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-01-4 

 

96
Prevention 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 Georgia

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 and Approved by:

David M. Matos – Acting Chemicals Unit Coordinator

John Yntema – Acting SSPP Manager

Heather Abrams – SSPP Manager

Ron Methier – Chief, Air Protection Branch

97
SUMMARY......................................................................................................................................................................................i

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

2.0 PROCESS DESCRIPTION........................................................................................................................................ 1

3.0 REVIEW 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 Rule – 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 H2S 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 Power 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 Technology Review for TRS and H2S 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

Summary – Control Technology Review for VOC Linerboard Machines P1 and P2 .......................................26

5.0 TESTING AND MONITORING REQUIREMENTS .......................................................................................26

6.0 AMBIENT AIR QUALITY REVIEW ...................................................................................................................30

7.0 ADDITIONAL IMPACT ANALYSES ..................................................................................................................35

8.0 EXPLANATION OF DRAFT PERMIT CONDITIONS .................................................................................36

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PSD Preliminary Determination Page i

SUMMARY

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 liquor 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 NOx burners. Finally, small 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 recovered 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, SO2, 

and NOX 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 permitted 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 unit 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 proposed modification the unit will 

burn only low sulfur coal and low sulfur fuel oil. Inland will install and operate a CEMS for NOX and a furnace oxygen 

monitor as a result of this project.

The Rome Linerboard Mill is located in Floyd County, which is classified as “attainment” or “unclassifiable” for SO2, 

PM10, NOX, 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 that 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 PM10, CO, VOC, TRS, and H2S, 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 violation 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 or 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 requested 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.

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PSD Preliminary Determination Page 1 of 49 

1.0 INTRODUCTION

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 boilers, 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 of 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 emission 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 of 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

PM10 288 15 Yes

PM 288 25 Yes

SO2 39.0 40 No

NOX (119) 40 No

CO 643 100 Yes

VOC 864 40 Yes

TRS 84 10 Yes

H2S 23 10 Yes

Pb 0.123 0.6 No

H2SO4 0.72 7.0 No

Be (2.08 x 10 -4) 4.00 x 10-4 No

Hg 7.35 x 10-30.10 No

The net increases were calculated by subtracting the past actual emissions (based 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 the potential emissions increases of 

PM/PM10, CO, VOC, TRS, and H2S 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 EPD 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 units 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 source 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 recycle 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).

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PSD Preliminary Determination Page 2 of 49 

Currently, heavy black 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 and 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.

Recovery 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 very 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 decommissioned.

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 clarification) 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 project 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, tire 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 the 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 controled 

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 PM 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 proposed 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 and 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 changes may allow for an increase 

in the unit’s overall steam generating efficiency. In addition, the coal burners will be upgraded to low NOx burners 

with a total heat input rating of 565 MMBtu/hr. Boiler management controls will also be upgraded.

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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 person 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 that 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 Section 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 NOX.

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 limit 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 six-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 subject to the rule for PM, NOX, 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 0.025 

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 NOX is limited to 0.20 pounds per million Btu heat input. Opacity for the Waste 

Fuel Boiler is subsumed by a more stringent PSD limit of 10%. The facility will control PM and opacity 

with an ESP. Opacity and NOX emissions will be monitored using a COMS and a CEMS.

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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 × P0.67

For P> 30 ton/hr, E = 55 × P0.11 - 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 SO2

from new fuel burning sources 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. Paragraph 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 NOX emissions from fuel burning equipment installed or modified 

after May 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 NOX emissions to 30 ppm @ 3% O2 on a dry 

basis during the period of May 1st to September 30th 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 install 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 

categories 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 stationary 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 for 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 plant in a newspaper of general circulation.

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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 reflecting 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 

application 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, if 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 standard 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” approach. 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 technically 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 operated 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 feasibility: 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 technology 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 development. 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 extended 

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 technologies 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 basis 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 to 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 In 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 technology 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.”

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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 Units. 

The standard sets limits for PM, opacity, NOX, and SO2 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 allowing the facility to avoid SO2 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 more 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 Furnace 5 is not subject to a NOX 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 NOX limits of 0.20 pounds per 

million Btu heat input. Compliance with these limits will be assured through the use of NOX 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 limit 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 prescribed 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 sludge, 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.

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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 mill 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 mill 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 

SO2 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 Mills, 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 reconstructed 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 MACT 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 furnaces 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% O2 0.152 lb/ton BLS

Lime Kiln 2A 0.064 gr/dscf@ 10% O2 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% O2 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 emission 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 combustion 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.

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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% O2

1

0.306 lb/ton BLS

Lime Kiln 2A 0.155 gr/dscf@ 10% O2 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% O2 0.467 lb/ton BLS Proposed 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 apply 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 Heaters 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% O2), 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/MMBtu 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 covered 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 Emissions

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 potential 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.

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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 precipitators (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 attracted 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 expensive 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 smallest 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 would 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: Evaluate 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 technology 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.

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Step 5: Select BACT

The BACT database emission limits for PM emissions from a recovery furnace range from 0.021 gr/dscf @ 8% O2

to 0.15 gr/dscf @ 8% O2. Inland proposes to meet a limit of 0.021 gr/dscf @ 8% O2 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 firing 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 dry ESP to minimize PM emissions constitutes BACT. 

The BACT emission limit has been established as 0.021 gr/dscf @ 8% O2 as also proposed by Inland. Compliance 

with the PM limit must be demonstrated through performance testing and monitoring of the associated 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% O2

RECOVERY 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 practices 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 CO2 in a downstream control device. This could be 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 CO2 at lower temperature. Fuel would also be required for a CO catalyst 

application because the exhaust 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%

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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 and 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, 

Recovery 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 combustion 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 temperature 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 degrees 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 injection 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 NOX, would result from the combustion needed to either 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 catalyst, 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% O2. 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 limit 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 established as 650 ppm @ 8% O2

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 burning 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 Package 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% O2 while burning BLS

CO Good Combustion Practices 0.20 lb/MMBTU while burning fuel oil alone

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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 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 8: 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 4-5 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 combustion 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 

BACT 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 limit 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 analysis 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 Recovery 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 alone

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RECOVERY FURNACE 5 – TOTAL REDUCED SULFUR (INCLUDING H2S)

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 from 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, efficient 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. 

Caustic packed tower scrubbers are also effective in controlling a portion of TRS emission, primarily H2S, 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 is H2S; therefore, by assuring BACT is met for TRS, it is assumed that BACT for 

H2S 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 technically 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 TRS 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%

1Direct contact 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 PSD 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 design 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 corrected 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 H2S; therefore the proposed BACT level for H2S, is set at 

4 ppm @ 8% oxygen.

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PSD Preliminary Determination Page 14 of 49 

Conclusion – TRS Control (Including H 2S)

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

TRS and H2S emissions constitutes BACT. The BACT emission limits have been established as 5 ppm and 4 ppm, 

respectively, corrected to 8% O2. Compliance with the emission limits must be demonstrated through continuous 

emissions monitoring.

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

To fulfill the PSD permitting requirements for TRS and H2S, 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 of 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% O2 12 hours

H2S NDCE Design and Good Operating Practices 4 ppm, 8% O2 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 efficiency 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 Filtration (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 most 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

Control 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 database 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.

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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 PM 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 pulverized 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 feasible 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 analysis 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 would 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 existing 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.

Summary – 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 is 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: Identify all Control Technologies

The generation of CO can be minimized through the use of good combustion practices, oxidation to CO2 in a 

downstream unit, or by passing the gases over a catalyst at sufficiently high temperatures.

Option 1: Staged Combustion and Good Combustion Practices

Option 2: Oxidation

Option 3: Catalyst Technology

Step 2: Eliminate Technically Infeasible Options

All options are technically feasible.

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PSD Preliminary Determination Page 16 of 49 

Step 3: Ranking Remaining Control Technologies by Control Effectiveness

Table 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 database 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 combustion 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% O2, which is roughly equivalent to 0.25 

lb/MMBtu. With this proposed project the mill will be installing low NOX burners on the coal-fired boiler. This 

installation is expected to reduce NOX to less than half its current level. With this reduction in NOX, CO emissions 

may potentially increase because of the design of the low NOX burners. A small increase in CO would, however, be 

considered warranted due to significant reduction in NOX, which is considered a higher priority pollutant.

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 established as 300 ppm @ 3% O2, 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 summarized 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 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.

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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 Catalytic 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 catalytic 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 there 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 demonstrated 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 Limit

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 high 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 pre-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: Cyclone

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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 converted 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 Technology 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 emission 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 project, 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 oil, 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 clearinghouse) 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 has 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 performance 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 Boiler 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.

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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 more 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 CO2. In the 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 systems 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 stokerfired 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 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 4-13 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 practices. 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 

environmental 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. Currently 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 moisture 

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 fuel oil separately or in combination.

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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% O2 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 and 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 waste 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 limits 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, and fuel oil separately 

or in combination.

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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 SULFUR (including H2S)

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

Waste Fuel Boiler WF is a potential source of TRS and H2S gases. The unit will be used to burn HVLC NCGs, 

which contain TRS gases, should the facility not 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 SO2. 

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 currently 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 resulting 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.

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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

1According 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 only 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 technology 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 showed 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 midrange 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 has 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 permitting 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/MMBtu

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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 CO2.

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 Control 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. NOX emissions would also increase with the use of an RTO by about 20 tpy. 

Any increase in NOX emissions is highly undesirable because NOX 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 NOX 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 established 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 permitting 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 RBLC database.

Table 27: BACT Summary for Package Boiler 2

Pollutant Control Technology Proposed BACT Limit

CO Good Combustion Practices 0.20 lb / MMBtu

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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 Control 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 emission 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 impact 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. NOX emissions would also increase with the use of an RTO by about 20 tpy. 

Any NOX increase is undesirable 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 

constitutes 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 

previous 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/MMBTU

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LINERBOARD MACHINES P1 and P2 - VOLATILE ORGANIC 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 subject 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

Step 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 BACT/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 operations, 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 consumption (natural gas and electricity used by the RTO), and the significant increase in NOX emissions 

(estimated at greater than 100 tpy) that would result from the combustion of natural gas in the RTO.

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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 681. 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 per 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 Method 

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 control 

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 SO2 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 this amendment to conduct initial performance tests for PM, opacity, TRS, H2S, CO, VOC, 

and SO2. 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, H2S, 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 Conditions 3.3.6 and 3.4.5.

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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 limit in 

Condition 3.4.5 and the SO2 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 burned 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 Condition 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, excess 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 combustion 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 Title V permit. The facility will be required to undergo initial performance testing for 

opacity, PM, CO, VOC, and NOX emissions from Power Boiler 4 when the modifications to unit are completed.

Monitoring Requirements

The Permittee is required to measure the 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 

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

The Permittee is required to operate a CEMS for NOX for Power Boiler 4. The CEMS is necessary to provide a 

reasonable assurance of compliance with the PSD Avoidance limit in Condition 3.3.63.

Compliance with the PSD and PSD Avoidance limits for SO2 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 content 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. Good 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 amount 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 NOX. The tests are 

necessary to determine compliance with limits under PSD and 40 CFR 60 Subpart Db.

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Monitoring Requirements

The Permittee is required to use a CEMS to monitor emissions of NOX. 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 NOX limits in 40 CFR 60 Subpart Db.

No periodic monitoring is required for PM. Based on the fuels burned 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 periodic 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 SO2 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 required 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 for PM, opacity, CO, VOC, SO2, and NOX. 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 NOX, SO2, 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 the 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. The 

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 necessary to demonstrate compliance with the NOX 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 achieved 

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.

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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 compliance 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 this 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 SO2 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 major 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 SO2 and to 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 O2 from the Lime Kilns in order to 

calculate and record 12/24 hour total reduced sulfur 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 recorded 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, and 3.4.2. These limits include those contained in Georgia Rules (b) and (e).

There is no monitoring required for SO2 from the lime kilns. The regenerated lime acts as a scrubbing agent for the 

pollutant; therefore the likelihood of violation of the PSD limits 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 SO2. 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 the 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 SO2 and TRS limits in Conditions 3.3.11 and 3.4.8 (PSD and Georgia 

Rule (gg)).

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HVLC NGCs:

If the facility does not comply 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 the 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 

Standard (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/PM10, CO, TRS, and H2S 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 the 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 

provided 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/PM10 concentration of 181 ug/m3

on the road. This is above the standard of 150 ug/m3.

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 

able to provide representative data that may be used in place of pre-construction monitoring by the company.

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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, the 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 about 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 determination. 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 around 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 for 

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 building 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 regulations establish specific maximum allowable increases in ambient concentrations (or increments) for 

PM10, NOx, SO2, 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 PM10, NOX, SO2 and CO concentrations within each area category. The area 

categories are defined below:

Class I – Those areas where almost any deterioration 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 

quality 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 ambient 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 ambient 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 PM10, CO, TRS, and H2S were calculated in this 

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.

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Table 32. Significant Impact Levels and Significant Monitoring Concentrations

Pollutant Averaging 

Period

PSD Significant 

Impact Level 

(ug/m3)

Monitoring 

Concentration 

Level (ug/m3)

Modeled 

Concentration 

(ug/m3)

Notes

24-Hour 5 10 67.2 Additional modeling needed PM10 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

H2S 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 PM10 concentration did exceed its SIL; therefore refined modeling is required for the pollutant. 

PM10, H2S, and TRS did exceed their pre-construction monitoring levels. A state local area monitor (SLAM) for 

PM10 is close enough to be considered representative of background emission, therefore pre-construction monitoring 

is not considered necessary for PM10. The mill currently has on-site TRS monitors; therefore no additional 

monitoring of that pollutant is considered warranted. H2S is a component of TRS; therefore pre-construction 

monitoring of that pollutant was also not considered necessary.

Because the modeled PM10 concentration increases exceed 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 determined 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 EPD 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/m3)

Modeled Concentration 

(ug/m3)

Notes

24-Hour 30 15.7 Includes all sources within 64 km PM10 Annual 17 1.7 Includes all sources within 64 km

As shown in Table 33, the modeled impacts of PM10 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 PM10 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/m3)

Background Conc. 

(ug/m3)

Combined Conc. 

