba ck of an ESP w ith either continuous or intermittent water flow. The water flow is collected into a sump. The advantage

to a wet ESP is that it has no back coronas and reduced risk of fire. The collection efficiency for a wet ESP is similar to that of a dry ESP.

Review of EPA RACT/BACT/LAER Clearinghouse (RBLC) Searches of t he R BLC w ere c onducted t o i dentify c ontrol t echnologies f or t he c ontrol of

PM/PM 10 and VOC emissions from converting department equipment operations. Searches were conducted only for RBLC determinations add ed during or after January 1995. The specific EPA RBLC categories searched are listed below:PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 108

Process name contains “converting” or “printing” 30.002 Kraft Pulp Mills 30.004 Pulp & Paper Production Other than Kraft

The onl y e ntry i n t he R BLC i s G

- P Port Hudson, LA Mill (permit PSD

- LA

- 581 (M

- 2)). T he specified c ontrol i s a w et s crubber f or e ach c onverting area. While the determination in the RBLC does not specify a control efficiency, the permitted emission rate of 1.75 l bs PM/hr for

each stack is liste d.

Step 2 - Technical Feasibility Analysis The technically feasible controls are wet scrubbers and a baghouse.

Step 3

– Ranking t he T echnically F easible C ontrol A lternatives t o E stablish a Control Hierarchy The next step in the BACT analysis is to rank the various control options not eliminated in the previous step. The two control technologies are ranked as follows:

1. The top level of control is a baghouse rated at up to 99% removal

2. The next level of control is a wet scrubber rated at up to 98% removal

Step 4 – Control Effectiveness Evaluation The Mill currently operates a baghouse for this source that will not need modification to control potential dust emissions from the converting area following the completion of the construction project. The Mill se lects the top level of control. Thus, no additional effectiveness evaluation is

needed.

Step 5

– Select BACT The Mill proposes the top level of control, the existing baghouse, as BACT

BACT FOR POLYETHYLENE FILM FLEXOGRAPHIC PRINTERS

SOURCE DESCRI PTION The M ill i s pr oposing t o a dd t hree f lexographic pr inters t o i ts pol yethylene pl ant. T he three printers will operate in the same work area as the existing printer. T he plant produces rolls of polyethylene film and prepares them for printing logos. The proposed presses will unwind the unprinted rolls pr oduced a t t he M uskogee M ill or of fsite a nd t ransfer c olor i mages us ing t he flexographic process and solvent-based inks.

The e xisting pr inting ope rations us e a c atalytic ox idation uni t to control the e xisting pr ess. BACT is not applicable to the existing press as it w ill not be modified. However, the Mill is voluntarily designing the control system f or B ACT on t he ne w pr esses t o a ccommodate a nd control e missions f or t he e xisting pr ess a t a c ommon l eve l of control. T he e xisting c ontrol system will no l onger be used. A s the printing presses do not emit particulates, BACT for this source addresses only VOC.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 109

STEP 1 - Review of Vendor Data and Other Operations Within the Company VOC e missions f rom pol yethylene pr inting pr esses c ould be r outed t o a c atalytic or thermal oxidizer for destruction, or to a carbon adsorption system. T hermal oxidation offers up to 99% control, catalytic ox idation of fers up t o 95% c ontrol, a nd c arbon a dsorption of fers up t o 90%

control. G

- P cur rently ope rates t hree pr inting pr esses at i ts facility in Warwick, NY, using a thermal oxidizer to destroy VOC.

Review of EPA RACT/BACT/LAER Clearinghouse (RBLC) Searches of the RBLC were conducted to identify control technologies for VO C emissions from printing pr ess e quipment ope rations. S earches w ere c onducted onl y for RBLC determinations added during or after January 1995. The specific EPA RBLC categories searched are any whose

p rocess name contains the term “printing.” A large tab le in the application lists 16 companies using carbon adsorption, thermal oxidizers, catalytic oxidizers, low

- VOC or UV

- cured inks, and

various combinations of the first four. A brief explanation of these control technologies is listed

below.

Carbon Adsorption Carbon a dsorption r ecovers V OC

- containing gas streams by passing t he g as s tream t hrough a static “bed” of activated carbon. The VOC is retained in the pores of the carbon molecules while “clean” ai r i s di scharged to the at mosphere. T he be d of car bon must be r egenerated after it becomes saturated with VOC. Regeneration may involve the use of heat to release the adsorbed VOC so the “ bed” c an be r eused. T he V OC m ay be c ollected by c ondensation or t reated by another piece of control equipment, such a s an incinerator. There are usually a s eries of “beds” in use so that one or more beds are i n us e w hile t he ot her be ds a re be ing r egenerated. V OC removal efficiencies above 90% are achievable, de pending upon t he a bility of t he c arbon t o

adsorb the VOC.

Thermal Oxidizers Thermal ox idizers ( including r egenerative a nd r ecuperative) react volatile organic compounds with oxygen in the air to form carbon dioxide and water vapor as follows:

VOC + Oxygen + heat  H 2 O + CO 2

This r eaction oc curs w hen t he air is heated to a s ufficiently hi gh temperature, typically 1,400

- 1,600 o F. The fuel needed to heat the gas stream to the oxidation temperature is greatly reduced by the use of a “r ecuperator

, ” or preheater. The preheater will recover as much as 95% of the heat, thus providing significant fuel savings a s c ompared t o a s ystem t hat doe s not i ncorporate a preheater. These types of oxidizers can remove over 95% of VOC from a gas stream.

Regenerative thermal oxidizers ( RTOs) bui ld on t he pr inciple of t hermal oxidation, but w ith enhanced fuel ef ficiency. A n RTO cons ists of t wo or more heat exchangers connected by a common combustion zone. T he heat exchangers use beds of ceramic beads to store and release heat recovered from t he ox idation pr ocess. T he V OC

- la den air s tream ent ers t he f irst he at exchange be d where t he ai r s tream pa sses di rectly t hrough the ceramic medium and is then preheated before entering the combustion chamber. In the combustion chamber, a burner is usedPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 110

to supply any heat necessary to rea ch the optimum combustion temperature ( e.g ., usually 1,400 o F or higher) and complete the oxidation process.

The cleaned air stream next enters a s econd heat exchanger where it passes directly through the ceramic medium and is cooled while simultaneously heating the medium before the air stream is exhausted to the atmosphere. T he airflow through the heat exchange beds is reversed at regular

intervals to conserve the heat of combustion within the RTO. VOC destruction efficiencies can be 95% or higher with thermal efficiencies as high as 95%.

Catalytic Oxidation In contrast to recuperative thermal oxidizers, recuperative catalytic oxidizer (RCO) systems use a catalyst to encourage the oxidation reaction instead of depending on he at alone. R eactions in a

r ecuperative cat alytic ox idizer us ually t ake pl ace between 500 and 600 o F. T his cr eates t he opportunity to reduce fuel expenses and materials cost, since the materials of construction will be subjected t o m uch l ower t emperatures. T he a ddition of a preheate r can further reduce t he fuel costs. These types of oxidizers are capable of removing VOC from a gas stream with destruction efficiencies equal to 95% or higher.

UV cured or low-VOC containing inks The t echnology of us ing U V c ured or l ow

- VOC c ontaining i nks is strictly limited by s pecific product requirements.

Step 2 - Technical Feasibility Analysis Of the technologies identified, thermal oxidation, catalytic oxidation, and carbon adsorption are technically feasible and are de monstrated, while t he us e of UV

- cured or l ow

- VOC c ontaining inks may not be technically feasible due to the specific product requirements.

Step 3

– Ranking t he T echnically F easible C ontrol A lternatives t o E stablish a Control Hierarchy The following table r anks t he r emaining t echnolo gies by V OC de struction efficiency. T he control efficiencies in this table are actually only destruction efficiencies, as they do not account for VOC emission capture efficiency. The existing press control system captures approximately 70% of VOC emissions and destroys at least 85%, for an overall destruction of approximately

60% of total emissions.

Technology Control Efficiency

Thermal Oxidizer 95% + Catalytic Oxidizer 95% Carbon Adsorption 90%

Step 4 – Control Effectiveness Evaluation To yield the highest level of overall VOC control, the Mill proposes to design a permanent total enclosure to meet total capture efficiency for all four presses. The Mill has selected the top level of control, a regenerative thermal oxidizer to destroy the collected VOC. N o additional control effectiveness evaluation is necessary.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 111

Step 5

– Select BACT The Mill proposes a permanent total enclosure for all four presses collected into an RTO with a minimum destruction e fficiency of 95% . T he e nclosure w ill m eet t he de fi nition of “ total enclosure” specified in EPA Method 204.

BACT FOR POLYETHYLENE FILM EXTRUDERS

SOURCE DESCRIPTION

Step 1 - Review of Vendor Data and Other Operations Within the Company The C ompany ope rates pol yethylene f ilm e xtrusion a t t wo ot her f acilities. N either of the se facilities applies any control technologies to the film extrusion process.

Review of EPA RACT/BACT/LAER Clearinghouse (RBLC) The RBLC was s earched for “pol yethylene” and “extrusion” / “ extruder” i ndividually. T he clearinghous e does not contain any entries for a process similar to the Muskogee Mill extruders. For other types of extrusion of plastics, the RBLC listed no add-on controls.

Step 2 - Technical Feasibility Analysis Step 3

– Ranking the T echnically Feasible C ontrol A l ternatives to Establish a C ontrol Hierarchy Step 4 – Control Effectiveness Evaluation Step 5

– Select BACT Because Step 1 of t his B ACT a nalysis di d not i dentify a ny t echnically f easible c ontrol technologies, S teps 2, 3, a nd 4 a re satisfied vacuously, and t he M ill pr oposes “ No a dd -on controls” f or i ts pr oposed pol yethylene f ilm e xtruders. T he pr oposed e xtruders w ill e mit less than 300 lbs of VOC per year.

BACT FOR PLATEMAKING

SOURCE DESCRIPTION An additional part of the polyethylene plant that is being modified as part of the project is the plate making operation. The activity of plate making is related to the number of different logos or images that mus t be cast. T o accommodate additional presses, the M ill w ill add one plate

washer and one electric dr yer. The operation prepares plates to transfer a logo or other image to the polyethylene film on t he printers in addition to plates made for all paper printing. Once a plate is prepared, it is washed in an enclosed

- top washer prior to use on a printer. The emissions are the evaporation of solvents used in plate making and are limited to VOCs.