(ug/m3)

NAAQS 

(ug/m3)

24-Hour 84.1 38 122.1 150 PM10 Annual 14.7 20 36.8 50 

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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 significant 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 SO2

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/m3)

Modeled Conc. 

(ug/m3)

Notes

24-Hour 0.32 0.18 No additional modeling required PM10 Annual 0.16 0.013 No additional modeling required

3-Hour 1 0.086 No additional modeling required

SO2 24-Hour 0.2 0.022 No additional modeling required

Annual 0.08 0.0013 No additional modeling required

Complex Terrain:

Because some 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 Procedures” 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 concentrations 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 PM10; therefore, complex terrain analysis is required for PM10. 

A further evaluation of the PM10 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 

completed 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 applicable 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 defined 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 maximum 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 calculation 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 MGLC, the ISCST3 refined dispersion model was used to 

predict a more accurate MGLC.

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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 pollutant 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 plume 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: Sources 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 

km” 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 prescribed 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 Bext for the 

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 addition 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 

SO2, 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 was 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 plume 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 version 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 visible 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 characteristic 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 

Class 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% level corresponded with a wind speed of 3 meters per second and a stability class of 

F.

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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 degrees. 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 thresholds. 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 and 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 area 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 would 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 reduces 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-absorbing 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 presented 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, the 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 forested and demonstrate no obvious sensitivity to industrial air 

emissions.

Since ground level concentrations of PM, NOX, and CO are not expected to increase by a significant degree as a 

result of this project, the impacts on soil and vegetation are predicted 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.

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Growth:

The modification to the Inland 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 Permit Amendment No. 2631-115-0021-V01-4.

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 modifications 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 Island, 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 emissions 

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 SO2 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 concentration of SO2 does not increase due to this 

change because of the shutdown of some equipment and the new SO2 limits imposed on other equipment.

Condition 3.3.2 has been modified. The allowable emission rate of SO2 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 referred 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 citation 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 SO2 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 SO2 does not increase due 

to this change because of the shutdown of some equipment and the new sulfur SO2 limits imposed on other 

equipment.

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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 

BACT 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 H2S 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 condition 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 emission 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 sulfur 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 Tank 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 referred 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 allowable SO2 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 SO2 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 has 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 CFR 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, the 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 according to 40 CFR 63 Subpart S. Reference to Lime Kiln 3A, which is to be 

decommissioned, has been removed from the condition.

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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 facility 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 391-3-1-.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 SO2 emissions do not increase from recovery furnaces when co-firing 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 

SO2 emissions 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 million 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. The condition limits NOX 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 

pounds 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 condition 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.

Condition 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 condition 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 391-3-1-.02(2)(d).

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PSD Preliminary Determination Page 39 of 49 

Condition 3.3.68.b has been added to the permit. The condition 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 -3-1-.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 input. 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 SO2 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 3.3.70 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 low 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 SO2 emissions.

Condition 3.3.72 has been added to the permit. The condition limits the fuel to be burned in the 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 CFR 63 Subpart DDDDD.

Condition 3.3.73.b has been added to the permit. The condition limits the emission of NOX 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 has 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 SO2 from Waste Fuel 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 

Boiler 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 391-3-1-.02(2)(d).

Condition 3.3.74 has been added to the permit. 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 permit. 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.

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PSD Preliminary Determination Page 40 of 49 

Condition 3.3.76 has been added to the permit. The condition 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. The 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 from 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 decommissioned.

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 

will 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 391-3-1-.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 Power 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 state 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 NOX from Package Boiler 2 to 

30 ppm corrected to 3 percent oxygen from May 1st through September 30th each year and is a requirement of 

Georgia Rule 391-3-1-.02(2)(lll). The rule applies to fuel-burning equipment permitted or brought on site after May 

1, 1999. The unit was permitted on October 17, 2002.

Condition 3.4.32 has been added to the permit. The condition limits the emission of SO2 from the Waste Fuel Boiler 

to 0.80 pounds per million BTU heat input. This is a requirement of Georgia Rule 391-3-1-.02(2)(g).

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PSD Preliminary Determination Page 41 of 49 

Part 4.0 Requirements for Testing

Condition 4.1.3 has been modified. Paragraph (k) has been updated to include SO2. 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 include 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 NOX 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 performance 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 SO2 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 testing for TRS, SO2, 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 Recovery 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 wastewater 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.

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PSD Preliminary Determination Page 42 of 49 

Condition 5.2.1.b has 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 H2S 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 modified. 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. NOX and furnace 

oxygen CEMS have been added for Power Boiler 4. The citation has been 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, SO2, and NOX 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 built.

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).

Condition 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 SO2 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 for 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 added 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 and 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.

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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 the 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 requires 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 requirements 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 requirements 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 requirements 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 streamgenerating records for Waste Fuel 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.

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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.

Condition 6.1.7.a(x) has been modified. The condition referred to the SO2 PSD limit for the combined power boiler 

stack. The excess emission statement has been rewritten to indicate the new short term SO2 limit of 1,130.0 pounds 

per hour for Power Boiler 4.

Conditions 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 because 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 deleted. 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 added to the permit. The condition describes as an excess emission any 12-hour 

period during which the average H2S 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. The condition describes as an excess emission any 12 month 

period during which the emissions of SO2 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 NOX 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 excess emission any 3-hour 

period during which the average NOX emission rate from Package Boiler 2 is equal to or in excess of 30 ppm during 

May 1st through September 30th. This is a requirement of Georgia Rule (lll).

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

rolling period during which the average NOX 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 determined in accordance with Condition 4.2.25.

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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 SO2 emissions are in excess of 1,170 tons. This is a PSD Avoidance limit.

Condition 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 SO2 emissions from Waste Fuel Boiler WF are in excess of 0.80 pounds per million 

BTU. This is a limit under Georgia 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 criteria 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 Island.

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 condition.

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 the 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.

Condition 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.

Condition 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 permit. 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 any unit operating 

day that wastewater sludge combustion in Waste Fuel Boiler WF exceeds 30 tons. This is a PSD Avoidance limit.

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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 mercury 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 

establish 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 emissions 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 continuous 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 will 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 establish 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 Boilers 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 Power 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 performance 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 

compliance 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 asurance 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 provides 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 average 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.

Condition 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.

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PSD Preliminary Determination Page 47 of 49 

Condition 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.

Condition 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 record 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 include 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 

emissions.

Condition 6.2.26 has been modified. The condition requires the facility to calculate SO2 emissions from Power 

Boiler 4 (reference to Power Boilers 1 through 3 has been removed). The calculations are necessary to determine 

compliance with the SO2 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.

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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 assurance 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 

implement 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 permit. 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 the 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 requires 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 sitespecific 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 records 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 complies 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 notifications for the 

start up of Waste Fuel Boiler WF as required by 40 CFR 60 Subpart A and 60.49b(a).

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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 show 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 sample 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 limit 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 records 

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 SO2 CEMS to calculate the SO2 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 condition 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 information 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 Activities 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 increased from 20 to 21.

148
PSD Preliminary Determination

APPENDIX A

Draft Revised Title V Operating Permit Inland Paperboard and Packaging, Inc. – Rome Linerboard Mill

Rome (Floyd County), Georgia

149
PSD Preliminary Determination

APPENDIX B

Inland Paperboard and Packaging, Inc. – Rome Linerboard Mill

PSD Permit Application and Supporting Data

Contents Include:

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

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PSD Preliminary Determination

APPENDIX C

EPD’S PSD Dispersion Modeling and Air Toxics Assessment Review

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Michigan Department of Environmental Quality Files 

Mead Corporation – Escanaba Paper Company 

Excerpt from Permit Review for Permit No. 40422 

 

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Oklahoma 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) PSD 

 

203
OKLAHOMA 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 outheast 

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 (M2)(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 existing spent liquor mix tanks. 

• Enhancements to the evaporator area.

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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 ssolving 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 steam 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 NCGs 

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 washing 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 mill 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. 

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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 achine 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 has 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 Production 

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 scrubber also results in a reduction in SO2 emissions. Exhaust gases are emitted 

to the atmosphere through a dedicated stack. 

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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 concentrated 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 liquor 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 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 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 material, 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 from 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 oxidize the collected 

NCGs/SOGs.

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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 Bins 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 ailroad 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 Treatment 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 materials 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.

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 6 

VALLIANT MILL FUNCTIONAL AREAS

 

 

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)

Functional Area C – Paper Making

D1 - Bark Boiler (decommissioned)

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 (proposed)

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(proposed)

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 Stormwater 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 Areas

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PERMIT 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 Digester 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 steaming 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 in 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 

materials, 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, which 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 rejects 

are pressed to remove water, then may be l andfilled, transferred off-site, or t ransferred to a 

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PERMIT 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 of 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 ource 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 Makedown 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 introduced 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 and 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 NCG

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PERMIT 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 hests (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 headboxes. 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 

various 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 unit, and a CFB Boiler will be 

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PERMIT 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 system 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 through 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 as, 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, existing 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 steamgenerating 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. 

Functional 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-condensable 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 remaining 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 11 

water. The water is drawn off and sent to the steam stripper or the sewer. The turpentine 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 proposed 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 he 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 

processed 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 evaporate 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 capacity 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 burning 

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. The 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 project; however, it will be 

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PERMIT 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 combusting NCGs/SOGs. 

In addition to burning spent liquor and combusting NCGs/SOGs, the Recovery Furnace also 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 xhaust 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 Tanks (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 emissions 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 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 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 liquor 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 (principally 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 13 

calcium carbonate). 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 Lime 

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 landfilled 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 

function 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 vessels 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). 

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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 received 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 transferred 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 (EUGs 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. Fuel 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 pile 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 15 

Facility Traffic (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 dust 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 materials 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, Aerated 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 Dewatering 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 treams 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 

primary 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 combines 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 H2S.

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 he 

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PERMIT 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. 

Wastewater 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 effluent 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 (H2S) 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 feed 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 hermal 

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 released 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).

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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 back 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 emissions, 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 pulped. 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 nature. 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 off-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 and 

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 trucks 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 chip 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 following page.

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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 being 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 

(CFB 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 

#2 Steaming Vessel (Planned)

#2 Digester

#2 Surge Tank

Primary Flash 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 

#3 Steaming Vessel (Planned)

#3 Digester

#3 Surge Tank 

Primary Flash Tank

Secondary Flash Tank

221
PERMIT 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 1990/2005 (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 Lightweight Rejects Handling System

Emission Point EU Name/Model Construction Date

A8 

(baghouse stack) 

OCC Lightweight Rejects Handling System 1990/2001/2005 

OCC Lightweight Rejects Receiving Bin (planned)

EUG B1 – No. 1 Brownstock Washing Area

Emission 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 Point 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)

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 20 

This unit is a “semi-chemical” operation. It is therefore 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 semichemical operation, but pulp washing is defined in 40 CFR 63.441 to be a HVLC operation. 

EUG C1 – No. 1 Paper Machine (Stock 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 Construction Date

C2,A Fourdrinier Pre-1972/1990/ 

C2,B Vacuum Pumps/ Vacuum Flume 1996/2005 (planned) 

C2,D Press Section

C3,A Dryer Section

The “Fourdrinier” operation refers to a rotating cylindrical wire mesh screen used for draining 

water from pulp. 

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 

C5,B Press Section (planned) 

C5,D Vacuum Pumps/ Vacuum Flume

C6,A Dryer Section

EUG C7 – No. 3 Paper Machine (Stock Preparation)

Emission Point EU Name/Model Construction Date

C7 No. 3 Paper Machine (stock preparation) 1981 / 2002 /2005 

(planned)

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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 

C8,B Press Section (planned) 

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 Confidential 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 – Package 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)

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 22 

EUG E1 – Turpentine 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 

No. 2 Evaporator Hotwell / 2000

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 Liquor 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)

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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 Dissolving 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 Construction 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 Point 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 he 

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PERMIT 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 Construction 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 tanks; 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 1970

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PERMIT 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 Traffic 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 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 F3b – Wastewater Treatment System

Emission Point EU Name/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 Aerated 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 1991

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PERMIT 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 hermal 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 1998

ADS-2 Air Density Separator 1998

F9 Chip Conditioner 1998

229
PERMIT 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 Condensate 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 Basin 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 reciprocating 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 generators totaling 250 kW (310 HP) located at the facility. 

 

230
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 uel 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 water 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. 

- Hazardous 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 sewer 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 mical, 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 than 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 ctivities 

231
PERMIT 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 applied 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 default 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. 

232
PERMIT MEMORANDUM 97-057-TV 30 

PROJECT CRITERIA POLLUTANT EMISSIONS SUMMARY AFTER THE MODIFICATIONS

Discharge

Point

Operation PM10 CO SO2 NOx VOC TRS Lead H2SO4

lb/hr TPY lb/hr TPY lb/hr TPY 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 

Washing 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 1,351.7 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 -- -- -- --

E5 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 -- -- -- --

233
PERMIT MEMORANDUM 97-057-C (M-4) PSD 31 

PROJECT CRITERIA POLLUTANT EMISSIONS SUMMARY AFTER THE MODIFICATIONS – CONTINUED

Discharge

Point

Operation PM10 CO SO2 NOx VOC TRS Lead H2SO4

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 Tall 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 2,447 1,549 1341 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 device (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 

Furnace

234
PERMIT 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:

• Technical 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 –dated 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.

MILL DATA

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 Valliant 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 were 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 does 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, 

except 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. 

235
PERMIT MEMORANDUM 97-057-C (M-4) PSD 33 

TOXIC AIR POLLUTANT EMISSIONS SUBJECT TO SUBCHAPTER 41

Toxic CAS 

Number

Category Emissions De Minimis >De 

lb/hr TPY lb/hr TPY Minimis 

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-Dibromoethene 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-pdioxin1746016 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 4.54E-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 chrysene 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

Acetophenone 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 7664417 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 100527 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

Benzo(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 No

236
PERMIT MEMORANDUM 97-057-C (M-4) PSD 34 

FACILITY WIDE TOXIC AIR POLLUTANT EMISSIONS – CONTINUED 

Toxic CAS 

Number

Category Emissions De Minimis >De 

lb/hr TPY lb/hr TPY Minimis 

Beryllium 7440417 A 3.96E-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 7440439 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

Chlorobenzene 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

Chrysene 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 0.00E+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 50000 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

Hexachlorobiphenyl 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+00 0.00E+00 5.6 6.0 No

237
PERMIT 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-05 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

Methyl 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 varies 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 No

238
PERMIT MEMORANDUM 97-057-C (M-4) PSD 36 

TOXIC AIR POLLUTANT EMISSIONS – CONTINUED 

Toxic CAS Number Category Emissions De Minimis > De 

lb/hr TPY lb/hr TPY Minimis 

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-pdioxins1746016 A

0.00E+00 0.00E+00

0.57 0.6 No

Tetrachlorodibenzo-pfurans51207319 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 No

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-01 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 ting 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 modification 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, emissions 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 compute past actual emissions:

239
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 twoyear 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 emissions 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 

required 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 the 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 increases 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 (PM10), carbon monoxide (CO), sulfur dioxide (SO2), 

oxides of nitrogen (NOx), VOC, TRS, lead (Pb), and SAM (H2SO4).

240
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 ncreases 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 below.

241
PERMIT MEMORANDUM 97-057-C (M-4) PSD 39 

Total Emission Increases and Decreases 

Operation PM10 CO SO2 NOx VOC TRS Lead H2SO4

* 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 58.1 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 

131.5 299.2 167.7 167.9 407.3239.4 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 Tank - - - - - - - - - - - - 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 Kiln 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 change

 

242
PERMIT MEMORANDUM 97-057-C (M-4) PSD 40 

Total Emission Increases and Decreases Continued

Operation PM10 CO SO2 NOx VOC TRS Lead H2SO4

* 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

- - - - - - - - - - - - 103.3 441.8 338.5 119.6 119.6 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 operation 

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 1.29 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

 `

243
PERMIT MEMORANDUM 97-057-C (M-4) PSD 41 

Emissions Increases from the Proposed Project

PM10 CO SO2 NOx

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 YES 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, PM10, CO, SO2, NOx, 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 project 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 following 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 backup 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.

244
PERMIT MEMORANDUM 97-057-C (M-4) PSD 42 

Project Net Emissions Change

In order to determine the total 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 

considered creditable changes. 

Net Emissions Change from the Proposed Project

PM10 CO SO2 NOx

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

The 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, PM10, CO, SO2, NOx, TRS, and Pb do not exceed their respective 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 backup 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 implementing 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 modification 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 technologies 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. 

245
PERMIT MEMORANDUM 97-057-C (M-4) PSD 43 

BACT APPLICABILITY BY POLLUTANT AND EMISSIONS UNIT

Unit Description 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 equirements 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 which 

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 Radiation, 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 through 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. 

246
PERMIT MEMORANDUM 97-057-C (M-4) PSD 44 

CFB Boiler BACT Analysis

SUMMARY OF ANTICIPATED MAJOR CFB BOILER DESIGN PARAMETERS

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 O2 to S O3 and i ts 

subsequent reaction with water; less than 3% of the SO2 is oxidized to SO3. In the boiler stack, 

all of the S O3 formed i s e xpected t o c onvert t o s ulfuric acid mist. SO2 and S O3 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 technologies 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 reduction potential.

POTENTIAL CONTROL TECHNOLOGIES FOR THE CFB BOILER

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 of SO2 in free (i.e., liquid phase) water. Therefore, in order to 

control emissions of SAM, emissions of SO2 must be controlled. The remainder of this analysis 

focuses on controlling emissions of SO2. 

247
PERMIT MEMORANDUM 97-057-C (M-4) PSD 45 

Because of the acidic nature of SO2, existing sulfur dioxide control technology is primarily based 

on a lkaline s crubbing s ystems. S crubbers r emove S O2 formed dur ing c ombustion by us ing 

various alkaline agents to absorb SO2 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 

fluidized 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 CO2. The lime then reacts with SO2 to form 

calcium s ulfate, a s olid (CaSO4). 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 SO2 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 crubbers 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 SO2 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 O2 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 SO2 inlet concentrations (because of the inherent SO2 control 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 SO2 (U.S. EPA, “Air Pollution Control Technology Fact 

Sheet; Flue Gas Desulfurization”, EPA-452/F-03-034, p. 2) . The SO2 control efficiencies 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 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.

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 46 

U.S. EPA COST DATA FOR WET SCRUBBERS ON SMALL BOILERS (<2,000 MMBTU/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 ystem 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 chamber. 

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 stream, the alkali droplets are allowed to 

react w ith the S O2 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 system and provides additional contact between the dried reactants 

and SO2 contaminants. 

The combination of s pray s ystem and particulate r emoval i s abl e t o achieve S O2 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 O2 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 SO2 inlet concentrations (because of the inherent SO2 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 absorber on t he CFB Boiler. C ost information was obtained from recent U.S. EPA data 

used to calculate costs for controlling SO2 ( U.S. EPA, “Air Pollution Control Technology Fact 

Sheet; Flue Gas Desulfurization”, EPA-452/F-03-034, p. 2) . T he SO2 control efficiencies 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. 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 47 

U.S. EPA COST DATA FOR SPRAY DRYERS ON SMALL BOILERS (<2,000 MMBTU/HR) 

Cost Range

Parameter Low 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 SO2 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 

varieties. 

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 O2 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 ppropriate 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 SO2, 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. 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 48 

Good Combustion Practices 

Good c ombustion pr actices i nvolve pa rametric monitoring and controlling 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 ensured 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, the 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 SUMMARY FOR THE CFB BOILER

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)0.005 lb/MMBtu (Weyerhaeuser fiscal month average) GCP

 

Lime Kiln BACT Analysis

SUMMARY OF ANTICIPATED MAJOR LIME KILN DESIGN PARAMETERS

Parameter Value

Heat Input (TSI)

Primary Fuel Petcoke/Natural Gas

Average Petcoke Sulfur 

Content

5% 

Lime Kiln Control 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. Consistent 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.

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 49 

POTENTIAL CONTROL TECHNOLOGIES FOR THE LIME KILN

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 O2 is 

oxidized to SO3 and hydrated to form H2SO4. The removal mechanisms for SAM are the same 

as for SO2, with each control technology providing similar efficiencies for both SO2 and SAM. 

Therefore, the remainder of this analysis is focused on SO2 control technologies. 

Lime Kiln Scrubbing 

The ability of lime and/or limestone to scrub SO2 from the exhaust gas. Since the Lime Kiln 

contains a large quantity of lime , significant a mounts of S O2 are s crubbed f rom t he e xhaust 

stream. The effectiveness of the SO2 removal is estimated at up to 98% (NCASI, “Technical 

Bulletin 646, E mission F actors f or N Ox, S O2 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 O2 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 SO2 emissions. H owever, the presence of lime in the Lime Kiln 

means that SO2 emissions are relatively insensitive to fuel sulfur content. Therefore, the use of 

low sulfur fuel is likely to have minimal effect on SO2 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 averaged on a 

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PERMIT 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 concentrations of S O2, 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, facility that was never built. Therefore, the proposed BACT limit is at the 

low end of the remaining BACT entries in the RBLC). 

Summary

BACT SUMMARY FOR THE LIME KILN

Pollutant Emission Limit

Control 

Technology

SAM

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) GCP

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 51 

Pollutant Formation Processes 

The formation of SO2 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 Furnace 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 Furnace 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. 

POTENTIAL CONTROL TECHNOLOGIES FOR THE RECOVERY FURNACE

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 O2 must be c ontrolled. T herefore, t he 

remainder of this analysis focuses on controlling emissions of SO2. 

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 Recovery F urnace. W eyerhaeuser conc ludes 

that the use of a wet scrubber on the Recovery Furnace is not technically feasible.

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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 successfully 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 olids 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 higher bed temperature improves reduction of sulfur 

in the Recovery Furnace and, thus, lowers SO2 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 ecovery 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 SO2

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 O2 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 practice 

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. 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 53 

Catalytic Oxidation

Catalytic ox idation w as di scussed pr eviously i n Section. Catalytic 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-Direct 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 indicate 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 additional 

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 ppropriate 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 SUMMARY FOR THE RECOVERY FURNACE

Pollutant Emission Limit Control Technology

SAM 0.5 ppm @ 8% O2 (Weyerhaeuser fiscal month 

average)

GCP

VOC (as 

carbon) 

40 ppm @ 8% O2 (Weyerhaeuser fiscal month 

average) Staged Combustion / 

NDCE

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 54 

Paper Machines BACT Analysis

Pollutant 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 water 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 aids, 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 

substitute 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 technologies for VOC emissions from the 

paper machines.

POTENTIAL CONTROL TECHNOLOGIES FOR THE PAPER MACHINES

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 beds 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 

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” annualized cost of greater than $20,500,000 ( using $20.5/ scfm, t he m iddle of t he 

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PERMIT 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 Ox. V OC f rom paper 

machines are al so difficult t o capture, 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 economically 

feasible and has adverse e nvironmental i mpacts, ba sed on t he a dditional g eneration of N Ox

emissions. 

Catalytic Oxidation

Catalytic ox idation is s imilar to thermal ox idation for control of VOC emissions from paper 

machines and can achieve similar 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 specific 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 particulate 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 stripped 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 from 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 56 

the paper machines is at or near saturation 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 the 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 machines 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 nalyses 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 chnology 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 CO2 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 

approximately 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 flow 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 biofilter 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 not technically feasible. 

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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 remove 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 respect 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 will 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 nfeasible, 

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 the 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. 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 58 

POTENTIAL CONTROL TECHNOLOGIES FOR OCC PLANTS

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 

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 

concentrations 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 would emit between approximately 123 a nd 370 t on/yr NOx. 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 Ox

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 typically 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 addition, 

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 the capi tal cos ts. T hus, catalytic 

oxidation is considered economically infeasible. 

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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 

before. 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 no 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 ompliance 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 

concentration expressed in either m icrograms pe r cubi c m eter [ μg/m3

] or pa rts pe r m illion by 

volume [ppmv]) 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 μg/m3 or ppmv). 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 Method 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). 

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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 NOx emissions f rom t he f acility. T he l ookup tables have been validated for 

NMVOC/NOx 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/NOx ratios 

less than 2:1 result in no significant i ncrease i n oz one ( Texas C ommission on E nvironmental 

Quality (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 /NOx 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/NOx ratio will be 

less t han 1.17: 1. A s t he N MVOC/NOx ratio is less tha n 2:1, the V alliant M ill is c onsidered 

NOx-dominated, a nd t he N MVOC/NOx 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 area. 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 cause 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 harmful 

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). The 

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PERMIT 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 cropland. 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 Valliant 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. Therefore, 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 sources w ill c ontribute to significant vi sibility 

impairment. The proposed project will not result in a net emissions increase of NOx, SO2, PM, 

or PM10. 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) Air Quality 

Related Values (AQRVs). Class I Increment modeling is explicitly required by U.S. EPA under 

the PSD program and is reviewed for approval by the state permitting agency. Class I Areas have 

a s eparate s et of P SD I ncrements f or P M10, S O2, a nd N Ox 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 PM10, S O2, a nd N Ox. 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 to 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 Area

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PERMIT 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 requirements.

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, Subpart 

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]

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 pol lutants. W eyerhaeuser w ill s ubmit r equired a nnual e missions i nformation ( 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 the 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 

individual 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 requirements 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) 

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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 combustible 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 ineration 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 process 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 except 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. Emission 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 fugitive 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 terials 

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PERMIT 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 (SO2) 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 SO2 standards. 

COMPLIANCE WITH SO2 AMBIENT IMPACTS LIMITATIONS

Averaging Period Ambient SO2 Impacts 

Limitation, ug/m3

Modeled SO2 Impacts, 

ug/m3

3-Hours 650 299

24-Hours 130 104

Part 2 also limits H2S 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 specifies 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 H2S on a dry 

basis)

TRS Emission Rate Test 

Results

Recovery Furnace 40 ppm @ 8% O2 24.6 ppm @8% O2 (1989)

Lime Kiln 40 ppm @ 10% O2 31.3 ppm @10% O2 (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 (constructed 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 O2 emission rates ar e m uch 

more stringent than Subchapter 31 limits.

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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 Subchapter 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 gallons 

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 rated 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 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 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. 

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PERMIT MEMORANDUM 97-057-C (M-4) PSD 66 

COMPLIANCE WITH OAC 252:100-41

Toxic Ambient 

ImpactsA ug/m3

MAACB

ug/m3

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

Chloroform 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 Maximum 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 Listing 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 formaldehyde.

269
PERMIT MEMORANDUM 97-057-C (M-4) PSD 67 

REFINED DISPERSION MODELING RESULTS FOR

FORMALDEHYDE 

Meteorological Year Maximum Impact (μg/m3) 

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 

formaldehyde emissions are less than the corresponding MAAC of 12 μg/m3. 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 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 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 exclusive 

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 landfill

270
PERMIT 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, SO2, PM10, and VOC. Any future increases must be evaluated in the context of 

PSD significance levels: 40 TPY NOx, 100 TPY CO, 40 TPY SO2, 15 TPY PM10, 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 pecified 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 heat 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 O2, 0.10 l b/MMBTU P M, a nd 0.3 l b/MMBTU N Ox. CEMS systems m easuring 

opacity, NOx, SO2, and a diluent gas (CO2 or O2) 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 SO2, 0.10 l b/MMBTU PM, and 0.20 l b/MMBTU NOx. CEMS 

systems m easuring N Ox, SO2, and a di luent g as ( CO2 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 

minimis 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 ssolving 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 concentrator 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 pollution 

271
PERMIT 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 compliance 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): breaking, 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, limiting 

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 lowvolume-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 

oxidizer. 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 April 17, 2006, to achieve 

272
PERMIT 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 addition 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 secondary 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 affects 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. Initial 

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 ombustion 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 Register 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 ts 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/. 

273
PERMIT MEMORANDUM 97-057-C (M-4) PSD 71 

Stratospheric 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) 

vehicles 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. 