STEP 1 - Review of Vendor Data and Other Operations Within the Company The Company makes plates at m ost l ocations t hat pr int our pr oducts. N one of t he e xisting pl atemaking operations use add

- on control technologies. A solvent recovery unit is a standard work practice and integral part of the washer design. VOC emissions are avoided by chilling the solvent vapors when the washer is operating with the door closed.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 112

Review of EPA RACT/BACT/LAER Clearinghouse (RBLC) A search of the RBLC only returned one entry for plate making or pre

- press operations. Golden Books Publishing Co. (RBLC ID WI

- 0188) is a paper printing and book assembly facility. The entire facility is subject to Lowest Achievable Emission Rate rules (LAER) and not BACT. The control technology identified for this source (permit 97

- RV

- 019) is a set of work practices for the cold cleaning operation. T hese practices include equipping the cleaner with a c over, closing the cover whenever parts are not being handled in the cleaner, draining the cleaned parts for at least 15 seconds or until dripping ceases; and providing a permanent, conspicuous label summarizing the operating procedures and provide supervis ion or instruction adequate to ensure that the procedures

are followed. The permit is available at http://dnr.wi.gov/org/aw/air/permits/APM_toc.htm

. The Golden B ooks e quipment i s a c old

- cl eaning ba tch t echnology w ith a t op

- sitting lid over a washing chamber.

In contrast, the plate washer proposed for the Mill Improvement Project, and manufactured by Euroflex, is a new generation of washing technology that has all but eliminated exposure of the solvent to the work area air. The proposed washer has no hinged top or direct contact of operator with the solvent. T he plates are fed on a small conveyor belt and enter the cleaning chamber through a narrow slot under a slight negative pressure. T he plates emerge on the belt dry to the touch. The design of the in- line cleaner is inherently lower emitting than a batch cold cleaner.

Step 2 - Technical Feasibility Analysis Both t he w ork pr actice s tandard a nd t he in

- line c onveyor c leaning t echnology are t echnically feasible for the proposed Muskogee Mill plate washer.

Step 3

– Ranking t he T echnically F easible C ontrol A lternatives t o E stablish a Control Hierarchy The top ranked choice for control efficiency is the in- line conveyor cleaner.

Step 4 – Control Effectiveness Evaluation The Mill proposes to operate the top choice, so no additional control effectiveness evaluation is required.

Step 5

– Select BACT The M uskogee M ill pr oposes t o i nstall a ne w g eneration i n

- line pl ate w asher w ith inherently lower emission design by minimizing the contact of solvent with the work area air.

BACT FOR SYSTEM 5 PULPING

SOURCE DESCRIPTION The pulp processing and bleaching lines generate fugitive VOC emissions as a result of the use

of chemical additives and to a lesser extent; the wastepaper stock generates a smaller quantity of VOCs that are liberated during the pulp processing steps.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 113

S tep 1

- Review of Vendor Data and Other Operations Within the Company Bleaching in a recycle paper mill (sometime referred to as “deinking” mills) can be accomplished by using chemical agents, such as sodium hydrosulfite, hydrogen peroxide, or peracetic acid that do not contain chlorine or chlorine dioxide. The use of elemental chlorine as a bleaching agent,

which w as us ed i n the past for Kraft pulp and paper mills is no l onger allowed under the US

EPA’s “C luster R ules

, ” pr omulgated i n A pril 1999. Chlorine di oxide, a s ubstitute bl eaching agent for elemental chlorine, has become the main bleaching agent used in the Kraft pulp and paper i ndustry s ince t he C luster R ules be came ef fective. However, neither elemental chlorine nor chlorine dioxide is used in the recycle paper industry.

Most r ecycle pa per m ills i n t he U S t oday us e s odium hy pochlorite or other non -chlorine bleaching agents, such as those l isted a bove. F acilities t hat us e non -chlorine-containing bleaching agents are exempt from the stringent standards of the “Cluster Rules

. ” Use of these

non- chlorine bleaching agents will generate VOC and hazardous air pollutants (H APs). Based on a study performed by NCASI that was published in July 1997 for deinking processes, the most significant HAP at mills that utilize hypochlorite as a bleaching agent was chloroform. At mills that did not use hypochlorite, the chloroform emis sions were much smaller. Other HAPs present in significant concentrations were methanol, biphenyl, toluene, and acetaldehyde. A ll of these

HAPs are also considered VOCs.

Higher emissions of methanol, a cetaldehyde, a nd bi phenyl w ere obs erved dur ing t he s tudy a t mills t hat us ed pe roxide, w hile l ower e missions of c hloroform w ere obs erved. Peracetic aci d systems are believed to have similar VOC emissions of peroxide systems. System 5 and System 1 were specifically tested at the Muskogee Mill. System 5 was tested using peroxide bleaching.

G- P operates five recycle pulp mills i n the United States. The bl eaching agents us ed at t hese

mills are listed below.

Savannah River M ill B leaching S ystems

Nos. 1

- 3 Hypochlorite, hydrosulfite

Savannah River M ill B leach ing S ystem

No. 4 Hypochlorite, peroxide, hy drosulfite,

oxygen Green Bay Broadway Mill Hypochlorite, peroxide, hy drosulfite,

oxygen Green Bay Day Street Mill Hypochlorite Halsey Mill Peroxide and hydrosulfite

G- P is not aware of any type of pollution controls used in recycle pulp bleach plants except for

the Chlor

- Alkali plants that are used to manufacture the hypochlorite solution. T he Muskogee Mill us es hy pochlorite s olution on S ystem 1, but doe s not currently operate its Chlor

- Alkali plant.

Review of EPA RACT/BACT/LAER Clearinghouse (RBLC) Searches of the RBLC were conducted to identify control technologies for the control of VOC emissions from bleaching processes. S earches were conducted for RBLC determinations addedPERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 114

before a nd a fter J anuary 1994 to de termine w hat t echnologies a re i n us e t o c ontrol V OC emissions from recycle mill bleach plants. The RLBC database was searched for process names containing the terms “ bleach”, “ hypochlorite”, “ hydrosulfite”, “ de

- inking”, “ peroxide”, “ chlor

alkali”, an d “recycle pulp” to see which entries were listed for the addition of or the modification of a bleach plant. The specific EPA RBLC categories searched are listed below.

30.002 Kraft Pulp Mills 30.004 Pulp & Paper Production Other than Kraft

The only f acility that matched any of these terms for a recycle pulp mill (and not a Kraft mill) was for the Consolidated Paper Company’s Mill l ocated i n S tevens P oint, W isconsin. T he BACT e ntry l isted w as f or a m odification of t he hydrogen pe roxide pul p bleaching system in 1999. B ACT for the modification was “no control” with a methanol limit of 4.1 tons per year. There were no BACT entries for recycle paper mills found before this date.

Conventional VOC removal technologies for other types of VOC sources include Recuperative/ Regenerative/ C atalytic/ T hermal O xidation, C arbon A dsorption, a nd Biofiltration. However, these technologies have never been demonstrated on a pul p m ill s ystem f or BACT or f or a ny other purpose.

Step 2 - Technical Feasibility Analysis

Ble aching chemical agents The use of hypochlorite solutions ( e.g., calcium hypochlorite and sodium hypochlorite) and the

use of non -chlorine- containing chemical agents, such as sodium hydrosulfite, thiourea dioxide, hydrogen peroxide, or peracetic acid are te chnically feasible as the Mill currently operates at least one of its pulping systems with these chemicals. System 5 has utilized sodium hydrosulfite and peroxide s ystems i n t he pa st. S ystem 5 ha s not used sodium/calcium hypochlorite to date for production.

As g rades cha nge, the M ill ne eds t o adapt i ts che mical pa ckage. S pecifically, as wastepaper quality deteriorates, the Mill needs the f lexibility to switch its chemical package on System 5 between sodium hypochlorite a nd ot her C luster R ule

- exempt ma terials ( e.g., peroxide). T he proposed modification at the pulp mill is intended to improve the yield from increasingly lower grades of wastepaper. T he w astepaper c urrently pr ocessed i s not bl eached w ith s odium hypochlorite.

Add -on oxidation/incineration The us e of r ecuperative/ r egenerative/ c atalytic/ t hermal ox idation, carbon adsorption, or biofiltration techniques have not been demonstrated and they are not technically feasible for at least the following two reasons.

1) The presence of poisoning halides attack the oxidizer components and conventional media 2) The heat value and concentration of V OC i n t he e xhausts m easured dur ing t he N CASI stack t esting i s ve ry l ow a nd c annot s ustain a n ox idation r eaction without continuous natural gas combustion that can generate significant amounts of NO X

.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 115

Biofiltration Mr. Karl Mundorff of Bioreaction Company, a biofilter vendor, expressed serious doubt about this application of biofilters. C hloroform will either inhibit or poison the biological population

of a biof ilter. Since chloroform comprises a significant amount of the total VOC emitted from the Bleach Plants, most of the biofilter media would be rendered useless for emissions control. Additionally, ba sed on t he a pproximate c omposition of ot her H AP c ompounds listed in the NCASI study, and information supplied by Bioreaction, only 80% of the remaining HAPs could be r emoved by bi ofiltration t echnology, l eaving t he ot her 20% una bated. T herefore, i t i s technically infeasible to use biofiltration to remove VOC.

S tep 3

– Ranking t he T echnically F easible C ontrol A lternatives t o E stablish a Control Hierarchy The t op l evel of c ontrol i s us e of va rious non -chlorine- containing che mical ag ents, such as sodium hy drosulfite, hy drogen pe roxide, pe racetic a cid, or sodium hyp ochlorite to minimize

methanol formation.

Step 4 – Control Effectiveness Evaluation The M uskogee M ill S ystem 5 i s a ble t o us e hy pochlorite s olutions a nd other non -chlorine chemical agents. As this technology is the top choice, there is no additional cont rol effectiveness

evaluation.

Step 5

– Select BACT The Muskogee Mill proposes no additional control for System 5. The existing technology is the

most effective choice.

BACT SUMMARY

The following table summarizes proposed BACT for each of the modified sources.

Source Pollutant Existing Controls Proposed BACT Emission Rate Paper Machine Combustion (a) Paper Machine 11

- 14 SO 2 Clean Fuel No Additional Controls 0.2 tpy each Paper Machine 11

- 14 NOx Conventional Burners Low NOx Burners 0.04 lb/MM BTU Paper Machine 11

- 14 PM/PM 10 Clean Fuel No Additional Controls 2.3 tpy each Paper Machine 11

- 14 CO Conventional Burners Low NOx Burners 0.184 lb/MMBTU Paper Machine 11

- 14 VOC Good Combustion Practices No Additional Controls 1.7 tpy each Paper Mac hine Process Paper Machine 11 PM/PM 10 None No Additional Controls 9.3 tpy (b) Paper Machine 12 PM/PM 10 None No Additional Controls 13.0 tpy (b) Paper Machine 13 PM/PM 10 None No Additional Controls 11.2 tpy (b) Paper Machine 14 PM/PM 10 None No Additi onal Controls 11.2 tpy (b) Paper Machine 15 PM/PM 10 None No Additional Controls 10.3 tpy (b) Paper Machine Additives (PM11

- 15) VOC None New Substance Review 202 tpy
combined Converting Area Vent PM/PM 10 Baghouse No Additional Controls 0.032 tpy (b)

3 New Printing Presses VOC NA

- Proposed Source Permanent Enclosure, RTO 48.5 tpy (c)

3 New Extruders VOC NA

- Proposed Source No Additional Controls 0.14 tpy New Plate Washer/Making(d) VOC NA

- Proposed Source Washer Inherent Design 1.4 tpy

Pulping System 5 VOC No use of chlorine or chlorine dioxide (e) No Additional Controls 46.2 tpy (c)PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 116

(a) BACT levels for the burners are applicable only if the physical modification includes replacing the existing burner. (b) No change from existing permit limit/maxi mum emissions. (c) The emission rate reflects the proposed control on all four presses combined – the proposed presses and one existing press not undergoing modification (d) This source does not include emissions from the existing platemaking operations. ( e) This is equivalent to one of the requirements of MACT under 40 CFR 64 Subpart S

( This ends the quotation from the application )

Based on the immediately preceding table and upon t he di scussions f rom w hich t he t able i s derived, the only emissions that re quire testing will be NO X and CO emissions from the paper machines’ ne w bur ner c onfigurations a nd V OC f rom t he pol yethylene pr inting a rea. These emissions will be addressed in the Specific Conditions of the permit.