SECTION 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 24th 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 anager 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 certifies 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 comments 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) 

274
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 fuel 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-specific 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 actually 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 this 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 a 

275
PERMIT 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 SO2

must be controlled. Therefore, the applicant focused on controlling emissions of SO2. High 

solids firing was 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 SO2 

emissions “Factors that influence SO2 levels are liquor sulfidity, liquor solids content, stack gas 

O2, furnace load, auxiliary fuel use, and furnace design. None of these factors has exhibited a 

consistent relationship to SO2 emissions (p. 789).” Obviously there are a number of factors that 

need to be considered regarding sulfur emissions from this 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-depth evaluation of current Kraft Recovery furnace designs reveal that high 

solids firing is key to consistently achieve very low SO2 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 iquor 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 H2S released during char pyrolysis. The latter results 

from the e quilibrium in the H2S c apture r eaction shifting to the r ight w ith increasing 

temperatures, as given by the equation: 

 Na2CO3 + H2S = Na2S + H2O + CO2 

All SO2 originates in the furnace first as H2S, released during char pyrolysis. The H2S is oxidized 

to S O2 in t he uppe r ox idizing z ones. H ence, a r eduction i n H 2S r eleased would lead to 

comparably l esser S O2 emissions. T he S O2 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 increase of PM10, SO2, and NOx, 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. 

276
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 M10, S O2, a nd N Ox 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 

compliance or enforcement issues concerning this facility which would prohibit issuance of this 

permit. Issuance of the modified construction permit is recommended. 

277
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 equirements 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 Applicable 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 particular 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 commencement 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, 40 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] 

278
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 VOCA

lb/hr B TPY C

E-A4, C No. 1 OCC Plant

A5 No. 2 OCC Plant 9.28 36.89 

A7 No. 3 OCC Plant 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.-D.-1 shall be demonstrated monthly based on 

Weyerhaeuser fiscal calendar month operating rate records and 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 PM10

lb/hr A TPY B

E-A8,A OCC Lightweight 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.

279
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 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. 

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 

1st Stage Brownstock Washer 21.67 87.60 5.80 23.43 2nd 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 calendar 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)]

280
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

Vacuum Pumps/ Vacuum Flume 115.05 419.93 

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. Compliance 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 with 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 Machine (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 C

281
SPECIFIC 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 Vacuum 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 Specific 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 / PM10 CO SO2 NOx

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 H2SO4

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 

periods 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 Boiler

282
SPECIFIC 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)]

Emission 

Point

EU Name/ 

Model

PM / PM10 CO SO2 NOx

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 H2SO4

lb/hr B TPY C lb/hr B TPY 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

H2SO4 0.0012 lb/MMBtu (Weyerhaeuser fiscal month average)

0.0021 lb/MMBtu (daily average)

CFB Boiler with Limestone Injection

VOC (as carbon) 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, SO2, VOC, Lead, and H2SO4 limits shall be demonstrated 

monthly with monthly operating rate records and emission factors developed based on 

the ini tial pe rformance t est. C ontinued c ompliance w ith t he N Ox and P M / P M10

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 regulations: 

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 Oxidizer 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. 

283
SPECIFIC CONDITIONS 97-057-C (M-4) PSD 7 

O. EUG E2a – Spent Liquor Concentration

1. NCG’s from the 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. Compliance 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 / PM10 CO SO2 NOx

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 TRS Lead H2SO4

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. 

284
SPECIFIC CONDITIONS 97-057-C (M-4) PSD 8 

Pollutant Emission Limit Control Technology

H2SO4 0.5 ppm @ 8% O2 (Weyerhaeuser fiscal month average) GCP / High Solids Firing

VOC (as carbon) 40 ppm @ 8% O2 (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 M10, CO, NOx, V OC, Lead, a nd H2SO4 limits s hall be 

demonstrated m onthly w ith m onthly ope rating r ate r ecords and emission factors 

developed based on the initial performance test. Continued compliance with the TRS 

and S O2 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 comply 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 month.

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; and 

285
SPECIFIC CONDITIONS 97-057-C (M-4) PSD 9 

c. Federal NESHAP for Source Categories, 40 CFR 63, Subpart 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 / PM10 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 month.

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 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.-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)]

286
SPECIFIC CONDITIONS 97-057-C (M-4) PSD 10 

Emission 

Point

EU Name/ 

Model

PM / PM10 CO SO2 NOx

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 H2SO4

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 with the following BACT requirements. 

Pollutant Emission Limit Control Technology

H2SO4 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 M10, CO, NOx, V OC, L ead, a nd H 2SO4 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 SO2 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.

287
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 PM10 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 Material 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 2005 (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.

 [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

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 operation. 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.

288
SPECIFIC CONDITIONS 97-057-C (M-4) PSD 12 

AA. EUG F4a – NCG 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 specified 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 / PM10 CO SO2 NOx

lb/hr B lb/hr B lb/hr B lb/hr B

F4 Thermal 

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 PM10

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.

289
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 

following emission limits. [OAC 252-100-8-6(a)(1)]

Emission 

Point

EU Name/Model VOC A PM PM10

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 Density 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 urnace, 

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 PM10

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 fiscal month basis and hours of operation. B 12-month rolling total based on Weyerhaeuser fiscal calendar month.

290
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 Causticizing 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-F1b) 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 Oxidizer (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 basis.

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 onditions 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: 

291
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 under 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. 

292
Weyerhaeuser Company

Attn: Kelly Folsom

2821 West &th Street

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 referenced 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 inspections.

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 1st of eve ry y ear. Any que stions c oncerning 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

293
PERMIT

AIR QUALITY DIVISION

STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100 

P.O. BOX 1677 

OKLAHOMA CITY, OKLAHOMA 73101-1677 

Issuance Date Permit No. 97-057-C(M-4) 

 Weyerhaeuser Company_________________________, 

having complied with the requirements 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

294
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 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 nvironmental Q uality ( DEQ). T he pe rmit doe s not relieve the holder of the 

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 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 

requirements) 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 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 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)]

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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 upon 

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, 

the 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 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 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)(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 Recordkeeping, 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)] 

296
STANDARD CONDITIONS 3

I. Any ow ner 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 contain 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 the 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 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 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 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 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)]

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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 sequence 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 applicable 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 permit 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)] 

298
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 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 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, 

reissuing, 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)] 

299
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, termination, 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 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 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 XVIII (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. 1998, § 2-5-105(18) 

for confidential information submitted to or obtained by the DEQ under this section): 

300
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 where 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 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 e mergency s hall be de monstrated t hrough pr operly s igned, 

contemporaneous operating logs or other relevant 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)]

301
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 emissions 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 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 more HAP's, or 20 percent of any threshold less than 10 tons per year 

for single HAP that the EPA may establish by 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 ohibited 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;

302
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 facility, 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 line 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 ide 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, 1974, 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-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] 

(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] 

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STANDARD CONDITIONS 10

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A.The permittee shall comply with the following standards for production and consumption of ozone-depleting 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) vehicles 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 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. [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 aintenance, 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 comply 

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. 

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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 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 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 requirements 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 construction 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 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 D EQ s hall not i ssue t he pr oposed c onstruction permit 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 the 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.

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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. 

306
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, David 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 45th 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 

Improvement 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 Introduction, 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 facility. After 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 tate 

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 pplication was w ithdrawn a fter s ubmittal of t he P art 70 a pplication, which 

included the equipment authorized by the construction permit. 

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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 into 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 

material. 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, requiring 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 products, 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, dilution 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 pulp 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 to 

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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, the 

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 no 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 nonemitting components will be physically altered. 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, 

washers, 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, PM14, 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 machines 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 quantity 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.

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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 the 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, manufactured 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 total. 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 water 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 emission 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 re 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 adjusting.

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.

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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-flap 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 corona 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 project 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 urrent 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.

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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 onsite 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 

natural 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 baghouse 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 rule 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 facility 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 approximate 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 by 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 

Generators for Which Construction is Commenced After August 17, 1971). 

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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-24089 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 second 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 Oven-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 Electric, 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, including 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, 

including 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, because t here are no physical 

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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 units 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. Emissions 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 MACT 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) 1977, 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 

1980

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Flexo 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 6/05

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EUG 6 – VOC 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 an 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 – VOC 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 1975-1992

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, 78” 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 1992

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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 emissions 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 ollowing tables condense information available in t he m emorandum a ssociated w ith t he 

pending Part 70 permit. Fuel oil data is excluded here, since the facility states that it no longer has 

the ability to burn oil. There are no changes contemplated for these boilers and these tables will not 

be used to support analysis of PSD significance.

Boiler Descriptions

EU 

ID

Rating 

(MMBTUH)

Firing Configuration Controls Low 

NOX

Fuels

B-1 310 Forced Draft Package None No Gas

B-2 440 Wall Fired Electrostatic Precipitator 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 Emissions

B-1: 310 MMBTUH

PM NA NA 7.6 lbs/MMCF(4) 12.4 (1)

NOX NA NA 0.115 lbs/MMBTU(3) 187 (1)

SO2 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

H2SO4 NA NA NA NA

HF NA NA NA NA

B-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)

NOX 0.43 lbs/MMBTU(3) (Hi Btu Coal) 994 (1)

190 lbs/MMCF(6) 366 NOX (Lo Btu Coal) 0.319 lbs/MMBTU(3) 738 (1)

SO2 (Hi Btu Coal) 0.644 lbs/MMBTU(3) 1,489(1)

0.6 lbs/MMCF(4) 1.39 (1)

SO2 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)

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COAL NATURAL GAS

Emissions Factor Emissions Emissions Factor Emissions

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)

H2SO4 (Hi Btu Coal) 0.001 lbs/MMBTU(3) 2.31 (1)

NA NA H2SO4 (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)

SO2 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 lbs/MMBTU(3) 87.8 (1) NA NA

H2SO4 0.003 lbs/MMBTU(3) 8.78 (1) NA NA

HF 0.001 lbs/MMBTU(3) 2.93 (1) NA NA

B-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

SO2 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

H2SO4 0.004 lbs/MMBTU(3) 11.7 (1) NA NA

HF 0.001 lbs/MMBTU(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 NOX SO2 VOC CO HCl H2SO4 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 otherwise

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Establishing the a ctual-to-potential increase in emissions for P SD a nalysis is di fficult w ith 

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 emission 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 icant 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 equivalent 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 SO2, NOX, and PM10 are maximum allowables from Subpart D 

and/or Subchapters 19, 31, and 33. All others are footnoted. The second table shows additional 

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

SO2 1.20 0.2

NOX 0.7 0.2

PM10 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 testing 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) 

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B-1 (Gas) B-2 or B-3 (Coal) B-4 (Coal/Gas) Maximum

SO2 64.4 386 386 386

NOX 64.4 225 225 225 

PM10 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 SO2, PM10, 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 PM10 factor used is that for total PM. F actors for NOX 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 scussion 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 calculate 

combustion emissions from the paper machine hood burners. 

Machine No. Pollutant Emission Factors (Lbs/MMBTU)

SO2 PM10 VOC Lead NOX CO

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 93,679 438,000

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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 calculated from these tables by assuming continuous 

operation and dividing by 8,760 hours per year. 

SO2

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 

Change 0.18 0.15 0.16 0.18 0.12 0.80

PM10

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

NOX

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 75.8 405

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Burner Combustion Emissions Summary - TPY

SO2 PM10 VOC Lead NOX CO

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

SO2 PM10 VOC NOX CO

Existing dryer 0.01 0.07 0.05 0.88 0.74

Dryer #2 (new) 0.01 0.11 0.08 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 0.03 0.39 0.28 5.08 4.27

Increase 0.03 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 

NOX. T he manufacturer has supplied NOX 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 more 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

Combustion Emissions (TPY)

SO2 PM10 VOC NOX CO

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 98.6% 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 98.6%, 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 ssuming 

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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 

summarizes 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 NOX SO2 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 13.9 198 1.10 58.6 530 8.67 × 10-4

Increase 10.7 153 0.86 -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 calculating 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. 

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EUG 3 –Coal Preparation Plant 

EU Name Particulate Matter 

Emission Factors 

(lbs/ton coal)

PM Emissions (TPY)

2003 Actual PTE

Railcar Unloading

Radial Stacker 0.0859 22.3 35.2 

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

Pulverizers No emissions

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

Emissions 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, VOC Sources 

Not Subject to an NSPS or NESHAP, and are not repeated here.

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

PP-1 Pulp Processing Units

Emission factors for these units were developed in a comprehensive emissions testing program 

by The National 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 and 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 lbs 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.

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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 

Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15 

Various methods have been used in the past to calculate emissions of VOC from chemicals used 

at the paper machines. One method used a site-specific evaluation by NCASI. Emissions from 

building vents and equipment 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 calculations 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 incipal 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 worstcase results have been combined to produce a ratio, or emission factor, for all VOC as a function 

of paper production. B ecause of the uncertainty 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. 

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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 year

**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 used 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 and 

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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 inventory 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 analyze 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 the 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 melting 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 

2003 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 from 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 41.5 280.0 238.5

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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 amount 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 estimated 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 hree 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 -12.6 

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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 concentration 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 

lbs/ton a nd 2003 us e w as a pproximately 0.031 l bs/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 bs/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 bs/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 Printer 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 lbs/hr of non-combustion 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 lbs/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.

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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 calculated 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 following 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 reases 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 NOX CO SO2 PM10 VOC Other

1 225 27.0 386 32.2 1.77 H2SO4 - 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 O3 – 9.6 (included in VOC total)

7 22.2

Totals 377 437 387 114 487 H2SO4 - 5.47, Lead – 0.0026

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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 single 

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 ing 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-August 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 missions 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. 

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NOx CO VOC

1999

TPY

Model

TPY

1999

TPY

Model

TPY

1999

TPY

Model

TPY

Boiler -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 Dryer- 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 inventory (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 facility. 

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 cause or significantly contribute to a violation of the 8-

hour standard. 

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Point Source Modeling

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 application 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 

undergo 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 proposed 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 applicant 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 and 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 Analysis.

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.

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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 pares 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-highest 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 locations. 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 analyses 

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 topography 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 predict 

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 processing 

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PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD)

 

29

D.2.3 LAND USE CLASSIFICATION

Dispersion coefficients are set in the model by selecting 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 assifications. 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 

miles t o t he northwest. 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 emperature, 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 easurements 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 located 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 threshold 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.” 

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PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD)

 

30

The E PA G uideline f or D etermination of Good Engineering P ractice S tack Height1 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. 

HGEP = HB + 1.5 L, where 

HGEP = GEP formula stack height 

HB = 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: 

HGEP = 2.5 HB

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 

nearby 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 modeling. 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 Section 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 excluded 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 8.53

336
PERMIT 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 #18 159.2 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 #41 161 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 COOLING TOWER S 160.1 12.19

COOLST COAL PILE SHORT TERM 162 15.24

337
PERMIT 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 Bldg 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 impact 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/m3)

De Minimis Concentration 

(μg/m3)

PM10 24-hour 5 10

Annual 1 --

NO2 Annual 1 14

SO2 3-hour 25 --

24-hour 5 13

Annual 1 --

CO 1-hour 2,000 --

8-hour 500 575

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PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 33 

Model Inventory

For the significant impact analysis, the 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 increase 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 presents the baseline 

emissions, potential e missions a nd computes the di fference in particulate ma tter ( PM10) 

emissions from the modified project sources. 

Table D-4 PM10 Significant Impact Analysis Emiss. Rates

Model ID Source Description

Baseline 

(TPY)

Potential 

(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

PM 11Yankee Wet End Exh. - burner 0.26 1.40 2.17 0.062 

PM 11 Yankee Wet End Exh. - total 1.42 3.59

1112_7 

PM 11 Yankee Dry End Exh. - process 1.16 2.19

PM 11Yankee Dry End Exh. - burner 0.26 1.40 2.17 0.062 

PM 11 Yankee Dry End Exh. - total 1.42 3.59

1112_20 

PM12 Yankee Exh -process 3.71 6.13

PM12 Yankee Exh -burner 0.90 2.80 4.32 0.124 

PM12 Yankee 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 Building 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 0.0039

339
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 34 

Table D-4 PM10 Significant Impact Analysis Emiss. Rates

Model ID Source Description

Baseline 

(TPY)

Potential 

(TPY)

Project

(TPY)

Project

(g/s)

Paper Machine 13

13_13 

Yankee Economizer - burner 0.729 2.796

Yankee Economizer - process 3.406 5.256 3.92 0.113 

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 Roof 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

Yankee Wet End Exh. - process 1.803 2.628 1.968 0.057 

Yankee Wet End Exh. - total 2.058 4.026

14_17 

Yankee Dry End Exh.burner 0.255 1.398

Yankee Dry End Exh.process 1.803 2.628 1.968 0.057 

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 0.004

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. - burner 0.214 0.999

Yankee Wet End Exh. - process 1.778 2.420 1.427 0.041 

Yankee Wet End Exh. - total 1.992 3.419

15_18 

Yankee Dry End Exh.burner 0.214 0.999

Yankee Dry End Exh.process 1.778 2.420 1.427 0.041 

Yankee Dry End Exh. total 1.992 3.419

15_11 Riffler Roof Exhaust 0.20 0.28 0.074 0.002

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PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 35 

Table D-4 PM10 Significant Impact Analysis Emiss. Rates

Model ID Source Description

Baseline 

(TPY)

Potential 

(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 0.0035

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 Pile 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 PM10 emission increase attributable to the project for 

steam is 2.0 grams/sec. The emission rate reflects the permit limit of 0.1 lbs/MMBtu. The analysis to determine 

project impact divided these emissions equally between the two stacks.

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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 

carbon monoxide, respectively. 

Table D-6 

Model ID Source Description

Annual Fuel Usage 

(MMBTU)

SO2 Emission Rates for Significant Impact 

Analysis

Baseline

(TPY)

Potential 

(TPY)

Project

(TPY)

Project

Baseline Potential (g/s)

Modified Sources

1112_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 0.017 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 MBtu/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 lbs SO2/MMBtu x 454 g/lb x hr/3,600s = 11.13 gram/s

Table D-7 

Model ID Source Description

Annual Fuel Usage 

(MMBTU)

NOX Emission Rates for Significant Impact 

Analysis

Baseline

(TPY)

Potential 

(TPY)

Project

(TPY)

Project

Baseline Potential (g/s)

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 MBtu/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 for these 

two cases. Total attributable emissions are equal to 73.5 MMBtu/hr x 0.7 lbs NOx/MMBtu x 454 g/lb x hr/3,600s = 6.48 gram/s.

342
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

Baseline Potential (g/s)

Modified 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 613200 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 for these 

two cases. Total attributable emissions are equal to 73.5 MMBtu/hr x 0.084 lbs 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 Description

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 Exhaust 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 1.22 

343
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 38 

Table D-9 

Model ID Description

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 Roof 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 After 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 Exhaust 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 1.07 

344
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 39 

Table D-9 

Model ID Description

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 Roof 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 model 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 0.2

345
PERMIT 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 receptor 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 

outside 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 were 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 NO2, SO2, 

and P M10. 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/m3) Form of Standard

PM10 24-hour 150 High-sixth-highest for 5 years

Annual 50 Annual Mean

NO2 Annual 100 Annual Mean

SO2 3-hour 1,300 High-second-highest for each year

24-hour 365 High-second-highest for each year

Annual 80 Annual Mean

Background 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 included 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).

346
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 41 

ODEQ r ecommended conservative 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/m3

) used for the analyses.

Table D-12

Pollutant Monitor and Data Description

Averaging 

Period

Background Concentration

(ppm) (μg/m3)

SO2

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

NO2 Tulsa - 2004 Annual Mean Annual 0.0054 10.2

PM10

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)

PM10 SO2 NOX

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 Exhaust 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 Building 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 -- --

347
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 42 

Table D-13

Model ID

Source Description

Emission Rates (g/s)

PM10 SO2 NOX

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 Exh. 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 Exh. Fan 0.012 -- --

14_21 Wall Exh. Fan 0.012 -- --

348
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 43 

Table D-13

Model ID

Source Description

Emission Rates (g/s)

PM10 SO2 NOX

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 Railcar 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 26.2 191.61a 150.23

(a) Muskogee M ill pr oposes to restrict tot al S O2 emissions f rom B oilers 1 t hrough 4 

combined to 191.6 grams/second.

349
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 significant 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 missions 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 NO2, PM10, and SO2, 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

Distance

From Mill

(km)

Direction

From Mill

(degrees)

Potential Emissions 

(lb/hr)

SO2 NO2 PM10

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 height set to 10 meters, vertical extent set to 10 m, initial vertical 

dispersion coefficient (σz) of m, lateral extent set to 5 m, and initial lateral dispersion coefficient 

(σy) set to 1.16 m or based on footprint of source area. 

350
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 45 

Table D-16 (page 1) 

Facility / 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)

SO2 NO2 PM10 Sig 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 Melting 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 0.214 10.1 0.4 294 19.1

Crushing (Primary,Secondary,Tertiary) 10118 0 0 0.214 10.1 0.4 294 19.1

351
PERMIT 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)

SO2 NO2 PM10 Sig 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) PM10 Emissions for all American Foundry Group sources modeled as a single source - 13673 

352
PERMIT 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 Group 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 SO2 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 receptors 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 NO2, SO2, 

and P M10. 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 oncentration 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/m3

) Form of Standard

PM10

24-hour 30 High-second-highest for each year

Annual 17 Annual Mean

NO2 Annual 25 Annual Mean

SO2

3-hour 512 High-second-highest for each year

24-hour 91 High-second-highest for each year

Annual 20 Annual Mean

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 ources 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 consume 

353
PERMIT MEMORANDUM No. 99-113-C (M-4)(PSD) 48 

increment. The Mill was constructed after the major source baseline date for SO2 and PM10, 1975. Thus, 

the N AAQS i nventory f or P M10 and S O2 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 NOX is March 1988. Table D-19 summarizes the NO2

emission calculations for increment-affecting emissions.

Table D-19 

Model ID Source Description

Source 

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 Yankee 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 heat 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.

354
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)

SO2 NO2 PM10 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 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 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 26.4

355
PERMIT 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 

(μg/m3)

Receptor 

Location UTM 

Zone 15 (m) Period Ending 

YYMMDDHH

Significant 

Impact 

Level 

(μg/m3)

Monitoring 

De minimis 

Conc., 

(μg/m3 East North )

1-hour 

High 1st 

High

1986 323 291715 3956388 86080904

2000 --

1987 318 291714 3956338 87090301

1988 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 291714 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 evel 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 NO2 impact out to approximately 4.5 km from the Mill. Table D22 presents the maximum predicted impacts from the significant impact analysis.

Table D-22

Averaging 

Period Year

Maximum 

Predicted 

Impact 

(μg/m3)

Receptor 

Location UTM 

Zone 15 (m) Period Ending 

YYMMDDHH

Significant 

Impact 

Level 

(μg/m3)

Monitoring 

De minimis 

Conc., 

(μg/m3 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 3.7

356
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 51

The maximum annual NO2 impact due to the project is above the SIL but below the monitoring 

de minimis c oncentration of 1 a nd 14 μg/m3

, respectively. T herefore, G-P pe rformed a ful l 

NAAQS analysis for NO2. 

Sulfur Dioxide 

By modeling the emissions that would result from the project, G-P determined that the project 

will have a significant SO2 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 

(μg/m3)

Receptor 

Location UTM 

Zone 15 (m) Period Ending 

YYMMDDHH

Significant 

Impact 

Level 

(μg/m3)

Monitoring 

De minimis 

Conc., 

(μg/m3 East North )

Annual 

Mean

1986 0.6 292300 3958000 --

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 3954600 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 90050924

1991 14.3 296500 3955000 91120306

The maximum 24-hour SO2 impact due to the proposed project is 5.3 μg/m3, which is above the 

SIL but below the monitoring de minimis concentrations of 5 a nd 13 μg/m3

, respectively. The 

maximum 3 -hour a nd a nnual ave rage i mpacts ar e be low t he r espective modeling significance 

levels. Therefore, G-P performed a full NAAQS analysis for SO2. 

Particulate Matter

By modeling the emissions that would result from the project, G-P determined that the project 

will have a significant PM10 impact out to 2.1 km. Table D-24 presents the maximum predicted 

impacts from the significant impact analysis.

357
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 52

Table D-24 

Averaging 

Period Year

Maximum 

Predicted 

Impact 

(μg/m3)

Receptor 

Location UTM 

Zone 15 (m) Period Ending 

YYMMDDHH

Significant 

Impact 

Level 

(μg/m3)

Monitoring 

De minimis 

Conc., 

(μg/m3 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 90122224

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 PM10 impact due to the project is above the SIL but below the monitoring 

de minimis concentrations of 5 a nd 10 μg/m3

, 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 PM10. 

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?

SO2

24-hr 4.25 No

3-hr 0 --

Annual 0 --

NOX Annual 4.8 No

PM10

Annual 2.0 --

24-hr 2.5 No

NAAQS Analysis

Nitrogen Dioxide 

By modeling the tot al pot ential M ill e missions a nd c ompeting s ource e missions, t he a nalysis 

predicted the total impact to compare to the NAAQS. Table D-26 summarizes the NO2 model 

results.

358
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 53

 Table D-26 

Year Annual Predicted 

Impact (ug/m3)(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 μg/m3 to the modeling result. As summarized in 

Table D-27, when adding the background concentrations, the annual concentration is 40.1 μg/m3. 

This impact is less than the respective NAAQS of 100 μg/m3. Therefore, G-P has demonstrated 

that the Mill emissions that reflect all project changes will not cause or contribute to a violation 

of the NAAQS.

Table D-27 Concentrations in μg/m3

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 SO2 predicted impacts are 4,915, 133, and 14.5 μg/m3

, 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 SO2 model results.

Table D-28 

Averaging 

Period Year 

Maximum Predicted 

Impact (μg/m3)

Receptor Location Period

Ending

East (m) North (m) (YYMMDDHH)

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 3957700 --

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 86060815

1987 433 292700 3954100 87062412

1988 445 296000 3954000 88090403

1990 360 292700 3954100 90062218

1991 491 291500 3954100 91060921

359
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 54

G-P added background concentrations of SO2 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 Concentrations in μg/m3

Averaging Period

Maximum 

Predicted Impact

Background 

Concentration

Total 

Concentration NAAQS

Annual 14.46 6.8 21.3 80.0

24-Hour High 2nd High 132.5 41.9 174.4 365.0

3-Hour High 2nd High 490.5 159.8 650.3 1300.0

Particulate Matter – PM10

The analysis predicted exceedances of the 24-hour NAAQS for PM10 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 automatically 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 

(μg/m3)

Receptor Location

UTM Zone 15(m) Period Ending 

East North (YYMMDDHH)

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 3957270 --

24-Hour High

6th 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

6th 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 exclude r eceptor ( 291600, 3956300) [ ISC f ile 

PMAQS*_1] 

360
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 be exceeded. Further, the modeling output files for the significant impact 

analysis of P M10 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/m3

Averaging Period Annual 24-Hour High 6th 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 NO2 increment predicted impact is 14.3 μg/m3. 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 NO2 model results. This impact is less than the allowable increment 

of 25 μg/m3. T herefore, 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 (μg/m3)

Receptor Location 

UTM Zone 15 (m)

Allowable 

Increment 

(μg/m3 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 sources, G -P 

determined that maximum SO2 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 SO2 model results. These impacts are less 

than t he r espective a llowable i ncrements of 512, 91, a nd 20 μg/m3. 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.

361
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 56

Table D-33 

Averaging 

Period Year

Maximum 

Predicted 

Impact 

(μg/m3)

Receptor Location 

UTM Zone 15 (m) Period

Ending

(YYMMDDHH)

Allowable 

Increment 

(μg/m3)

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 – PM10

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 M10 increment 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 μg/m3. 

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 

(μg/m3)

Receptor Location

Period Ending 

(YYMMDDHH)

Allowable 

Increment 

(μg/m3 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 2nd

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 91122824

362
PERMIT 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 her 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 height 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 other 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) The 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, wakes, 

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.

363
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 

SO2, NO2, a nd P M10 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 epresentative 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 of the Muskogee Mill. 

Table D-36

Station ID County City Location

Years of 

Available 

Data

Distance 

to Mill 

(km)

SO2 Monitors

400219002 Tahlequah Cherokee Co Residential – Rural 2002-current 31

401010167 Muskogee Muskogee Co Residential – Rural 2002-current 6.8

401430175 Tulsa Tulsa Industrial – Suburban 2002-current 80

401430235 Tulsa Tulsa Industrial – Urban 2002-current 77

PM10 Monitors

400219002 Tahlequah Cherokee Co Residential – Rural 2002-current 31

401010167 Muskogee Muskogee Co Residential – Rural 2002-current 6.8

NO2 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 68

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PERMIT 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/m3)

SO2 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

NO2 Tulsa - 2004 Annual Mean Annual 0.0054 10.2

PM10

Muskogee – 2002-2004 24-hour High 

Fourth High and 2004 Annual 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 post-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 the 

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 significant 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.