NSPS, 40 CFR Part 60 [No Change Due to This Project] Subparts D, Da, Db, and Dc These standards affect steam generating units of particular sizes and dates of construction, reconstruction, and modification. A s explained in detail in memorandum associated w ith t he pe nding P art 70 pe rmit, a ll f our boilers ar e af fected facilities unde r onl y Subpart D. T he standards and requirements identified in that memorandum are unchanged by this project.

Subpart Y This standard applies to affected facilities in coal preparation plants that process more

tha n 181 Mg (200 tons) per day and that commenced construction or modification after October 24, 1974. The current project does not alter any of the discussion found in the memorandum associated w ith t he pe nding P art 70 pe rmit, a nd t he standards and conditio ns of tha t pe rmit remain unchanged.

NESHAP, 40 CFR Part 61 [ No Change Due to This Project ] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke ove n e missions, m ercury, r adionuclides, or vi nyl c hloride e xcept f or s mall a mounts of mercury f rom t he boi lers w hich a re c overed by N SPS S ubpart D a nd w ill become subject to NESHAP Subpart DDDDD. Subpart M

– The facility may be subject to certain regulations pe rtaining to the c onstruction, demolition, and disposal of asbestos- containing materials.

NESHAP, 40 CFR Part 63 [Only Subpart KK Affected by This Project ] Subpart S (Pulp a nd P aper I ndustry) The memorandum a ssociated w ith t he pe nding P art 70 permit s hows t hat, a lthough F t. J ames i s a n affected facility under Subpart S , there ar e no standards that apply to the equipment or processes. T he current project will no t add any units or processes that will alter that status. Subpart KK (Printing and Publishing Industry) The memorandum associated with the pending

Par t 70 permit shows that the flexographic printing presses at the facility are affected sources.

Th at memorandum describes the standards and requirements that apply. The current project adds three new polyethylene printers, but none of the standards is chan ged by this increase in machine count. The following lists the affected sources:PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 117

EU

ID EU Name Manufacturer/Model No. Const.

Date

PO -1 Polyethylene Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer 6/84

Polyethylene Printer 2 Make/model N/A, but similar to that listed above. 2005 Polyethylene Printer 3 Polyethylene Printer 4

FP -1 Paper Printers (six) Flexo 21

- 182

– PCMC/ Model No. 6724

Flexo 31-001 – Fort Howard

Flexo 31-002 – Fort Howard

Flexo 31-003 – Fort Howard

Flexo 31-005 – PCMC/Model No. 6992

Flexo 31

- 008

– PCMC/Model No. 7416 1983

1980

1980

1980

1990

1993

FP

- 7 Paper Printer Flexo #7

– PCMC/Model No. 6726 1997

FP

- 8 Paper Printer Flexo #8

– Bretting 4

- color 78 **′′** wide 6/05

Subpart DDDDD (Industrial, Commercial, and Institutional Boilers and Process Heaters) affects all existing, new, or reconstructed industrial boilers, institutional and commercial boilers, and process heaters located at a major source of HAPs. Requirem ents are discussed in the memorandum associated with the pending Part 70 permit. According to that analysis, all four boilers will be subject to the subpart, with a compliance demonstration date of September 13,
2007, and the current project will cause no change in the conditions established.

CAM, 40 CFR Part 64 [Not Applicable to Current Project] The memorandum associated with the pending P art 70 pe rmit s hows t hat t he boi lers a t t he facility are affected sources. While the boilers have potential pre

- con trol emissions greater than or equal to major source levels (100 TPY of a regulated pollutant or 10/25 TPY of a HAP), they are not large emissions units since post -control emissions do not equal or exceed 100 TPY. They will be subject to CAM upon renewal of the Title V permit. The boilers will have to demonstrate compliance with MACT DDDDD before the operating permit is renewed, which may obviate theneed for CAM. Similarly, the addition of three printers will lead to an estimated 971 TPY of precontroll ed V OC e missions f rom t he g roup of f our pr inters, but onl y 49 TPY of controlled emissions, making them “other” sources under CAM, thus requiring that they satisfy CAM at the

time of Title V renewal.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] The emissions units subject to this determination do not process or store more than the threshold quantity of a ny r egulated s ubstance ( Section 112r of t he C lean A ir A ct 1990 Amendments). More information on this federal program is availab le on the web page: www.epa.gov/ceppo

.

Stratospheric Ozone Protection, 40 CFR Part 82 [ No Change Due to This Project ] This Part sets standards for Class I & I I s ubstances. T he c urrent pr oject w ill not c ause a ny change in applicability of Part 82.PERMIT MEMORANDUM 99 -113- C (PSD)(M -4) 118

SECTION IX. COMPLIANCE

Testing Testing of the boilers for initial compliance with 40 CFR 60 Subpart D was performed for each

fuel fired. Additional testing in anticipation of 40 CFR 60 Subpart DDDDD, National Em ission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process H eaters, was conduc ted on J anuary 7

- 9, A pril 15

- 16, and May 1 6

- 17 & 20

- 21, 2003. Details of this testing are contained in the discussion of emis sions in th e memorandum associated with the Part 70 permit

.

Inspection The facility is subject to unscheduled inspections by DEQ Enforcement/Compliance personnel and has been vi sited by D avid P ollard, permit w riter f or t he pe nding P art 70 pe rmit. N o inspection is required for this construction permit.

Tier Classification and Public Review This application has been classified as Tier I II based on the request for a construction permit for a potentially s ignificant s ource a t a ma jor s tationary source. The applicant ha s s ubmitted a n affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the land.

The applicant publ ished a “ Notice of F i ling a T ier I I A pplication” in the Muskogee Daily

Phoenix , a daily newspaper in the City of Muskogee, Muskogee County, on October 12, 2005. The notice stated that the application was available for public review at the Muskogee County Health Department, 530 S. 34 th St., Muskogee, Oklahoma. It also gave the address of the DEQ Air Quality Division office in Oklahoma City. Notice of the availability of the Draft permit was also published in the Muskogee Daily Phoenix on January 31, 2006. A copy of the draft permit was m ade ava ilable at t he M uskogee C ounty H ealth Department, at DEQ’s Oklahoma City office, and on the DEQ website. The same draft copy was made available to EPA Region 6 for concurrent r eview, w hich c ommenced F ebruary 1, 2006. T he 30

- day public c omment pe riod expired March 2, 2006, and the 45-day period for Region 6 review expired March 18, 2006.

This facility is not located within 50 miles of the border of Oklahoma and any other state. N o comments were received from the public. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page at http://www.deq.state.ok.us

.

Fee Paid Significant modification construction permit for a Title V source f ee of $1,500.

SECTION X. SUMMARY

There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance of the construction permit is recommended.

# PART 70 PERMIT

AIR QUALITY DIVISION

STATE O F OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA 73101 -1677



## Permit Number: 99

- 113 -C (M -4) (PSD)

FORT JAMES OPERATING COMPANY,

having complied w ith t he r equirements of t he l aw, is hereby granted p ermission t o

construct t he Mi ll P rocess I mprovement P roject at t he Mu skogee P aper Mill located at

4901 C handler R oad, M uskogee, O klahoma, M uskogee C ounty, h aving t he legal

description of Section 33 & W/2 Section 34, T15N, R19E

subject to the following conditions, attached:

[X] Standard Conditions dated July 1, 2005

[X] Specific Conditions

This p ermit s hall exp ire 18 months f rom March 27, 2006 , except as A uthorized u nder

Section VIII of the Standard Conditions.

_________________________ Chief Engineer , Air Quality Division DatePERMIT TO CONSTRUCT

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Fort James Operating Company Permit No. 99-113- C (M -4) (PSD) Muskogee Mill Mill Process Improvement Project

The permittee is authoriz ed to construct in conformity with the specifications submitted to the Air Quality Division on October 6, 2005. T he Evaluation Memorandum dated June 12 , 2006

, explains the de rivation of a pplicable pe rmit r equirements a nd the estimates of emissions,

howeve r, it doe s not c ontain operating limita tions or pe rmit r equirements. C ommencing construction or continuing operations under this permit constitutes acceptance of, and consent to,
the conditions contained herein.

The following conditions are numbered acco rding to the format established in the pending Part 70 permit. T he phrase “No Changes” appears in each condition or subcondition for which the requirements of this construction permit match those established in the Part 70 permit.

1. Points of emission and emissions limitations. [OAC 252:100-8- 6(a)(1)]

Where two emission limits w ith different ba ses a re g iven for a s ingle e mission point a nd pollutant, the source shall not exceed either limit at any time.

EUG 1

– Subpart D Boilers

A. No changes

B. No cha nges C. No changes

D. Total S O X emissions f rom B oilers B

- 1, B

- 2, B

- 3, and B

- 4 s hall not e xceed 36,4 60 pounds pe r da y. Emissions shall be calculated based on a ctual f uel c onsumption a nd emissions factors identified in development of the Part 70 Permit for the facility, as indicated in the following table, or shall be taken from continuous emission monitors.

Unit Fuel type Emission factor

B

- 1, B

- 2, B

- 3, B

- 4 Natural gas 0.6 lbs/MMSCF*

B

- 2 High BTU coal 0.644 lbs/MMBTU**

B

- 2 Low BTU coal 0.267 lbs/MMBTU**

B

- 3 Coal 0.403 lbs/MMBTU**

B-4 Coal 0.631 lbs/MMBTU** *Assumes 1,020 BTU/CF **Based on the heating value of the coal used.

E UG 2

– Combustion Sources Not Subject to NSPS or NESHAP

EU ID Manufacturer & Serial

Number Burners (MMBTUH) Fuels EU

Construct Burner ReplaceSPECIFIC CONDITIONS NO. 99 -113- C (M -4) (PSD) 2

PM

- 11 Kinedizer 27M * 2

- 35 ( 70 ) * Gas/Propane 1975 2006

PM

- 12 Oven

- Pak EB6 Model 400* 2

- 35 (70)* Gas/Propane 1975 2006

PM

- 13 Oven

- Pak EB6 Model 400* 2

- 35 (70)* Gas/Propane 1979 2006

PM

- 14 Combustifume* 2

- 35 (70)* Gas/Propane 1981 2 006

PM

- 15 LV

- 85 2

- 25 (50) Gas 1992 1992

PO

- 1 Oven

- Pak EB3 * 4

– 3.2 (12.8) Gas 1984 2006

PO

- 1 RTO* 10.4 * Gas 2006 NA Power Output

DG

- 1 Marathon Electric, Magna One, Model# 683 1,200 KW Diesel 1982 NA

DG

- 2 Marathon Electric, Magna One, Model# 6 83 1,200 KW Diesel 1982 NA

* Some design elements have not been fully determined. H eat ratings for each are the maximum that m ay oc cur. M anufacturer a nd m odel i nformation w ill be provided with the application for modified operating permit.