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 60

D.6. AMBIENT IMPACT ANALYSIS IN CLASS I AREAS

D.6.1. INTRODUCTION

Generally, if the 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 the 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 oposed 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 Land 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 general 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 the 

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 to 

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PERMIT 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 

designed 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 formats 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 regulatory 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 increments: use highest, second highest 3-hour and 24-hour average SO2

concentrations; highest, second highest 24-hour average PM10 concentrations; and 

highest annual average SO2, PM10, and NOx concentrations.

2. For haze: process, on a 24-hour basis, compute the source extinction from the 

maximum increase in emissions of SO2, NOx, and PM10; 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 SO2, PM10, and NOx. a

 IWAQM Phase II report (December, 1998) and FLAG document (December, 2000) 

Table D-39 CALPUFF Model Settings

Parameter Setting

Pollutant Species SO2, SO4, NOx, HNO3, NO3, PM10

Chemical Transformation MESOPUFF II scheme including hourly ozone data

Deposition Include both dry and wet deposition, plume depletion 

Meteorological/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 scheme

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 62

Terrain Effects Partial plume path adjustment

Output Create binary concentration file including output species for SO4, NO3, 

PM10, SO2, and NOx; 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 significant impact analysis: highest predicted annual and highest 

short-term averaging time concentrations for SO2, NOx, and PM10.

Background Values Ozone: 50 ppb; Ammonia: 1 ppb

Emission Inventory and Building Wake Effects 

The C ALPUFF m odel i ncluded t he 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 Input 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. For 

the 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 ignificant 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 re 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 riables 

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PERMIT 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 processing

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 stations 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 from 

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 TD3240 variable format and converted into a fixed-length format. The utility 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 Digital 

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 processed 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 processing 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 criterion is based 

on the annual averaging period. 

Estimates of dr y ( SO2, S O4, NOx, HNO3 and N O3) and wet ( SO2, S O4, HNO3 and N O3) 

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 from 

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PERMIT 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 SO2, SO4, 

NOx, HNO3 and N O3. 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/meter2

/second (g/m2/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 estimated 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

Thresholdb

(kg/ha/yr)

1990 1992 1996

(g/m2/s) (kg/ha/yr) a (g/m2/s) (kg/ha/yr) a (g/m2/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/m2

/s to kg/hectare is 1 g/m2/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 2002.

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 ( bext). T he b ext is t he a ttenuation of 

light pe r uni t di stance due t o t he scattering and absorption 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 as

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 65

∆% = (bexts / bextb) × 100, where 

bexts is the extinction coefficient calculated for the source, and

bextb 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) of 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 ed 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 criterion 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

 Concentrations 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/m3) a Significant

Impact Level (μg/m3 1990 1992 1996 )

Caney Creek NWA

SO2 Annual 0.001 0.002 0.002 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 NA

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 66

Table D-42 

Pollutant

Averaging 

Time

Maximum Concentrations (μg/m3) a Significant

Impact Level (μg/m3 1990 1992 1996 )

PM10 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

NO2 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 NA

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

Hercules-Glades NWA

SO2 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

PM10 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

NO2 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 NA

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 67

Table D-42 

Pollutant

Averaging 

Time

Maximum Concentrations (μg/m3) a Significant

Impact Level (μg/m3 1990 1992 1996 )

Upper Buffalo NWA

SO2 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

PM10 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

NO2 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-Hour 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 WILDLIFE 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 not 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. 

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 68

Impacts to 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 

changes, 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 pollutant 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 assumption 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 meteorological 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 

behavioral 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 

SO2, NO2, a nd pa rticulates. T he pr oposed pr oject’s c ontribution t o c umulative impa cts is 

expected to be negligible.

Research with primates s hows t hat O3 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 O3, and desquamated cells were found from acute exposures at 

0.25, 0.5, a nd 1.0 ppm . I n animal research, O3 has been found to 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 growing 

374
PERMIT 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 O3 concentrations 

may be causing or contributing to irreversible chronic lung injury. 

The project’s contribution to ground level O3 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 impacts 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 

Agency.

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 Standards. 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 tandards 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.

375
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) [Applicable]

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 either 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 conditions listed in this subchapter. 

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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 specifies 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 the 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.

Emission

Unit

Heat Input 

MMBTUH

Coal Factor, 

Lb/MMBTU

NG Factor, 

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 PM-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 emission points 

will be in compliance with the Subchapter 19 limits.

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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 for 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 Subpart 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 emissions 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 dioxide 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 limits 

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 from 

378
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 73

coal combustion that demonstrated emissions from this fuel were well 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 Section 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 0.0006 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 NOX per MMBTU, 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). 

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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 toxic 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 permanent 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 ergency 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. 

380
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 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 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 applicable 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 emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Grain Elevators not in source category 

OAC 252:100-35 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 table compares the actual-to-potential 

increases with the PSD significance thresholds.

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 76

Pollutant NOX CO SO2 PM10 VOC H2SO4 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 contemporaneous decreases to consider, so pollutants NOX, CO, SO2, PM10, 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 modified. 

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 term “G-P” in this document refers 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

Tunnel 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 Y

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PERMIT 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 proposed 

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 ith 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 Mill, 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 requirements 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 vicinity 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 associated 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 must 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 selecting 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 conomic 

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 nalysis 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. Eliminate 

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PERMIT 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 emission 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

SOURCE 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 Machine 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 dryers 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 educing PM /PM10, S O2, NOx, 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 anufacturing 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 drying 

384
PERMIT 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-NOX 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/PM10 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/PM10. Based 

on a PM/PM10 emission factor of 7.6 lbs/MM ft3

 gas burned from AP-42 (EPA) and a 20% safety 

factor, the potential emissions for PM/PM10 are 0.00912 lbs/MMBTU.

Control technologies such as a baghouse or wet scrubber would not normally be considered for 

reducing PM/PM10 emissions when burning natural gas due to the very low emissions generated. 

Sulfur Dioxide (SO2) 

Natural gas a nd pr opane a re t he c leanest bur ning f uel a vailable f or c onsideration of S O2

emissions. The use of natural gas/propane for the dryer burners will result in very low emissions 

of SO2. 

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 SO2

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/ft3 is only 0.00072 lbs/MMBTU or 0.22 tons per year, assuming 8,760 hours of operation per 

year.

The es timated concentration of SO2 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 ft3/min 

combustion air flow for burner, operating temperature of 400°

F, and 0.05 l bs/hr emission rate). 

Add-on pollution control devices could not reduce SO2 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 xygen 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.

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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 combustion 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 bs/MM ft3 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 combustion of natural gas will be about 30 ppm v (based on 3,100 f t3

/min combustion 

air flow for burner, operating temperature of 400°

F, and 0.4 l bs/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-NOX or ultra 

low-NOX burners). W hen g as-fired bur ners i ncorporate l ow-NOX (or ul tra l ow-NOX) 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-NOX 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. AP42 l ists a C O e mission f actor of 84 lbs/MM f t3 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 vendor 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 ombustion 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 ith 

386
PERMIT 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 (NOx) 

NOx emissions are generated in three ways; thermal NOx, prompt NOx, and fuel NOx. Thermal 

NOx occurs in the high temperature zone near the burner itself. The formation of thermal NOx 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, NOx emissions al so increase. T he s econd 

mechanism of NOx formation, prompt NOx, occurs in the flame itself 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 NOx is usually negligible when compared to the amount of NOx formed from the thermal 

NOx mechanism. T he t hird m echanism of NOx formation, c alled f uel N Ox, 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, NOx formation through the fuel NOx mechanism is insignificant compared to 

thermal NOx formation. 

There are two approaches to control the emissions of nitrogen oxides in combustion gases: either 

modify the combustion operation to prevent the formation of NOx or treat the combustion gas 

chemically, after the flame, to convert NOx to elemental nitrogen. Low-NOX burners and flue 

gas recirculation modify the combustion operation. 

Low-NOX methods 

The technique normally used to control NOx emissions from natural gas-fired burners in paper 

machine burners is the use of low-NOX or ultra low-NOX burners. These burners 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 NOx 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 Ox 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 Ox 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. NOx 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. NOx formation rates in this zone are low because the inerts from the primary flame 

zone lower the flame temperature and oxygen concentration.

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 82

Low-NOX burners will r educe N Ox emissions by a t l east 30% c ompared t o N Ox emissions 

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-NOX

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-NOX

burners can reduce NOx emissions by 50% c ompared t o N Ox emissions g enerated by 

conventional burners. 

According to the manufacturer in 2005, t he NOx emission rate from the existing Maxon LV-85 

Line burners is approximately 0.12- 0.15 lbs/MMBTU. Estimates for NOx emissions from lowNOX burners r ange f rom 0.036 -0.06 l bs/MMBTU ba sed on i nformation f rom s everal pa per 

machine bur ner ve ndors. E stimates for NOx emissions for ultra low-NOX 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 NOx emissions. FGR can reduce NOx emissions by 

approximately 15-25%, depending upon specific operating conditions. 

Selective Catalytic Reduction (SCR)

SCR is a post combustion control technology that uses the injection of ammonia followed by a 

catalyst to convert a ll N Ox 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 NOx emissions by as 

much as 90%. 

Selective Non-Catalytic Reduction (SNCR)

SNCR is another pos t c ombustion c ontrol t echnology f or N Ox reduction. T his t echnology i s 

similar to SCR in that ammonia injection is required to convert all NOx to elemental nitrogen. 

However, SNCR operates in the absence 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 Ox

emissions by 25-50%, depending upon specific operating conditions. 

Review of EPA RACT/BACT/LAER Clearinghouse

Searches of the RACT/BACT/LAER Clearinghouse (RBLC) were conducted to identify control 

technologies f or t he c ontrol of P M/PM10, S O2, NOx, C O, a nd V OC e missions f rom pa per 

machine dryer burners. Searches were only conducted for RBLC determinations added 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 solvent388
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 compared 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 analysis lists only 

the salient points. Five companies in four states listed 15 units for the PM/PM10 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 specifying an emission rate in units of lbs/MMBTU, 

the range of values was from 0.004 to 0.024 lbs/MMBTU. Three companies in three states listed 

11 units for the SO2 review. These units ranged in size from 12 t o 117 M MBTUH and all of 

them listed natural gas or “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 

lbs/MMBTU. F ive c ompanies i n f ive s tates l isted 13 uni ts f or t he N OX review. T hese units 

ranged in size from 18 to 117 MMBTUH and 10 of them listed low-NOX 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 description. For 

the seven low-NOX units specifying an emission rate in units of lbs/MMBTU, the range of values 

was f rom 0.0913 t o 0.115 l bs/MMBTU. A ll t hree of t he Inter Lake uni ts were listed at 0.12 

lbs/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 lbs/MMBTU, the range of values was from 

0.1139 t o 0.26 lbs/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 lbs/MMBTU, the 

range of values was from 0.019 to 0.0564 lbs/MMBTU.

Step 2 - Technical Feasibility Analysis

PM/PM10

Clean Fuel 

The use of clean fuel such as natural gas is technically feasible for the paper machine burners.

SO2

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. 

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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 temperature 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 catalyst 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/PM10

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-NOx and Ultra Low-NOx Burners

The us e of l ow-NOX or ultra lo w-NOX 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-NOX 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. 

NOx

Low-NOX or Ultra low-NOX Burners

The us e of l ow-NOX or ul tra l ow-NOX burners i s t echnically f easible f or t he pa per m achines 

dryer 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 

NOx. 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 lower 

NOx 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 turn, 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 NOx emissions from the existing paper machine burners. 

Selective Catalytic Reduction

SCR w ould not be t echnically f easible f or r educing N Ox 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 Ox emissions to elemental ni trogen. T he use of 

additional heat to raise the temperature of the exhaust gases would waste energy since the new 

390
PERMIT 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 raised 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 Ox emissions. F or t hese r easons, S CR i s not t echnically feasible f or 

controlling NOx emissions from the paper machine dryer burners. 

Selective Non-Catalytic Reduction

SNCR would not be technically feasible for reducing NOx emissions from the paper machines 

dryer burners for one of the same reasons stated above for an SCR system – the 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 NOx

emissions. For these reasons, SNCR is not technically feasible for controlling NOx 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/PM10 Clean Fuel/Use of Natural Gas N/A

SO2 Clean Fuel/Use of Natural Gas N/A

NOx low-NOX Burners 30-75

Ultra low-NOX Burners 50-95

CO/VOC Combustion Control 30-60 

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 selects 

the most appropriate technology as 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, 6th edition, June 2003 (Chapter 2-

Cost Estimating 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 machine burners, which is equal to 

the best level of control for PM/PM10 emissions, an economic analysis is not required. 

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 86

SO2

Since the Mill will only be burning natural gas in the paper machine burners, which is equal to 

the best level of control for SO2 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.

NOx

The only feasible control technologies to reduce NOx emissions are the use of either low-NOX or 

ultra low-NOX burners in the paper machine dryer. For cost estimating and emission estimating 

purposes, G-P has first cal culated the cos t ef fectiveness of N orth American’s ul tra l ow-NOX

burner since it has the lowest NOx emission rate of several different burners investigated, which 

are listed below:

• North American Ultra low-NOX burner (Model 4213 LEx)—0.015 lbs NOx/MMBTU

• Maxon Crossfire low-NOX burner—0.036 lbs NOx/MMBTU

• Maxon Kinedizer low-NOX burner—0.04 lbs NOx/MMBTU

• North American low-NOX burner (Model 4096)—0.05 lbs NOx/MMBTU

• Coen low-NOX burner (Model THE-QL)—0.06 lbs NOx/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-NOX burner and therefore G -P c annot ve rify t he ope rational 

reliability or performance of the North American ultra low-NOX burner. The capital equipment 

cost da ta a nd installation cost da ta f or North American’s ultra low-NOX 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 the 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 

paper 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 direct 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% of direct operating labor and maintenance costs

• Property taxes – 1% of total capital investment

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PERMIT 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 Ultra lowNOXMaxon Crossfire 

low- NOX

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) Construction & 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) Other 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 $867,163 $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 operating 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 0.1424

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PERMIT 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 Ultra lowNOXMaxon Crossfire 

low- NOX

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 with 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 paper 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 

methodologies 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 “tons removed” term 

from the first table.