Authorized Burner Combustion Emissions Summary

– TPY 1

SO PM 2 VOC 10 NO CO X PM

- 11 0.22 2.80 11.0 2.02 56.4

PM

- 12 0.22 2.80 11.0 2.02 56.4

PM

- 13 0.22 2.80 11.0 2.02 56.4

PM

- 14 0.22 2.80 11.0 2.02 56.4

PM

- 15 0.16 2.00 1.45 32.9 96.4

PO

- 1 2 0.03 0.35 0.25 4.56 3.83

1. NO X and CO emission factors for PM

- 11, 12, 13, and 14 reflect BACT

values of 0.036 l b/MMBTU f or N O X

2. This r eflects onl y t he R TO, s ince t he t unnel dr yers are Insignificant activities. Depending upon f inal de sign c riteria, t he R TO m ay a lso be Insignificant. and 0.184 l b/MMBTU f or C O.

Limits f or P M

- 11, 12, 13, a nd/or 14 be come e ffective only after completion of all construction and related modifications fo r each.

All Paper Machines

– OAC 252:100

- 25, 31, & 33 Standards Opacity SO 2 (lbs/MMBTU) NO X (l bs/MMBTU)

Natural Gas 20/60 0.20 0.20

EUG 3 – Subpart Y Coal Preparation Plant No change.

EUG 4

– PP

- 1 Pulp Processing Units (Subpart S Affected/No Applicable Standards) No change, although modifications to covered equipment shall be documented per Sp ecific

Condition #7 of Permit No. 99-113- TV

.SPECIFIC CONDITIONS NO. 99 -113- C (M -4) (PSD) 3

EUG 5 – 40 CFR 63 Subpart KK Flexographic Printing

EU

ID EU Name Manufacturer/Model No. Const.

Date

PO -1 Polyethylene Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6

- color w/ vapor collecti on hood and tunnel dryer 6/84

Polyethylene Printer 2 Make/model N/A, but similar to that listed above. 2006 Polyethylene Printer 3 Polyethylene Printer 4

FP -1 Paper Printers (six) Flexo 21

- 182

– PCMC/ Model No. 6724

Flexo 31-001 – Fort Howard

Fl exo 31-002 – Fort Howard

Flexo 31-003 – Fort Howard

Flexo 31-005 – PCMC/Model No. 6992

Flexo 31

- 008

– PCMC/Model No. 7416 1983

1980

1980

1980

1990

1993

FP

- 7 Paper Printer Flexo #7

– PCMC/Model No. 6726 1997

FP -8 Paper Printer Flexo #8

– Bretting 4

- color 78 **′′** wide 6/05

G. All presses, Subpart KK Flexographic Printing

. [40 CFR 63 Subpart KK] No change.

EUG 6

– VOC So urces Not Subject to a n NSPS or NESHAP

EU ID EU Name Manufacturer/Model/Serial # Const. Date

PP

- 1 Pulp Processing Units Components listed in EUG 4 1977

- 1992

PM

- 11 Paper Machine #11 KMW 1975

PM

- 12 Paper Machine #12 KMW 1975

PM

- 13 Paper Machine #13 KMW 1979

PM

- 14 Paper Machine #14 Beloit 1981

PM

- 15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA

SC

- 1 Solvent Cleaning of PM

- 11,

PM

- 12, PM

- 13, and PM

- 14 NA 1975

PM

- 15 Solvent Cleaning NA 1992

PO

- 1 Flexo

- plate making Anderson

- Vreeland June, 1984 Flexographic Polyethylene

Printer Paper Converting Machine Company (PCMC), Model No. 6795, 6-color, w/ vapor collection hood and tunnel dryer June, 1984

Polyethylene Printers (3) Similar to above (proposed) 2005

FP

- 1 Flexographic Paper Printers (six) Flexo 21

- 182

– PCMC/ Model No. 6724

Flexo 31-001 – Fort Howard

Flexo 31-002 – Fort Howard

Flexo 31-003 – Fort Howard

Flexo 31-005 – PCMC/ Model No. 6992

Flexo 31-008 – PCMC/Model No. 7416 1983

1980

1980

1980

1990

1993

FP

- 7 Flexographic Paper Printer Flexo #7

– PCMC/Model No. 6726 1997

FP

- 8 Flexographic Paper Printer Bretting 4

- color, 7 8” wide 6/05SPECIFIC CONDITIONS NO. 99 -113- C (M -4) (PSD) 4

H. Paper Machine Additives and Solvent Cleaning of PM

- 11 through PM

- 15

. i. Emissions from Paper Machine Additives are emissions from VOC

- containing paper

enhancement che micals including dy es, softness aids, and bi ocides. E missions of VOCs from the use of paper machine additives shall not excee d 202 TPY, 12

- month rolling cumulative.

ii. Emissions of VOCs from solvent cleaning of Paper Machines PM-11, PM-12, PM-13,

PM -14, and PM-15 shall not exceed 787 TPY, 12

- month rolling cumulative.

iii. Emissions shall be calculated ba sed on t he t otal V OC c on tent of each ad ditive or

cleaner material used

.

I. Eliminated

J. No changes.

K. Eliminated

L. P aper p rinters FP -1

, FP -7 , and FP -8 . T otal e missions of V OCs f rom t he se printe rs is

limited to 92.28 T PY, r olling 12

- month c umulative. Emissions c alculation s s hall be based on mass balance, considering the VOC content of the inks.

M. Polyethylene printers (4) PO -1

. i. Total V OC e missions from this g roup of pr inters shall not ex ceed a cum ulative of

48.5 tons pe r y ear ba sed on a 12

- month r olling c umulative pe riod. This limit becomes effective only after all construction and related modifications are complete.

ii. The printers shall be contained in a 100% enclosure , as specified by EPA Reference Method 204, that routes all emissions to a r egenerative the rmal o xidizer w ith a minimum 95% destruction efficiency.

N. No changes.

O. Additional limita tions f or Platemaking. Despite the a ddition of i nline w ashers, t his process i s ex pected to emit l ess t han 5 TPY of VOC and is a n Insignificant A ctivity.

Records s uffi cient to demonstrate thi s s tatus s hall be maintained. T his r equirement becomes effective after the completion of all construction and related modifications.

EUG 7

– Non

- Combustion PM Sources Not Subject to NSPS or NESHAP No changes

.

2. Initial Testing r equirements. [OAC 252:100-8-6(a)(1)], [OAC 252:100-43]

A. Boilers B -1, B-2, B-3, and B-4. [40 CFR 60 Subpart D] No changes

B. Additional requirements for Boiler B -4. [40 CFR 60 Subpart D], [Permit No. PSD

- OK -404] No changes.SPECIFIC CONDITIONS NO. 99 -113- C (M -4) (PSD) 5

C. Additional requirem ents for Boiler B -4. [General Conditions, Permit No. PSD- OK -404] No changes.

D. The low- NO X burners to be installed on paper machines PM-11, PM-12, PM-13, and PM14 shall be pe rformance t ested at 90% or m ore of r ated he at i nput to de monstrate compliance with the BACT limits of 0.036 lb s /MMBTU for NO X and 0.184 lb s /MMBTU for CO. Testing shall occur within 60 days of initial operation of each burner. A protocol describing the test design and Reference Methods to be used shall be supplied to the DEQ Region al Office at Tulsa at least 30 days before the tests are scheduled to be performed. Testing is not required for any of the other pollutants reviewed in the BACT analysis. [OAC 252:100-43]

E. Performance t esting t o de monstrate t he 95% ove rall de structive efficiency of t he regenerative thermal oxidizer shall be performed within 60 da ys of first operation of the new enclosure and polyethylene printers, with all four printers operating at representative

rates

. A protocol describing the test design

, Referenc e Methods to be used, presentation of r esults, a nd monitoring parameters measured that w ill de monstrate cont inued compliance, shall be supplied to the DEQ Regional Office at Tulsa at least 30 days before the test is scheduled to be performed. [OAC 252:100-43]

3. Monitoring Requirements. [OAC 252:100-43], [OAC 252:100-4], [40 CFR 60 Subpart D]

A. No changes

. B. No changes.

C. No changes

. D. PO -1 Flexographic Printing Press Tunnel Dryers and Regenerative Thermal Oxidizer

. i. The t unnel dr yer s and catalytic oxidation incinerator shall be f ueled onl y w ith commercial pipeline

- grade natural gas.

ii. Monitoring pa rameter i nformation necessary to assure that design efficiency of t he regenerative t hermal ox idizer ( RTO) is m aintained s hall be pr ovided w ith t he appli cation f or a m odified ope rating pe rmit s o t hat a ppropriate specific conditions may be applied.

E. No changes

. F. No changes.

G. No changes.

H. No changes.

I. No changes.

J. No changes.

K. No changes.

L. No changes.

4. Hours of Operation. [OAC 252:100-8-6( a)(1)] No changes.SPECIFIC CONDITIONS NO. 99 -113- C (M -4) (PSD) 6

5. Emission Controls. [OAC 252:100-8-6(a)(1)], [OAC 252:100-37]

A. All boilers, B-1, B-2, B-3, and B-4. No changes

. B. Boilers B -2

, B-3 , and B-4

. No changes

. C. Paper Machine s PM -11, 12, 13, 14.

BACT shall consist of the use of low-NO X burners and natural gas for the primary fuel

and t he us e of propane as s econdary f uel. A ll ot her pol lutants shall be minimized by proper operation of the unit. This requirement becomes effective for each paper machine only after completion of all construction and related modifications for each.

6. Reporting Requirements. [OAC 252:100-8-6(a)(3)(B)], [OAC 252:100-43] No changes.

7. No changes

.

8. Recordkeeping. [OAC 252:100-8- 6(a)(3)(B)]

A. No changes.

B. No changes.

C. No changes.

D. No changes.

E. No changes.

F. No changes.

G. Sufficient records to demonstrate the calculations of VOC emissions from the group of paper pr inters ( currently 8) , t he g roup of pol yethylene pr inters (currently 4), and the solvent c leaning of pa per m achines ( currently 5) . These r ecords t ypically i nclude t he

basis of a mass

- balance analysis; gallons and/or pounds of product used, VOC content of each gallon and/or pound, any associated capture or destruction efficiency, and any other appropriate information.

H. No changes.

I. No changes.

9. Insignificant Activities. [OAC 252:100-8- 6 (a)(3)(B)] No changes.

10. Permit Shield [OAC 252:100-8- 6(d)(2)] No changes.

11. Compliance certification. [OAC 252:100-8- 6(c)(5)(A), (C) & (D)] No changes.

12. No changes.

## TITLE V (PA RT 70) PERMIT TO OPERATE / CONSTRUCT

STANDARD CONDITIONS
(July 1, 2005)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et s eq.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [ Oklahoma Clean Air Act , 27A O.S. § 2-5-112]

B. The is suing A uthority f or the pe rmit is the A ir Q uality D ivision (AQD) of the O klahoma Department of E nvironm ental Quality (DEQ). T he pe rmit doe s not r elieve t he hol der of t he obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

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

C. The permittee s hall comply with all conditions of this permit. A ny permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial o f an application to renew this permit. All terms and conditions (excluding state

- only requirements) are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act. This permit is valid for operations only at the specific location listed. [40 CFR §70.6(b), OAC 252:100-8-1.3 and 8- 6 (a)(7)(A) and (b)(1)]

D. It shall not be a de fense f or a pe rmittee i n a n e nforcement a ction t hat i t w ould ha ve be en necessary to halt or reduce the pe rmitted activity in order to maintain compliance w ith the conditions of the permit. [OAC 252:100-8- 6 (a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any e xceedance r esulting f rom e mergency c onditions a nd/or posing an imminent and substantial danger t o publ ic he alth, s afety, or t he e nvironment s hall be r eported i n a ccordance

with Section XIV. [OAC 252:100-8- 6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. [OAC 252:100-8- 6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the ow ner ope rator s hall s ubmit a w ritten report describing the extent of the excess emissions and response a ctions taken by the facility. E very written report submitted under OAC 252:100 -8- 6 (a)(3)(C)(iii) shall be certified by a responsible

official. [OAC 252:100-8- 6 (a)(3)(C)(iii)]TITLE V STANDARD CONDITIONS July 1, 2005 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The pe rmittee s hall ke ep records a s s pecified in this permit. Unless a different retention period or r etention c onditions a re s et f orth by a specific term in this permit, these records, including m onitoring da ta a nd ne cessary s upport i nformation, shall be retai ned on

- site or at a nearby f ield of fice f or a pe riod of a t l east f ive years f rom t he da te of t he m onitoring s ample, measurement, report, or application, a nd s hall be m ade a vailable f or i nspection by r egulatory personnel upon r equest. S upport information i ncludes a ll or iginal s trip

- chart re cordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, t he permit may specify that records may be maintained in computerized form. [OAC 252:100-8- 6 (a) (3)(B)(ii), 8 -6 (c)(1), and 8- 6 (c)(2)(B)]

B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions as existing at the time of sampling or measurement. [OAC 252:100-8- 6 (a)(3)(B)(i)]

C. No later than 30 da ys after each six (6) month period, after the date of the iss uance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required m onitoring. A ll i nstances of de viations f rom pe rmit requirements since the previous report shall be clearly identified in the report. [OAC 252:100-8- 6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions. [OAC 252:100-8- 6 (a)(3)(C)(i ii)]

E. In a ddition t o a ny m onitoring, r ecordkeeping or r eporting r equirement s pecified i n this permit, monitoring and reporting may be r equired unde r t he pr ovisions of O AC 252: 100 -43, Testing, Monitoring, and Recordkeeping, or as required by any provisio n of the Federal Clean

Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi

- annual reports required by any applicable requirement that are duplicative of the reporting required in t he pr evious pa ragraph w ill s atisfy t he r eporting requirem ents of the previous paragraph if noted on the submitted report.

G. Every report submitted under OAC 252:100 -8- 6 and OAC 252:100

- 43 shall be certified by a responsible official. [OAC 252:100-8- 6 (a)(3)(C)(iv)]

H. Any ow ner or ope rator s ubject t o t he pr ovisions of N SPS s hall m aintain r ecords of the occurrence and duration of any start

- up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]TITLE V STANDARD CONDITIONS July 1, 2005 3

I. Any ow ner or ope rator s ubject to the pr ovisions of N SPS s hall ma intain a f ile of a ll measurements and other information required by the subpart recorded in a permanent file suitable for i nspection. T his f ile s hall be r etained f or a t l east t wo y ears f ollowing t he da te of such

me asurements, maintenance, and records. [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi

- annually. The progress reports shall contain dates for

ac hieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. T he progress reports shall also contain an explanation of why any dates in the schedule of c ompliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8- 6 (c)(4)]

K. All t esting m ust be c onducted by m ethods a pproved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated

in accordan ce with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of t he “A QD P ortable A nalyzer G uidance” doc ument or a n e quivalent m ethod approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR §70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, a nd 63, f or a ll e quipment c onstructed or ope rated unde r t his pe rm it subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later t han 30 days af ter each anniversary da te of t he i ssuance of t he or iginal P art 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance w ith t he t erms a nd c onditions of t his pe rmit a nd of a ny ot her applicable r equirements w hich have be come ef fective s ince t he i ssuance of t his pe rmit. The compliance cer tification s hall a lso include s uch other f acts a s the pe rmitting a uthority ma y require to determine the compliance status of the source. [OAC 252:100-8- 6 (c)(5)(A), (C)(v), and (D)]

B. The certification shall describe the operating permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining c ompliance, c urrently a nd ove r t he r eporting pe riod; a nd a statement that the facility will continue to comply with all applicable requirements. [OAC 252:100-8- 6 (c)(5)(C)(i)

- (iv)]

C. Any document required to be submitted in accordance with this permit shall be certified as being t rue, accurate, and complete by a r esponsible of ficial. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. [OAC 252:100-8-5 (f) and OAC 252:100-8- 6 (c)(1)]TITLE V STANDARD CONDITIONS July 1, 2005 4

D. Any f acility r eporting nonc ompliance s hall s ubmit a s chedule of c ompliance f or emissions units or s tationary s ources t hat a re not i n c ompliance w ith all applicable requirements. This schedule s hall i nclude a s chedule of r emedial m easures, including an enforceable sequence of

actions with miles tones, leading to compliance with any applicable requirements for which the emissions uni t or s tationary s ource i s i n nonc ompliance. T his c ompliance s chedule shall resemble and be at l east as s tringent as t hat cont ained in any j udicial cons ent de cree or

a dministrative order to which the e missions uni t or s tationary s ource i s s ubject. A ny s uch schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based, except that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8- 6 (c)(3)]

SECTION V . R EQUIREMENTS TH AT BEC OME A PPLICABLE DURING THE

PERMIT TERM

The pe r mittee s hall comply w ith any additional r equirements that become effective during the permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8- 6 (c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance w ith t he t erms a nd c onditions of t his pe rmit ( including t erms and conditions established f or a lternate ope rating s cenarios, e missions t rading, a nd e missions a veraging, but excluding terms and conditions for whi ch the permit shield is expressly prohibited under OAC

252:100- 8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8- 6 (d)(1)]

B. Those requirements that are applicable are listed in the Stan dard Conditions and the Specific Conditions of this permit. Those requirements that the applicant requested be determined as not applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8- 6 (d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD. [OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8- 6 (a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8- 6 (a)(2)(A)]TITLE V STANDARD CONDITIONS July 1, 2005 5

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been s ubmitted a t l east 180 da ys be fore t he da te of expiration. [OAC 252:100-8-7.1 (d)(1)]

C. A duly issued con struction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100 -8- 1.4(b)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a c onstruction pe rmit s hall a pply f or a pe rmit t o ope rate ( or m odified operating permit) within 180 days following the first day of operation. [OAC 252:100-8- 4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit t o a ny c ircumstance, i s he ld i nvalid, t he a pplication of s uch provision to other circumstances, and the remainder of this permit, shall not be affected thereby. [OAC 252:100-8- 6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege. [OA C 252:100-8- 6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8- 6 (c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon r eceipt of a written request and within sixty (60) days of the request unless the DEQ specifies another time period, any information that the DEQ m ay r equest t o de termine w hether c ause e xists for modifying, reopening, revoking, reissuing, terminating the permit or to determine compliance with the per mit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8- 6 (a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27 A O.S. 2 -5- 105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment. [OAC 252:100-8- 6 (a)(7)(E)]TITLE V STANDARD CONDITIONS July 1, 2005 6

C. Notification to the AQD of the sale or transfer of ownersh ip of this facility is required and shall be made in writing within 10 days after such date. [ Oklahoma Clean Air Act , 27A O.S. § 2-5-112 (G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The pe rmit m ay be m odified, r evoked, r eopened and reissued, or t erminated f or c ause. Except as provided for minor permit modifications, the filing of a request by the permittee for a permit modification, revocation, r eissuance, t ermination, not ification of pl anned c hanges, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4( a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source category three or m ore y ears pr ior t o t he e xpiration da te of t his pe rmit. N o s uch reopening is required if the effective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit m ust be r evised or r evoked t o a ssure c ompliance w ith the applicable requirements. (3) The DEQ or the EPA determines that inaccurate in formation was used in establishing the emission standards, limitations, or other conditions of this permit. T he DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ.

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1]

(1) It onl y a pplies to that s pecific ite m by s erial num ber or some other permanent

identificati on. (2) Grandfathered status is lost if the item is significantly modified or if it is relocated outside the boundaries of the facility.

D. To make changes other than (1) those described in Section XVIII (Operational Flexibility), (2) a dministrative pe rmit a m endments, a nd ( 3) t hose not de fined a s a n I nsignificant A ctivity (Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8- 6 (c)(6)]TITLE V STANDARD CONDITIONS July 1, 2005 7

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of c redentials a nd ot her doc uments a s m ay be r equired by l aw, t he permittee shall allow authorized regulatory of ficials to perform the f ollowing ( subject to the permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2 -5-105(18)

for confidential information submitted to or obtained by the DEQ under this section): [OAC 252:100-8- 6 (c)(2)]

(1) enter upon the permittee's pr emises dur ing r easonable/normal w orking hour s w here a

source i s l ocated or e missions

- related a ctivity i s c onducted, or w here r ecords m ust be kept under the conditions of the permit; (2) have access t o a nd c opy, a t r easonable t imes, a ny r ecords t hat m ust be ke pt unde r t he conditions of the permit; (3) inspect, at r easonable t imes and using r easonable s afety practices, any facilities, equipment ( including m onitori ng a nd a ir pol lution c ontrol e quipment), pr actices, or operations regulated or required under the permit; and (4) as a uthorized by t he O klahoma C lean A ir A ct, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit.