PM11 PM12 PM13 PM14

North American Ultra Low NOX Burner @ 0.015 lb/MMBTU

Baseline heat input (MMBTU/yr) 113627 197251 159772 111735

Existing Burner NOX TPY (baseline) 6.8 11.8 9.6 8.4

ULNOX Burner NOX TPY (baseline 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 NOX TPY PTE 25.2 17.3 17.3 25.2

ULNOX Burner NOX 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 NOX TPY (baseline) 6.8 11.8 9.6 8.4

Lo NOX Burner NOX 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 NOX TPY PTE 25.2 17.3 17.3 25.2

Lo NOX Burner NOX TPY (PTE heat input) 11.04 11.04 11.04 11.04

Tons removed 14.19 6.31 6.31 14.19

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PERMIT 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 input 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 is not cost-effective. T he CrossFire Low NOx burner can be considered costeffective.

CO

The use of low-NOX burners will affect CO emissions, and in some instances, installing low-NOx

burners will increase CO emissions as discussed earlier in this analysis. Based on a review of a 

number of l ow-NOX and ultra l ow-NOX 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-NOX burner (Model 4213 LEx)—0.15 lbs CO/MMBTU

• Maxon Crossfire low-NOX burner—0.184 lbs CO/MMBTU

• Maxon Kinedizer low-NOX burner—0.3 lbs CO/MMBTU

• North American low-NOX burner (Model 4096)—0.15 lbs CO/MMBTU

• Coen low-NOX burner (Model THE-QL)—0.15 lbs CO/MMBTU

The Maxon Crossfire low-NOX burner generates slightly higher CO emissions than the lowest 

burner available, which is 0.15 l bs/MMBTU. H owever, the primary purpose of installing lowNOx burners i s t o r educe N Ox 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-NOX burner is more cost effective than the North American ultra low-NOX burner, 

and s ince M axon’s C rossfire l ow-NOX burner ha s l ower NOx emissions t han a ny of t he ot her 

burners i nvestigated, G -P be lieves t he M axon C rossfire low-NOX 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-NOX burner onl y 

generates a bout 60% of t he C O e missions t hat t he burners currently in t he pa per m achines 

generate.

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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-NOX burner. Based on North American’s ultra lowNOX 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-NOX 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-NOX burner for each of the criteria pollutants: 

PM/PM10

BACT for PM/PM10 emissions should be the use of natural gas as a clean fuel. G-P agrees to a 

permit limit of 0.0091 lbs/MMBTU heat input. 

SO2

BACT for SO2 emissions should be the use of natural gas as clean fuel. G-P agrees to a permit 

limit of 0.00072 l bs/MMBTU heat input. T his value is equal to the lowest values contained 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 lbs/MMBTU heat input. 

NOx 

For individual paper machines that replace the burner, BACT for NOx emissions is the use of a 

low-NOX burner. G -P a grees to a pe rmit limit of 0.04 lbs/MMBTU, which is e quivalent t o 

Maxon’s emission factor guarantee for the Crossfire low-NOX 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-NOX burner. G -P agrees to a permit limit of 0.184 lbs/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-NOX burner. 

This value is within the range of values contained in the RBLC summary above, which is 0.06 to 

0.214 lbs/MMBTU. Reducing the CO limit any further would most likely result in a higher NOx

value, which is undesirable.

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 enhance 

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 91

product quality and make the process more efficient. E xamples 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 

collected 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 Paper 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 2003 

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 that 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 testing 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. 

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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 drying 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 ontaining 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 properly. The amount of VOC emission reduction that 

can be achieved is highly variable depending on the specific application. 

Particulate Matter

PM/PM10 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 

more) of the overall PM/PM10 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/PM10 emission rates for the paper machine and in this 

BACT analysis. PM/PM10 emissions from the “wet end” of the paper machine are considered 

insignificant w hen c ompared t o P M/PM10 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 process 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 room 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 recycle 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 particulate matter emissions from the “wet-end” 

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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 os. 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 the 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 repe 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 missions 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/PM10 emissions f rom m anufacturing 

processes within the company include baghouses and wet scrubbers. A brief 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% for pa rticles 

down to 0.3 micrometers (μm) 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 process 

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 reverse 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.

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PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 94

Wet Scrubbers

Wet scrubbers 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 common 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 liquid (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 remove 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

VOC

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 oxidation, 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 control 

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 three states listed five units for the PM/PM10 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 

scrubber, ve nturi 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 nturi 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 oducts t hat t he M uskogee M ill m anufactures. 

These other paper products include coated board, containerboard, specialty papers, fine printing 

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PERMIT 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 enduse.

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 machines for pur poses of t his BACT 

analysis. Only those five units that 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 reduce 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 VOC 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. 

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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 done 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 emission 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 as “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 feasible 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/PM10 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/PM10 is generated from “dry end” point 

sources of the paper machine and the other 50% of the PM/PM10 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 baghouse to control PM/PM10 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.

402
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/PM10 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/PM10 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/PM10 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 machine 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 tional 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/PM10 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 systems 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 good 

403
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 98

operating 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.

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.

Step 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 LowVOC 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 selects 

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 Manual, 5th 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 alculations 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 

environmental 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 VOC 

404
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 99

generated in the pa per m achines due t o the large 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 analysis 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 various 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 he 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 Cost 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 stream flowrate (acfm): 385,200

-- Inlet stream temperature (oF): 120

-- Inlet stream temperature, adj.--pulse jet only (oF): 120

-- Dust type: Paper fiber

-- Inlet dust loading (gr/ft3): (based on 5.9 tpy) 0.0078

-- Dust mass median diameter (microns): 7

-- Filtration time (min): 10

-- Dust specific resistance (in.H2O/fpm/lb/ft2): 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. H2O/fpm): 1.1

405
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 100

Total Annual Cost 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/ft2 cloth area):

Shaker: 1.80

Reverse-air: 1.80

Pulse-jet: 13.81

Cartridge: 1.33E-02

-- Net cloth area required (ft2): 

Shaker: 214,000

Reverse-air: 214,000

Pulse-jet: 27,898

Cartridge: 28,918,102

-- Gross cloth area required (ft2): 

Shaker: 222,560

Reverse-air: 222,560

Pulse-jet: 27,898

Cartridge: 28,918,102

-- Area per bag--reverse-air (ft2) (8-in. x 24-ft): 50.3

-- Number of bags--reverse air: 4,428

-- Area per bag--shaker (ft2) (5-in x 8-ft): 10.5

-- Number of bags--shaker 21,253

-- Area per bag--pulse jet (ft2): 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 (ft2): 153

-- Number of bags--cartridge: 189,008

-- Bag pressure drop (in. w.c.):

Shaker 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

Total--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): 2

406
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 101

Total Annual Cost 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-air

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. 0 126,217 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] Parameters 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 easible. T o de termine t he c ost e ffectiveness of us ing a w et ( venturi) s crubber t o 

control P M/PM10 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 ssumptions. 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 (uncontrolled) for paper machines 14 

and 15 are approximately 270,000 acfm and 7.3 tons per year for each. 

407
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

INPUT PARAMETERS

-- Inlet stream flowrate (acfm): 270,000

-- Inlet stream temperature (oF): 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

-- Saturation 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 (oF):[6] 260.0

-- Saturation temperature (oF): 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 H2O): 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 (in. 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 244,179

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

Maintenance 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): 0.86

408
PERMIT 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 materials 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 Effectiveness ($/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] Enter 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 because 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. 

409
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 table.

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 (oF): 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 0.00075 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 1,335,696 840,832 773,204 832,170 

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 46,308 276,308 151,712 137,357 149,835 

410
PERMIT 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 wet scrubber.

Step 5 – Select BACT

VOC

The only listings 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 Girardeau, 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 

rate, which could result in lower overall VOC emissions from the paper machine. 

In lieu of agreeing to a specific “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 

one 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 product 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 be 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 FOR 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 the 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 area

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PERMIT 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 used. 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/PM10 and V OC e missions 

from Converting Department operations, information 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 

converting 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 particulate 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 controls.

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 available, 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 single 

412
PERMIT 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 multi-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 efficiency. 

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 fires, 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 (μm) size. Particles smaller 

than this are difficult 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/PM10 and VOC emissions from converting department equipment operations. Searches were 

conducted only for RBLC determinations added during or after January 1995. The specific EPA 

RBLC categories searched are listed below:

413
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 listed. 

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 selects 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 DESCRIPTION

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 existing 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 evel 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. 

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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 VOC 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 

process name contains the term “printing.” A large table 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 as 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  H2O + CO2 

This r eaction oc curs w hen t he air is heated to a s ufficiently hi gh temperature, typically 1,400 -

1,600oF. 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-laden 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 used 

415
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 110

to supply any heat necessary to reach the optimum combustion temperature (e.g., usually 1,400oF 

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 

recuperative cat alytic ox idizer us ually t ake pl ace between 500 and 600oF. 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 preheater 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 echnologies 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.

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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 finition 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 

clearinghouse 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 lternatives 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 the 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 dryer. 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 

platemaking 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. 

417
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 cover, 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 supervision 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-cleaning 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. The 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. 

418
PERMIT MEMORANDUM 99-113-C (PSD)(M-4) 113

Step 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 (HAPs). 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 emissions 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 leaching 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 added 

419
PERMIT 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”, “ chloralkali”, and “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 facility 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

Bleaching 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 technically 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 NOX. 

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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 biofilter. 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.

Step 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 hypochlorite 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 control 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 SO2 Clean Fuel No Additional Controls 0.2 tpy each

Paper Machine 11-14 NOx Conventional Burners Low NOx Burners 0.04 lb/MMBTU

Paper Machine 11-14 PM/PM10 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 Machine Process

Paper Machine 11 PM/PM10 None No Additional Controls 9.3 tpy (b)

Paper Machine 12 PM/PM10 None No Additional Controls 13.0 tpy (b)

Paper Machine 13 PM/PM10 None No Additional Controls 11.2 tpy (b)

Paper Machine 14 PM/PM10 None No Additional Controls 11.2 tpy (b)

Paper Machine 15 PM/PM10 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/PM10 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)

421
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/maximum 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 require testing will be NOX 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 

than 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 conditions 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. The current project will not add any units or 

processes that will alter that status.

Subpart KK (Printing and Publishing Industry) The memorandum associated with the pending 

Part 70 permit shows that the flexographic printing presses at the facility are affected sources. 

That memorandum describes the standards and requirements that apply. The current project adds 

three new polyethylene printers, but none of the standards is changed by this increase in machine 

count. The following lists the affected sources: 

422
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. Requirements 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-control 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 the 

need for CAM. Similarly, the addition of three printers will lead to an estimated 971 TPY of precontrolled 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 available 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. 

423
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 Emission 

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 emissions in the 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 III 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 iling 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. 34th 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 fee 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. 

424
PART 70 PERMIT

AIR QUALITY DIVISION

STATE OF 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 Date

425
 

PERMIT 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 authorized 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, 

however, 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 according 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 changes

C. No changes

D. Total S OX 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. 

EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP

EU ID Manufacturer & Serial 

Number

Burners 

(MMBTUH)

Fuels EU 

Construct

Burner 

Replace

426
SPECIFIC 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 2006

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# 683 

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 – TPY1

SO2 PM10 VOC NOX CO

PM-11 0.22 2.80 2.02 11.0 56.4

PM-12 0.22 2.80 2.02 11.0 56.4

PM-13 0.22 2.80 2.02 11.0 56.4

PM-14 0.22 2.80 2.02 11.0 56.4

PM-15 0.16 2.00 1.45 32.9 96.4

PO-12 0.03 0.35 0.25 4.56 3.83

1. NOX and CO emission factors for PM-11, 12, 13, and 14 reflect BACT 

values of 0.036 l b/MMBTU f or N OX

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 for each.

All Paper Machines – OAC 252:100-25, 31, & 33 Standards

Opacity SO2 (lbs/MMBTU) NOX (lbs/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 Specific 

Condition #7 of Permit No. 99-113-TV. 

427
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 collection 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

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 

G. All presses, Subpart KK Flexographic Printing. [40 CFR 63 Subpart KK] 

No change.

EUG 6 – VOC Sources Not Subject to an 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, 78” wide 6/05

428
SPECIFIC 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 exceed 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 ontent of each additive or 

cleaner material used. 

I. Eliminated

J. No changes.

K. Eliminated

L. Paper p rinters FP-1, FP-7, and FP-8. T otal e missions of V OCs f rom t hese printers is 

limited to 92.28 T PY, r olling 12 -month c umulative. Emissions c alculations 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 ufficient 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 requirements. [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.

429
SPECIFIC CONDITIONS NO. 99-113-C (M-4)(PSD) 5

 

C. Additional requirements for Boiler B-4. [General Conditions, Permit No. PSD-OK-404]

No changes.

D. The low-NOX 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 lbs/MMBTU for NOX and 0.184 lbs/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 

Regional 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, Reference 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 yers 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 

application 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.

430
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 Machines PM-11, 12, 13, 14.

BACT shall consist of the use of low-NOX 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.

431
TITLE V (PART 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 seq.) 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 nvironmental 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 of 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 actions 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)]

432
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 retained 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 includes a ll or iginal s trip-chart re cordings for 

continuous monitoring instrumentation, and copies of all reports required by this permit. Where 

appropriate, the 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 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 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)(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 Recordkeeping, 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 duplicative of the reporting required in t he pr evious pa ragraph w ill s atisfy t he r eporting 

requirements 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)] 

433
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 

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 contain 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 the 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. 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 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 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 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 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 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 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)]

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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 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 . R EQUIREMENTS TH AT BEC OME A PPLICABLE DURING THE 

PERMIT TERM

The pe rmittee 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 applicable are listed in the Standard 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)]

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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 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 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.

 [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 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 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 claim 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)]

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TITLE V STANDARD CONDITIONS July 1, 2005 6

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)] 

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 information 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 

identification. 