SECTION XIV. EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under

no circumstance sha ll notification be more than 24 hours after the exceedance. [OAC 252:100-8- 6 (a)(3)(C)(iii)(II)]

B. An " emergency" m eans a ny s ituation a rising f rom s udden a nd r easonably unf oreseeable events be yond t he c ontrol of t he s ource, i ncluding a cts of God, which situation r equires immediate corrective action to restore normal operation, and that causes the source to exceed a technology- based emission limitation under t his pe rmit, due t o una voidable i ncreases i n emissions attributable to the emergency. [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompliance with such technology-based emission limitation if the conditions of paragraph D below are met. [OAC 252:100-8- 6 (e)(1)]

D. The affirmative de fense of emergency s hall be de monstrated t hrough pr operly s igned, contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8- 6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]

(1) an emergency occurred and the pe rmittee can identify t he caus e or caus es of t he

emergency; (2) the permitted facility was at the time being properly operated;TITLE V STANDARD CONDITIONS July 1, 2005 8

(3) during the period of the emergency the permittee took all reasonable steps to minimize levels of e missions t hat e xceeded t he e mission s tandards or ot her r equirements i n t his permit ; (4) the pe rmittee s ubmitted timely not ice of the e mergency to AQD, pursuant to the applicable r egulations ( i.e., f or e mergencies t hat pos e a n “imminent and substantial danger,” within 24 hours of the time when emission limitations were exceeded due to the

e mergency; 4:30 p.m. the next business day for all other emergency exceedances). See

OAC 252:100 -8- 6(a)(3)(C)(iii)(I) and (II). T his notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emi ssions, and corrective actions taken; and (5) the permittee submitted a follow up w ritten r eport w ithin 10 w orking da ys of f irst becoming aware of the exceedance.

E. In any enf orcement pr oceeding, the pe rmittee s eeking t o establish the occurrence of an

emerge ncy shall have the burden of proof. [OAC 252:100-8- 6 (e)(3)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and register w ith the appr opriate ag ency a r isk managemen t plan by J une 20, 1999, or t he applicable effective date. [OAC 252:100-8- 6 (a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate i ndividual e missions un its that are either on the lis t in Appendix I to OAC T itle 252, Chapter 100, or w hose a ctual c alendar year e missions do not e xceed a ny of t he l imits below. Any activity to which a State or federal applicable requirement applies is not insignificant even i f it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

(1) 5 tons per year of any one criteria pollutant. (2) 2 tons per y ear f or a ny one ha zardous a ir pol lutant ( HAP) or 5 t ons pe r y ear f or a n aggregate of two or mor e HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule.

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

op erate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]TITLE V STANDARD CONDITIONS July 1, 2005 9

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherw ise in the permit). When an operating scenario is changed, the permittee shall record in a log at the facility the scenario under which it is operating. [OAC 252:100-8- 6 (a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) res ult in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted emission rate of any existing emissions unit to be exceeded;

provided that the f acility p rovides t he E PA a nd t he D EQ w ith w ritten not ification as required below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for emergencies as defined in OAC 252:100 -8- 6 (e). The permittee, the DEQ, and the EPA shall

attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, a nd any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8- 6 (f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE

- ONLY REQUIREMENTS

A. The following a pplicable r equirements a nd s tate

- only r equirements a pply to the f acility unless elsewhere covered by a more restrictive requirement:

(1) No person shall cause or permit the discharge of emissions such that Nation al Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] (2) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning Subchapter. [OAC 252:100-13] (3) No particulate emissions from any fuel

- burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19] (4) For all emissions units not subject to an opacity limit p romulgated under 40 CFR, Part 60, NSPS, no discharge of g reater t han 20% opa city i s a llowed e xcept f or s hort

- term
occurrences which consist of not more than one six

- minute period in any consecutive 60 minutes, not to exceed three such periods in any consec utive 24 hour s. In no c ase shall the average of any six -minute period exceed 60% opacity. [OAC 252:100-25] (5) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions or iginate i n s uch a m anner a s t o da mage or t o interfere w ith the us e of adjacent properties, or caus e ai r qua lity s tandards t o be ex ceeded, or i nterfere w ith the maintenance of air quality standards. [OAC 252:100-29]TITLE V STANDARD CONDITIONS July 1, 2005 10

(6) No sulfur ox ide emissions from new gas

- fired fuel

- burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31] (7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and with a capacity of 400 g allons or more storing a liquid with a vapor pressure of 1.5 ps ia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor- recovery system. [OAC 252:100-37-15(b)] (8) All f uel

- burning e quipment s hall a t a ll t imes be pr operly ope rated a nd m aintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of ozone-depleting substances. [40 CFR 82, Subpart A]

1. Persons producing, importing, or placing an order for production or importation of certain class I and class I I s ubstances, HCFC

- 22, or H CFC

- 141b s hall be s ubject t o t he requirements of §82.4.

2. Producers, importers, exporters, purchasers, a nd persons who transform or destroy certain class I and class II substances, HCFC

- 22, or HCFC

- 141b are subject to the recordkeeping requirements at §82.13.

3. Class I s ubstances ( listed a t A ppendix A t o S ubpart A ) include certain CFCs, Halons, HBFCs, carbo n t etrachloride, t richloroethane ( methyl c hloroform), a nd bromomethane (Methyl B romide). C lass I I s ubstances ( listed a t A ppendix B t o S ubpart A ) include

HCFCs.

B. If t he permittee performs a s ervice on motor (fleet) vehicles when this s ervice involves an

ozone- depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is s ubject to all a pplicable r equirements. N ote: T he te rm “motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. T he term “MVAC” as used in Subpart B does not include the

air

- tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC- 22 refrigerant. [4 0 CFR 82, Subpart B]

C. The pe rmittee s hall c omply w ith the f ollowing s tandards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F]

(1) Persons ope ning a ppliances f or m aintenance, s ervice, repair, or dispos al mus t c omply with the required practices pursuant to § 82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to § 82.158. (3) Persons pe rforming maintenance, service, repair, or di sposal of a ppliances m ust be certified by an approved technician certification program pursuant to § 82.161. (4) Persons disposing of small appliances, MVACs, and MVAC

- li ke appliances must comply

with record -keeping requirements pursuant to § 82.166.TITLE V STANDARD CONDITIONS July 1, 2005 11

(5) Persons ow ning c ommercial or i ndustrial pr ocess r efrigeration equipment must comply with leak repair requirements pursuant to § 82.158. (6) Owners/operators of a ppliances nor mally containing 50 or m ore pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit revi ew and, wherever it is not inconsistent w ith F ederal r equirements, t o pr ovide f or i ncorporation of r equirements established through construction permitting into t he S ources’ T itle V pe rmit w ithout c ausing redundant review. Requirements from construction p ermits may be incorporated into the Title V permit through the a dministrative a mendment pr ocess s et f orth in Oklahoma A dministrative Code 252:100-8-7.2(a) only if the following procedures are followed:

(1) The c onstruction pe rmit g oes out f or a 30

- day publ ic not ice a nd c omment us ing t he procedures s et f orth i n 40 C ode of F ederal R egulations ( CFR) § 70.7 (h)(1). This public notice s hall inc lude not ice to the publ ic tha t thi s pe rmit is subject to Environmental Protection A gency ( EPA) r eview, E PA obj ection, a nd pe tition t o E PA, a s pr ovided by 40 CFR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to pr ovide c omments w hen t he r equirements a re i ncorporated i nto t he Title V pe rmit; a nd that E PA r eview, EPA obj ection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit. (2 ) A copy of t he c onstruction pe rmit a pplication i s s ent t o E PA, a s pr ovided by 40 C FR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR § 70.8(b). (4) A c opy of t he pr oposed c onstruction pe rmit i s s ent t o E PA f or a 45

- day r eview pe riod as provided by 40 CFR § 70.8(a) and (c). (5) The D EQ c omplies w ith 40 C FR § 70.8 ( c) upon the written receipt within the 45

- day comment period of any EPA objection to the construction permit. T he DEQ shall not iss ue the permit until EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 CFR § 70.8 (d). (7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a). (8) The DEQ shall not issue the propose d construction permit until any affected State and EPA have ha d a n oppor tunity t o r eview t he pr oposed pe rmit, as provided by these permit

conditions. (9) Any requirements of the construction permit may be reopened for cause after incorporation

into the T it le V permit by t he a dministrative a mendment pr ocess, by D EQ a s pr ovided i n OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR § 70.7 (f) and (g). (10) The DEQ shall not issue the administrative permit amendment if performance tests fail to demonstrate that the s ource is ope rating in substantial c ompliance w ith all pe rmit requirements.TITLE V STANDARD CONDITIONS July 1, 2005 12

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall preclude the us e, i ncluding t he e xclusive us e, of a ny c redible e vidence or i nformation, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [OAC 252:100-43-6]June 14, 2006

Mr. Karl L. M eyers, Operating Vice President, Muskogee Fort James Operating Company

4901 Chandler Road Muskogee, OK 74403

RE: Construction Permit No. 99-113- C (M -4) (PSD) Fort James Operating Company Muskogee Mill – Mill Process Improvement Project

Dear Mr. Meyers :

Enclosed i s t he referenced permit a uthorizing construc tion of t he Mill P rocess I mprovement Project at the Muskogee Mill . Please note that this permit is issued subject to certain standard and specific conditions that are attached. These conditions mus t be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections.

Also note that you are required to annually submit an emission inventory for this facility. A n emission i nventory m ust be c ompleted on a pproved A QD f orms a nd s ubmitted ( hardcopy or electronically) by M arch 1 st of eve ry y ear. Any que stions c oncerning t he f orm or s ubmittal process should be referred to the Emission Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact our office at (918) 293 -1600. Air Quality personnel are located in the DEQ Regional Office at Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105.

Sincerely,

Herb Neumann AIR QUALITY DIVISION

En closure(s)

cc: Muskogee County DEQ OfficeTennessee Division of Air Pollution Control Files

Packaging Corporation of America, Counce Mill

Excerpt from PSD Preliminary Det ermination for Permit No. 953059PTexas Commission on Environmental Quality Files

Inland Paperboard and Packaging – Orange Mill

Excerpt from PSD Review for Permit No. PSD-TX-684M1/9654A/833M1PRELIMINARY DETERMINATION SUMMARY

Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60

I. APPLICANT

Inland Paperboard and Packaging Inc
1750 Inland Road Orange, Texas 77632

II. PROJECT LOCATION

The Inland Paperboard and Packaging facility is located at 1750 Inland Road near Orange, Orange County, Texas. The location is north of Orange and at Latitude 30 **** 13' 5" and Longitude 093 **** 44'
23".

III. Project Description

Inland Paperboard and Packaging, Inc. owns and operates a kraft pulp and linerboard mill in Orange, Orange county, Texas. They propose a Mill Improvement Project for this fa cility. The goal of this Mill Improvement Project is to improve the profitability of the mill by making the operations more cost effect ive and to increase the Mill
**** s Linerboard production capacity to 2,340 machine dr y tons of pulp per day (MDTPD). The increase in production will come from the recycle fiber process rather than an increase in the virgin pulp mill production.

Reductions in operating cost will be achieved through a number of projects. One project will be to upgrade their recycle fiber plant. Another project will include upgrades to the bark boiler to increase steam production through increase use of bar k. The two Linerboard machines will be modified to accept the increas e supply of fiber from the recycle fiber plant. Through t hese projects, the Mill
**** s Linerboard production will increase to 2340 machine dry tons of pulp per day, based on an annual

average.

Kraft linerboard is sold primarily for the manufacture of corrugated boxes.

IV. Federal StandardsThis facility must comply with Nati onal Emission Standards for Hazardous Air Pollutants (NSHAPS) for Pulp and Paper Industry, 40 CFR 63, Subpart
A and S.

This facility must comply with New Source Performance Standards (NSPS) for Kraft Pulp Mills, 40 CFR 60, Subpart A and BB.

The Bark Boiler must comply with NSPS for
Industrial-Commercial-Institutional Steam Generating Units, Subpart A

and Db.

The facility has made repr esentations that they will comply with all the applicable requirements of these standards.

Offsets required were obtained for the emissions of NO
x and VOC at a
ratio of 1.15 to 1.00. This was the proper ratio at the time the application

was submitted. Documentation on the source of these offsets was provided in the application.

V. Emissions

This facility is a major source of em issions. Listed below is a summary of

the total revised emissions rates asso ciated with this major modification request for the Mill Improvement Project.

Pollutant: Proposed Increase (tpy) PSD Significance Level (tpy)

PM/PM 10 95.40 15
SO 2 39.16 40
NO
x 190.70 40
CO 296.40 100
VOC 214.81 40

Lead 0.02

0.6

H 2 S 5.62 10
TRS 7.52 10

Be 0.000029 0.0004 Hg 0.000585 0.10

VI. Prevention of Significant Dete rioration (PSD) and Nonattainment (NA) ApplicabilityPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 3

This facility (Kraft Pulp Mill) is one of the 28 named PSD source categories with 100 tpy major threshol ds. The Mill Improvement Project is projected to trigger a PSD review for PM/PM 10 , CO, and NO
x and a
Nonattainment review for NO
x and VOC. The Beaum ont-Port Arthur area
was classified as a moderate nonattainm ent area for ozone at the time the application was submitted. Theref ore, this projec t also will undergo a
Nonattainment review for VOC and NO
x and secure the required offsets at
a ratio of 1.15 to 1.00.PRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 4

Pollutant Averaging

Period Highest

Modeled

Value

( μ g/m 3 ) Modeling Significance

Level ( μ g/m 3 ) Monitoring de

Minimis

Level ( μ g/m 3 )

PM 10 24-Hour 45.10 5 10

PM 10 Annual 0.99 1 -

NO
x Annual 2.22 1 14

CO 1-Hr 165.3 2000 -

CO 8-Hr 87.4 500 575

Maximum off-property concentrations of PM 10 exceeded its Modeling Significance Level and Monitoring de Minimis Level for the 24-hour averaging period, but did not exceed t he annual value. Therefore, a full impact analysis was required for PM 10 to show compliance with the
NAAQS for the 24-hour standard.

Screening modeling for NO
x exceeded the modeling significance level for the annual averaging period. Therefore, further refined modeling will be required to evaluate impact with NAAQS for the annual standard.

Screening modeling for CO maximum ground level concentration did not exceed either the monitoring nor t he modeling significance levels for 1-hour or 8-hour values. Therefore, no refined CO modeling is required.

VII. Best Available Control Technol ogy (BACT) and Lowest Achievable

Emission Rate (LAER)PRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 5



### PM 10 

### : Particulate matter (PM), both PM and PM 10 , emissions from this facility are primarily from the combustion process (bark boiler).

Bark Boiler: a review of the EPA RACT /BACT/LAER Clearinghouse and other permitting of bark boilers, the following methods are listed:

1. Electrostatic Precipitator (ESP)
2. Wet ESP 3. Baghouse 4. Wet Scrubbers (Venturi)

All system are considered technically feasible in the control of PM/PM 10 from a wood waste boiler with natural gas co-firing capabilities. The bark boiler is currently equipped with a venturi scrubber.

A cost/benefit analysis was performed to compare the econom ic impact of installing a new ESP (both dry and wet) and a new baghouse on the bark boiler, versus modifying the existing venturi scrubber. The results show
that the installation of new contro l equipment is not cost-effective.

From the Clearinghouse, tw o units that most closely match the Inland boilers in types of fuel mix are pe rmitted at 0.03 lb/MMBtu. The company proposes to remain with the existing scr ubber, but modify it to improve its efficiency to meet the 0.03 MMBtu limi t. This meets BACT for the control
of PM/PM 10 from a bark boiler.



### NO X 

### : NO
x emissions are formed by thermal burning of air with fuel and by nitrogen found in the fuel.

Bark Boiler: a review of the EPA RACT /BACT/LAER Clearinghouse and other permitting of bark boilers, the following methods are listed:

1. Selective Non-Catalytic Reduction (SNCR) 2. Selective Catalytic Reduction (SCR)
3. Good Combustion PracticesPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 6

A review of the permitted bark boile rs, along with literature from EPA, pollution control equipment vendors and technical associations, have
found several bark and wood waste fired boilers that use SNCR technology.

SCR technology has not been proven w hen applied to stoker fired bark boilers, such as the one used at the Inland Paperboard facility. SCR is

effective at a tem perature range of 500-800 **** F. In order to be effective, the catalyst must have a low parti culate loading to avoid clogging or chemically degrading the precious metal catalyst. Also, the presence of sulfur will cause problems with this syst em. The best location for a SCR system would be after the scrubber. The temperature leaving the

scrubber is about 154 **** F, therefore additional fuel will be needed to raise the exhaust gas stream to the requi red temperatures. Based on this,
SCR is not an effective method to control NO
x emissions from the bark

boiler.

The company has selected to insta ll a SNCR system on t he bark boiler to
control the formation of NO
x. as well as best combustion practices to
reduce all air contaminants from the bark boiler. It is expected that a
reduction of 22% will be achieved. The company proposes BACT as being 0.166 lb/MMBtu. This syst em meets BACT and LAER for the
control of NO
x from bark boilers.



### CO: CO emissions are pollutant formed by the incomplete combustion of fuel or hydrocarbons contained in the raw materials.

Bark Boiler: a review of the EPA RACT /BACT/LAER Clearinghouse and other permitting of bark boilers, the following methods are listed:

1. Good combustion practices

2. Fluidized Bed Boilers 3. Staged combustion

4. Incinerator 5. Oxidation Catalyst 6. Spreader StokerPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 7

The Oxidation Catalyst system woul d require an exhaust gas temperature

of 800 **** F in order to work properly. The current exhaust temperature of

the bark boiler is about150 **** F. Therefore, raising the exhaust temperature would require significant heat input, increasing the operating cost and increasing emissions.

The installation of a fluidized bed system would not be cost efficient because of the cost to replace the existing system.

Like the Oxidation Catalyst System , an incinerator system would require
the introduction of increased heat i nput in order to operate properly.

The company proposes process cont rols through the use of good combustion practices and good combusti on unit design. This includes improvements in the boiler over fir ed air system. The bark boiler is a spreader stoker type boiler. This system meets BACT for the control of
CO from bark boilers.



### VOC: VOC emissions are fo rmed by burning many types of fuel and by handling and processing trees.

Bark Boiler: a review of the EPA RACT /BACT/LAER Clearinghouse and other permitting of bark boilers, the following methods are listed:

1. Good combustion practices 2. Staged combustion

3. Incinerator 4. Oxidation Catalyst

The company proposes to use good co mbustion operation practices to
control the emissions of VOC from the Bark Boiler. This is BACT/LAER
for the control of VOC from Bark Boilers.

Linerboard Machines: a review of the EPA RACT/BACT/LAER Clearinghouse and other permitting of Linerboard/Paper Machines showed no papermaking systems having any type of add on controls. EPAPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 8

concluded in the review of the MACT standards that applying controls to the vent streams of papermaking systems was not cost effective to reduce HAPs. The amount of HAPs gener ated in the papermaking system was negligible when compared to the rest of the pulp and paper process. These HAPs are usually introduced in the form of additives used in the paper making system. Also, the Pu lp and Paper Industry has been reducing HAPs and other solvents us ed in the papermaking system in the past 15 years. Therefor e, EPA has concluded that a MACT standard for papermaking systems based on low-HAP additive substitution is not

warranted.

Therefore, BACT/LAER for the c ontrol of VOC fr om the Linerboard

Machines is low-HAP additives.

VIII. Air Quality Monitoring

A monitoring analysis was performed to determine if preconstruction monitoring would be required. A summary of the monitoring analysis with results shown in micrograms per cubic meters ( **** g/m 3 ) is provided as
follows:

Pollutant Averaging Period Monitoring Significance ( **** g/m 3 ) Maximum Concentration ( **** g/m 3 )

PM 10 24-Hour 10 45.10

NO

xAnnual 1 2.22

The maximum concentration for emissions of PM 10 was greater than its monitoring de minimis level, thus tri ggering pre-construction monitoring. To be exempt from the pre-constr uction monitoring requirements, a background modeling analysis is required to evaluate the existing ambient air quality for the region as per guidanc e from the NSR Modeling Section.

For the PM 10 PSD NAAQS analysis, a Point Source Database (PSDB)

retrieval was conducted to obtain s ources within the significant impact
area for PM 10 . The highest sixth-high for the years modeled showed aPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 9

24-hour concentration of 71.39 μ g/m 3 . This value was added to the background concentration of 75 μ g/m 3 to yield a total concentration of

146.39 μ g/m 3 for PM 10 . This concentration is below the 24-hour NAAQS

level of 150 μ g/m 3 . Therefore, complianc e with the PSD NAAQS is demonstrated and is exempted from pre-construction monitoring.

Local PM monitors are located clos e enough to the plant site to be considered representative of t he mill operation. The highest
concentration recorded in the Si gnificant Impact Area was 119.93 μ g/m 3

, which is below the NAAQS standard.

From the NO
x refined modeling for the annual averaging period, the highest value was 25.50 μ g/m 3 . When combined with the background
concentration of 35.0 μ g/m 3 , the total NO
x was 60.5 μ g/m 3 . This is below
the NAAQS value of 100 μ g/m 3

.

Local NO
x monitors had recorded a maximum background concentration
level of 50.6 μ g/m 3 , which is below the NAAQS.

IX. Air Quality Analysis

The air quality impact analysis was perfo rmed using the Industrial Source Complex model to predict worst-case impacts for all pollutants and is

summarized in the table below. A significance analysis was conducted to determine if a full impact analysis w ould be required. The modeling
results indicate that a full impact analysis is required for PM 10 for the
24-hour standard and NO
x for the annual st andard to demonstrate compliance with the National Ambient Air Quality Standard (NAAQS) and
PSD increment.

Incremen

t Analysis NAAQS Analysis

Averaging De

Minimis Incremen
t Class II

Area Modele

d NAAQS Primary /
Secondar Modele

d Backgroun Modeled Impact + BackgrounPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 10

Pollutan

t Period ( **** g/m 3 ) ( **** g/m 3 ) Impact ( **** g/m 3 ) y ( **** g/m 3 ) Impact ( **** g/m 3 ) d ( **** g/m 3 ) d ( **** g/m 3 )

PM 10 24-hour 5 30 18.23 150 71.39 75 146.39

NO

x annual 1 25 17.82 100 25.50 35 60.5

PM 10 : Plant-wide emissions of PM 10 and PSDB emissions for other off-property sources were modeled fo r the 24-hour averaging periods. Modeling showed compliance with N AAQS. The increment analysis showed that the project and other in crement consuming sources will not
result in exceedances of the PSD increments for PM 10

.