(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 mendments, 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)]

437
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 onitoring 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 shall 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;

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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 

emergency; 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 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.

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 register w ith the appr opriate ag ency a r isk management 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 if 

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 more 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 

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] 

439
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 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;

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, 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 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] 

440
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, and 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, carbon 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. [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 aintenance, s ervice, repair, or disposal 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-like appliances must comply 

with record-keeping requirements pursuant to § 82.166. 

441
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 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 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 issue 

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 proposed 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 itle 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.

442
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] 

443
June 14, 2006 

Mr. Karl L. Meyers, 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 construction 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 must 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 1st 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

Enclosure(s)

cc: Muskogee County DEQ Office 

444
Tennessee Division of Air Pollution Control Files 

Packaging Corporation of America, Counce Mill 

Excerpt from PSD Preliminary Determination for Permit No. 953059P 

 

445
446
447
448
449
Texas Commission on Environmental Quality Files 

Inland Paperboard and Packaging – Orange Mill 

Excerpt from PSD Review for Permit No. PSD-TX-684M1/9654A/833M1 

 

450
PRELIMINARY 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 facility. The goal of this Mill 

Improvement Project is to improve the profitability of the mill by making the 

operations more cost effective and to increase the Mills Linerboard 

production capacity to 2,340 machine dry 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 bark. The two Linerboard machines 

will be modified to accept the increase supply of fiber from the recycle 

fiber plant. Through these 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 Standards 

451
This facility must comply with National 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 representations that they will comply with all the 

applicable requirements of these standards. 

Offsets required were obtained for the emissions of NOx 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 emissions. Listed below is a summary of 

the total revised emissions rates associated with this major modification 

request for the Mill Improvement Project. 

Pollutant: Proposed Increase (tpy) PSD Significance 

Level (tpy) 

PM/PM10 95.40 15 

SO2 39.16 40 

NOx 190.70 40 

CO 296.40 100 

VOC 214.81 40 

Lead 0.02 

0.6 

H2S 5.62 10 

TRS 7.52 10 

Be 0.000029 0.0004 

Hg 0.000585 0.10 

 VI. Prevention of Significant Deterioration (PSD) and Nonattainment 

(NA) Applicability

452
PRELIMINARY 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 thresholds. The Mill Improvement Project 

is projected to trigger a PSD review for PM/PM10, CO, and NOx and a 

Nonattainment review for NOx and VOC. The Beaumont-Port Arthur area 

was classified as a moderate nonattainment area for ozone at the time the 

application was submitted. Therefore, this project also will undergo a 

Nonattainment review for VOC and NOx and secure the required offsets at 

a ratio of 1.15 to 1.00. 

453
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 4

 Pollutant Averaging 

 

 Period 

 

 

Highest 

 

Modeled 

 Value 

 

 (μg/m3

) 

 Modeling 

Significance 

 Level 

 (μg/m3

) 

 Monitoring de

 Minimis 

Level 

 (μg/m3

) 

 

 PM10 24-Hour 45.10 5 10 

 PM10 Annual 0.99 1 - 

 NOx Annual 2.22 1 14 

 CO 1-Hr 165.3 2000 - 

 CO 8-Hr 87.4 500 575 

Maximum off-property concentrations of PM10 exceeded its Modeling 

Significance Level and Monitoring de Minimis Level for the 24-hour 

averaging period, but did not exceed the annual value. Therefore, a full 

impact analysis was required for PM10 to show compliance with the 

NAAQS for the 24-hour standard. 

Screening modeling for NOx 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 the modeling significance levels for 

1-hour or 8-hour values. Therefore, no refined CO modeling is required. 

VII. Best Available Control Technology (BACT) and Lowest Achievable 

Emission Rate (LAER)

454
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 5

PM10: Particulate matter (PM), both PM and PM10, 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/PM10

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 economic 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 control equipment is not cost-effective. 

From the Clearinghouse, two units that most closely match the Inland 

boilers in types of fuel mix are permitted at 0.03 lb/MMBtu. The company 

proposes to remain with the existing scrubber, but modify it to improve its 

efficiency to meet the 0.03 MMBtu limit. This meets BACT for the control 

of PM/PM10 from a bark boiler. 

NOX: NOx 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 Practices 

455
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 6

A review of the permitted bark boilers, 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 when applied to stoker fired bark 

boilers, such as the one used at the Inland Paperboard facility. SCR is 

effective at a temperature range of 500-800 F. In order to be effective, 

the catalyst must have a low particulate loading to avoid clogging or 

chemically degrading the precious metal catalyst. Also, the presence of 

sulfur will cause problems with this system. 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 required temperatures. Based on this, 

SCR is not an effective method to control NOx emissions from the bark 

boiler. 

The company has selected to install a SNCR system on the bark boiler to 

control the formation of NOx. 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 system meets BACT and LAER for the 

control of NOx 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 Stoker 

456
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 7

The Oxidation Catalyst system would 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 input in order to operate properly. 

The company proposes process controls through the use of good 

combustion practices and good combustion unit design. This includes 

improvements in the boiler over fired 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 formed 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 combustion 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. EPA 

457
PRELIMINARY 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 generated 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 Pulp and Paper Industry has been 

reducing HAPs and other solvents used in the papermaking system in the 

past 15 years. Therefore, EPA has concluded that a MACT standard for 

papermaking systems based on low-HAP additive substitution is not 

warranted. 

Therefore, BACT/LAER for the control of VOC from 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/m3

) is provided as 

follows: 

Pollutant Averaging Period Monitoring Significance 

(g/m3

) 

Maximum Concentration 

(g/m3) 

PM10 24-Hour 10 45.10 

NOx Annual 1 2.22 

The maximum concentration for emissions of PM10 was greater than its 

monitoring de minimis level, thus triggering pre-construction monitoring. 

To be exempt from the pre-construction monitoring requirements, a 

background modeling analysis is required to evaluate the existing ambient 

air quality for the region as per guidance from the NSR Modeling Section. 

For the PM10 PSD NAAQS analysis, a Point Source Database (PSDB) 

retrieval was conducted to obtain sources within the significant impact 

area for PM10. The highest sixth-high for the years modeled showed a 

458
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 9

24-hour concentration of 71.39 μg/m3

. This value was added to the 

background concentration of 75 μg/m3

 to yield a total concentration of 

146.39 μg/m3 for PM10. This concentration is below the 24-hour NAAQS 

level of 150 μg/m3

. Therefore, compliance with the PSD NAAQS is 

demonstrated and is exempted from pre-construction monitoring. 

Local PM monitors are located close enough to the plant site to be 

considered representative of the mill operation. The highest 

concentration recorded in the Significant Impact Area was 119.93 μg/m3

, 

which is below the NAAQS standard. 

From the NOx refined modeling for the annual averaging period, the 

highest value was 25.50 μg/m3. When combined with the background 

concentration of 35.0 μg/m3

, the total NOx was 60.5 μg/m3. This is below 

the NAAQS value of 100 μg/m3. 

Local NOx monitors had recorded a maximum background concentration 

level of 50.6 μg/m3, which is below the NAAQS. 

 IX. Air Quality Analysis

The air quality impact analysis was performed 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 would be required. The modeling 

results indicate that a full impact analysis is required for PM10 for the 

24-hour standard and NOx for the annual standard 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 + 

Backgroun

459
PRELIMINARY DETERMINATION SUMMARY 

Permit No. 9654A, PSD-TX-684M1/833M1, and N60

Page 10

Pollutan

t 

Period (g/m3

) (g/m3) Impact 

(g/m3

)

y (g/m3

) Impact 

(g/m3

) 

d (g/m3

) d (g/m3)

PM10 24-hour 5 30 18.23 150 71.39 75 146.39

NOx annual 1 25 17.82 100 25.50 35 60.5

PM10: Plant-wide emissions of PM10 and PSDB emissions for other 

off-property sources were modeled for the 24-hour averaging periods. 

Modeling showed compliance with NAAQS. The increment analysis 

showed that the project and other increment consuming sources will not 

result in exceedances of the PSD increments for PM10. 

NOx: Plant-wide emissions of NOx and PSDB emissions for other 

off-property sources were modeled for the annual averaging period. 

Modeling showed compliance with the NAAQS. The increment analysis 

showed that the project and other increment consuming sources will not 

result in exceedances of the PSD increments for NOx. 

 X. Additional Impacts Analysis

Growth Analysis: There will be no additional jobs generated by the 

amendment to the State permit, by the modification of the PSD permits, 

nor by the issurance of the nonattainment permit. No air quality impacts 

associated with this project will occur. 

Soil and Vegetation Impacts: The modeled concentrations of PM10, 

NOx, SO2, and CO were determined to be less than the NAAQS, which is 

designed to protect the public health and welfare from known or 

anticipated adverse pollutant impacts. Therefore, soil and vegetation in 

the area should not be adversely affected 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 no 

460
PRELIMINARY 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 kilometers 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 Mill Improvement Project should 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 impacts evaluation was conducted. 

The evaluation included a Total Suspended Particulate (TSP) property line 

analysis to meet 30 Texas Administrative Code (TAC) Chapter 111, a SO2

and H2S property line analysis to meet 30 TAC Chapter 112, and Health 

Effects review. The modeling results indicate that off-property TSP 

impacts will be within property line standards as required by the state 

regulations. A maximum 1-hour concentration of 24.3 μg/m3

 and a 3-hour 

concentration of 18.3 μg/m3

 was predicted by modeling. The state 

standards are 400 μg/m3 for 1-hour and 200 μg/m3 for 3-hour. 

Facility-wide SO2 emissions were modeled with a result of a maximum 

30.3 μg/m3 for the 30-minute state standard. This compares to the state 

standard of 817 μg/m3

. 

Facility-wide H2S emissions were modeled with a result of a maximum of 

4.67 μg/m3

 for 30-minute state standard. This compares to the state 

standard of 162 μg/m3

. 

XII. Conclusion

461
PRELIMINARY 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 adverse 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 NOx

and VOC emissions were obtained in the proper amounts. Therefore, 

the Executive Director proposes a preliminary determination of approval 

for Inland Paperboard and Packaging Inc. to proceed with the Mill 

Improvement Project. 

462
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 established? (ED signature required if yes)...................................... No

Is a state or local official opposed to the permit? (ED signature required if yes) ............................... No

Is waste or tire derived fuel involved? (Deputy signature required if yes) .......................................... No

Are waste management facilities involved? (Deputy signature required 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 result in an increase in 

production at the facility. There are no increases (emissions sumarized below) and PSD major 

modification is not triggered. 

30 TAC Chapter 113 RULES

113.100 Compliance with applicable MACT standards expected? ............................................. 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 utilize BACT? .................................................................................... Yes

116.111(2)(G) Is the facility expected to perform as represented in the application? ...................... Yes

116.140 Permit Fee: $75,000 Fee certification provided? ................. 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 Clean Air Act? .......................................... Yes

116.111(2)(B) Will emissions be measured? ................................................................................ Yes

Comments: VOCs will be sampled from the process vents from the paper machine. 

FEDERAL PROGRAM APPLICABILITY

116.111(2)(D) Compliance with applicable NSPS expected? ........................................................ NA

116.111(2)(F) Compliance with applicable NESHAPS expected? ................................................. NA

116.111(2)(H) Is nonattainment review required? .......................................................................... No

A. Is the facility located in a nonattainment area? ................................................ No

463
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 applicable? ........................................................................................................ No

A. Is facility a federal major source (100/250 tons/yr)? ............................................. Yes

B. Is the project a federal major modification? ........................................................... No

1.Did project emission increases (proposed allowables minus the two-year average actual

emissions, no consideration given to decreases) trigger netting? .................................... Yes

2. Was contemporaneous increase significant? .................................................................. 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 the facilities that emit the HAP of concern (MeOH). 

122.10(8)(C) Does the facility emit 100 tons or more of any air pollutant? ...................................................... Yes 

122.10(8)(D) Is the facility a non-attainment major source? .............................................................................. No 

REQUEST FOR COMMENTS

 REGION: 10 (Beaumont) Reviewed by: Paul Judice

Paul Judice has indicated that the Region 10 office would like to see more 

enforceable conditions, in particular, sampling requirements on a regular basis. The 

company has tentatively agreed to include these in the pending renewal. It should be 

noted that the paper machines are separate 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 maintenance. 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 machines 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 shipping in bulk. The new paper machine will operate in a similar 

manner to the existing ones, put is designed to operate at a much higher capacity than any one of 

the existing machines. The additional capacity will allow 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 are the paper machine process vents, which direct the air from the 

464
New Source Analysis & Technical Review

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 are mostly steam, but there are 

entrained VOCs that are emitted as well. Although the emissions are very dilute, the overall 

emission rate is relatively large 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 emission factors are based on previous sampling done at 

this facility and do not account for the background 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 violation of NAAQS? .................................................. No

3. Is this a sensitive location with respect to nuisance? ............................................................... No

4. Is the site within 3000 feet of any school? ............................................................................... No

COMPLIANCE HISTORY

1. Was a NOV issued for construction without a permit? ............................................................. No

2. Was the NOV resolved by issuance of permit? ........................................................................ NA

MISCELLANEOUS

1. Is applicant in agreement with special conditions? ................................................................. Yes

Company representative? ........................................................................................ Chad Nerren

Contacted via? ........................................................................................................... Phone/FAX

Date of contact? .................................................................................................................. 7/7/99

2. Did the franchise tax verify the applicant to be in good standing? ........................................... NA

3. Emission reductions from source reduction or pollution prevention ........................................... 0

4. Emissions reductions resulting from the application of BACT required by state rules, avoidance 

of potential impacts problems, and voluntary reductions .......................................................... 0

5. Other permit(s) affected by this action? ................................................................................... No

 Changes in Emissions (TPY): Contaminants Current Proposed Change

TSP 648.4 648.4 0.00 

PM10 648.4 648.4 0.00 

NOx 1209.3 1209.3 0.00 

CO 1447.4 1447.4 0.00 

VOC 1795.9 1753.0 -42.90 

SO2 948.1 948.1 0.00 

465
New Source Analysis & Technical Review

Permit No. 8068 and PSD-TX-437 Account No. AC-0017-B 

Page 4 

 

 

 Permit Reviewer /Engineer Date Team Leader/Section Manager/Backup 

 Date 

466