NO x : Plant-wide emissions of NO
x and PSDB emissions for other off-property sources were modeled fo r the annual averaging period. Modeling showed compliance with the NAAQS. The increment analysis showed that the project and other in crement consuming sources will not
result in exceedances of the PSD increments for NO
x .

X. Additional Impacts Analysis

Growth Analysis: There will be no additional jobs generated by the amendment to the State permit, by t he modification of the PSD permits, nor by the issurance of the nonattain ment permit. No air quality impacts associated with this project will occur.

Soil and Vegetation Impacts : The modeled concentrations of PM 10 , NO
x , SO 2 , and CO were determined to be less than the NAAQS, which is designed to protect the public heal th and welfare from known or anticipated adverse pollut ant impacts. Therefore, soil and vegetation in the area should not be adversely affe cted by these emission increases from the facility.

Visibility Impairment Analysis: No PSD Class I area impact analysis for increment consumption and visibility was conducted because there are noPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 11

Class I areas within 100 km of this facility. The closest Class I area was
located a distance of 394 kilometers from this site and it was Breton

Wilderness Area located in Alabama. The second closest Class I area
was located a distance of 464 kilo meters and it was Caney Creek

Wilderness Area in Arkansas.

The nearest Class II area was the Orange County Airport, which is located approximately 17.6 kilometers from the Inland site. The visibility analysis
showed that the Class II standards were being met at the Airport site. Therefore, the Inland M ill Improvement Project s hould have no impact on visibility at this site.

XI. Air Toxics Review

In addition to the air quality analysis performed for all pollutants subject to PSD review, a state modeling and im pacts evaluation was conducted.
The evaluation included a Total Sus pended Particulate (TSP) property line analysis to meet 30 Texas Administra tive Code (TAC) Chapter 111, a SO 2 and H 2 S property line analysis to meet 30 TAC Chapter 112, and Health Effects review. The modeling result s indicate that off-property TSP impacts will be within proper ty line standards as required by the state regulations. A maximum 1- hour concentration of 24.3 μ g/m 3 and a 3-hour
concentration of 18.3 μ g/m 3 was predicted by m odeling. The state

standards are 400 μ g/m 3 for 1-hour and 200 μ g/m 3 for 3-hour.

Facility-wide SO 2 emissions were modeled wit h a result of a maximum

30.3 μ g/m 3 for the 30-minute state standard. This compares to the state
standard of 817 μ g/m 3

.

Facility-wide H 2 S emissions were modeled with a result of a maximum of

4.67 μ g/m 3 for 30-minute state standard. This compares to the state
standard of 162 μ g/m 3

.

XII. ConclusionPRELIMINARY DETERMINATION SUMMARY Permit No. 9654A, PSD-TX-684M1/833M1, and N **** 60 Page 12

The air quality analysis indicates that the emissions from the proposed project will not cause or contribute to a violation of any applicable NAAQS or PSD increment nor have any adver se impacts on soil, vegetation, visibility, or any Class I or Class II Area. LAER and BACT are proposed
for all affected emission sources to reduce emissions. Off-sets for NO
x and VOC emissions were obt ained in the proper amounts

. Therefore, the Executive Director proposes a pr eliminary determination of approval for Inland Paperboard and Packaging Inc. to proceed with the Mill Improvement Project.

### PERMIT AMENDMENT

REVIEW ANALYSIS & TECHNICAL REVIEW

Permit No: 8068/PSD-TX-437 Company: Donohue Industries Project Type: Amendment Facility Name: Kraft Pulp and Paper Mill

Record No: 64803 City: Lufkin

Account No: AC-0017-C County: Angelina Permit Reviewer / Engineer: Kevin Ellis

AUTHORIZATION CHECKLIST: Will a new policy/precedent be establis hed? (ED signature r equired if yes)...................................... No Is a state or local official opposed to t he permit? (ED signature required if yes) ............................... No

Is waste or tire derived fuel invo lved? (Deputy signature required if yes)

.......................................... No Are waste management facilities involved? (Deputy signature requ ired if yes) ................................. No

PROJECT OVERVIEW
The Donohue Industries Kraft mill in Lufkin (formerly owned by Champion International) has requested an amendment to authorize the installation of a new paper machine. The new machine will replace three of the existing paper machines (Nos 1, 3, and 4) and will not resu lt in an increase in production at the facility. There are no incr eases (emissions sumarized below) and PSD major modification is not triggered.

30 TAC Chapter 113 RULES 113.100 Compliance with applicabl e MACT standards expec ted? ............................................. Yes Subparts A and S

30 TAC Chapter 116 RULES
PUBLIC NOTICE INFORMATION 116.130-137 Was public notification required?

................................................................................... No If no, give reason: There is an emissions decrease

.

EMISSION CONTROLS 116.111(2)(C) Will the facility utiliz e BACT?

................................................................................ .... Yes 116.111(2)(G) Is the facility expected to perform as represented in the app licati on? ...................... Yes 116.140 Permit Fee: $ 75,000 Fee certificat ion prov ided? ................. NA

SAMPLING AND TESTING 116.111(2)(A)(i) Are the emissions expected to comply with all TNRCC air quality rules and regulations, and the intent of the Texas Cl ean Air Ac t? .......................................... Yes 116.111(2)(B) Will emi ssions be m easur ed? ................................................................................ Yes Comments: VOCs will be sampled from the pr ocess vents from the paper machine.

FEDERAL PROGRAM APPLICABILITY 116.111(2)(D) Compliance wit h applicable N SPS expec ted? ........................................................ NA 116.111(2)(F) Compliance with applicable NESH APS expec ted? ................................................. NA 116.111(2)(H) Is nonattainment review required?

.......................................................................... No A. Is the facility locat ed in a nonattain ment area? ................................................ No

### New Source Analysis & Technical Review

Permit No. 8068 and PSD-TX-437 Account No. AC-0017-B Page 2

116.111(2)(I) Is PSD applic able? ..............................................................................................

.......... No A. Is facility a federal majo r source (100/ 250 tons/y r)? ............................................. Yes B. Is the project a feder al major m odifica tion? ........................................................... No 1.Did project emission increases (proposed a llowables minus the two-year average actual

emissions, no consideration given to decreases) trigger netting? .................................... Yes 2. Was contemporaneous increase signi ficant? .................................................................. No 3. Change excluded by 40 CFR 52.21(b)(2)(iii)? ............................................................... No

30 TAC Chapter 122 RULES

TITLE V APPLICABILITY 122.10(8)(A) Is facility a major source under FCAA Section 112(b)? ......................................... Not determined A. Facility emits 10 tons or more of any single HAP? .............................................. Not quantified B. Facility emits 25 tons or more of a combination ................................................. Not quantified Note - the scope of this review does not cover th e facilities that emit the HAP of concern (MeOH ). 122.10(8)(C) Does the facility emit 100 tons or more of a ny air pollu tant? .................................................... .. Yes 122.10(8)(D) Is the facility a non- attainment ma jor source? ...................................................................

........... No

REQUEST FOR COMMENTS
REGION: 10 (Beaumont) Reviewed by: Paul Judice

Paul Judice has indicated that the R egion 10 office would like to see more enforceable conditions, in particular, sampli ng requirements on a regular basis. The company has tentatively agr eed to include these in the pending renewal. It should be noted that the paper machines are separat e from the sources that would be considered from regular testing.
COMP: 6/29/99 Reviewed by: Tel Croston This site has had one agreed order over the last five years that dealt with oders when
the lime kiln was shut down for maint enance. There have been several informally resovled NOVs since that time, none of which were connected with the paper

machines.

REVIEW SUMMARY
PROCESS DESCRIPTION Donohue Industries operates a 600 ton per day (tpd) Kraft pulp and paper mill in Lufkin. The mill currently operates four paper machi nes that reduce the moisture in the pulp and produce the final paper product. The machines direct the paper mat through a series of steam heated rollers and eventually onto a spool from shi pping in bulk. The new paper machine will operate in a similar manner to the existing ones, put is designed to operat e at a much higher capac ity than any one of the existing machines. The additional capacity will a llow DI to shut down 3 of the current paper machines. This process will not allow an increase in production due to the limited amount of pulp that could be sent to the paper machine( s) effectively bottlenecks the process.

SOURCES, CONTROLS, SOURCE REDUCTION AND BACT
The main sources of emissions ar e the paper machine process vents, which direct the air from the

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Permit No. 8068 and PSD-TX-437 Account No. AC-0017-B Page 3

paper machine out through the roof of the building. The emissions ar e mostly steam, but there are
entrained VOCs that are emitted as well. Although the emissions are very dilute, the overall emission rate is relatively lar ge due to the volume of the exhaust stream. There are building vents which also allow air to exit the building. These vents are mostly ambient air and are not quantified as an emission source in the permit. The emissi on factors are based on previous sampling done at this facility and do not account for the backgr ound concentration of VOCs from the surrounding vegetation. Because of this, the factors are considered conservative.

The changes in emissions are summarized below:

Note that there are some changes in the estimated emissions from several grandfathered boilers (not included in this summary). These units are included on the MAERT due to their use in netting calculations done during a previous permit review. The emissions have changed due to sampling that was performed on the units, and netting was
re-evaluated to make sure that there was no PSD major modification triggered.

IMPACTS EVALUATION 1. Was modeling done? No Type? NA 2. Will GLC of any air contaminant cause violati on of N AAQS?

.................................................. No

3. Is this a sensitive loca tion with respect to nuis ance? ............................................................... No

4. Is the site within 3000 feet of any sc hool? ............................................................................... No

COMPLIANCE HISTORY
1. Was a NOV issued for cons truction without a permit? ............................................................. No 2. Was the NOV resolved by issuance of permit? ........................................................................ NA

MISCELLANEOUS 1. Is applicant in agreement with special conditi ons? ................................................................. Yes Company repr esentat ive? ........................................................................................ Chad Nerren
Contact ed vi a? ........................................................................................................... Phone/FAX

Date of c ontact? ..............................................................................................................

.... 7/7/99 2. Did the franchise tax verify the applicant to be in good standi ng? ........................................... NA

3. Emission reductions from source reduction or pollu tion prev ention ........................................... 0 4. Emissions reductions resulting from the application of BACT required by state rules, avoidance of potential impacts problems, and voluntary reducti ons .......................................................... 0 5. Other permit(s) affe cted by this acti on? ................................................................................... No Changes in Emissions (TPY): Contaminants Current Proposed Change

TSP 648.4 648.4 0.00

PM 10 648.4 648.4 0.00

NO

x 1209.3 1209.3 0.00

CO 1447.4 1447.4 0.00

VOC 1795.9 1753.0 -42.90

SO 2 948.1 948.1 0.00

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Permit No. 8068 and PSD-TX-437 Account No. AC-0017-B Page 4

Permit Reviewer /Engineer Date Team Leader/Section Manager/Backup

Date