STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

PROPOSED REVISION TO STATE IMPLEMENTATION PLAN

SUBMITTAL NUMBER 2015-03

SO2 NONATTAINMENT AREA PLAN

NASSAU COUNTY, FLORIDA

April 3, 2015
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STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

PROPOSED REVISION TO STATE IMPLEMENTATION PLAN

SUBMITTAL NUMBER 2015-03

SO2 NONATTAINMENT AREA PLAN

NASSAU COUNTY, FLORIDA

TABLE OF CONTENTS

SUBJECT PAGE

Letter of Submittal........................................................................................................................ 1

Executive Summary...................................................................................................................... 3

Introduction....................................................................................................................... 3

Background ....................................................................................................................... 3

Rayonier Permit................................................................................................................ 4

RockTenn Permit.............................................................................................................. 4

SIP Development Process................................................................................................. 5

Attainment of the SO2 Standard...................................................................................... 5

SO2 Attainment Demonstration – Technical Document............................................................ 7

1. Emissions Inventory..................................................................................................... 7

2. Construction Permits................................................................................................... 9

3. RACM/RACT............................................................................................................. 11

4. Air Quality Modeling Demonstration ...................................................................... 15

5. Conformity.................................................................................................................. 26

6. Reasonable Further Progress.................................................................................... 26

7. Contingency Measures............................................................................................... 27

8. Future Growth ........................................................................................................... 28

9. Conclusion .................................................................................................................. 29

Response to 40 CFR Part 51, Appendix V, Criteria ................................................................ 30

Legal Authority ........................................................................................................................... 34

Materials Proposed to be Incorporated into the SIP............................................................... 36

Specified Limits and Conditions from Rayonier Permit 

(Permit No. 0890004-036-AC)........................................................................................ 36

Specified Limits and Conditions from RockTenn Permit 

(Permit No. 0890003-046-AC)........................................................................................ 49

Public Participation .................................................................................................................... 61
ii

Response to 40 CFR 51.102 Requirements............................................................................... 61

Notice of Opportunity to Submit Comments and Participate in Public Hearing................. 63

Requests for Districts/Locals to Provide Assistance to Public................................................ 65

Public Comments on SIP Notice................................................................................................ 66

DEP Response to Public Comments.......................................................................................... 67

Pre-Hearing Submittal to EPA.................................................................................................. 68

Materials Enclosed with Pre-Hearing Submittal..................................................................... 70

EPA Comments on Pre-Hearing Submittal.............................................................................. 71

DEP Response to EPA Comments............................................................................................. 73
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1

Letter of Submittal
2
3

Proposed Revision to State Implementation Plan

Submittal Number 2015-03

SO2 Nonattainment Area Plan

Nassau County, Florida

Executive Summary

Introduction

The Department of Environmental Protection (DEP) is proposing a revision to Florida’s State 

Implementation Plan (SIP) under the federal Clean Air Act (CAA). This SIP revision consists of 

a nonattainment area plan that will ensure the attainment and maintenance of the 2010 revised 

Sulfur Dioxide (SO2) National Ambient Air Quality Standard (NAAQS) in Florida’s SO2

nonattainment area located in Nassau County. Florida’s nonattainment area plan consists of 

specific conditions from two federally enforceable air construction permits for two pulp and 

paper mill facilities in Fernandina Beach, Florida – Rayonier Performance Fibers, LLC 

(Rayonier) and RockTenn CP, LLC (RockTenn) – as they pertain to emissions of SO2.

Background

On June 22, 2010 (effective August 23, 2010), the U.S. Environmental Protection Agency (EPA) 

promulgated a revised National Ambient Air Quality Standard (NAAQS) for SO2. The level of 

the revised standard is 75 parts per billion (ppb), three-year average of the annual 99th percentile 

of one-hour daily maximum concentrations. The revised SO2 standard is the first one-hour 

primary standard promulgated by EPA for this air pollutant.

On August 5, 2013 (effective October 4, 2013), EPA designated a small area (2.4 km radius 

circle) in Nassau County, Florida nonattainment for SO2 based on air quality monitoring data 

showing violation of the revised standard over the three-year period of 2009 to 2011. 78 FR 

47191. The designated nonattainment area is described as follows:

That portion of Nassau County encompassing the circular boundary with the 

center being UTM Easting 455530 meters, UTM Northing 3391737 meters, UTM 

zone 17, using the NAD83 datum (the location of the violating ambient monitor) 

and the radius being 2.4 kilometers.

78 FR 47198. The nonattainment area contains within its boundaries one major point source for 

SO2 emissions – Rayonier’s Fernandina Beach Sulfite Pulp Mill. DEP determined that a second 

major point source of SO2 emissions in the immediate vicinity of the nonattainment area is a 

significant contributor to elevated concentrations within the defined nonattainment area –

RockTenn’s Fernandina Beach Mill. This proposed revision to Florida’s SIP addresses SO2

emissions from both of these facilities.
4

Rayonier Permit

Rayonier’s Fernandina Beach Sulfite Pulp Mill is located at the foot of Gum Street, Fernandina 

Beach, Florida 32034. The Rayonier Mill produces approximately 155,000 metric tons of 

chemical cellulose each year. The high purity wood pulps processed by Rayonier are used in 

manufacturing photographic films, filters, and rayon fabric, among other industrial and consumer 

products.

On April 12, 2012, DEP issued a federally enforceable air construction permit to Rayonier 

(Permit No. 0890004-036-AC) (Rayonier Permit). Under the Rayonier Permit, the facility was 

authorized to construct a new, taller stack (to at least 165 feet) for the Vent Gas Scrubbing 

System (EU No. 005) and to extend the stack at the Power Boiler (EU No. 022), if needed. The 

permit also lowered the allowable SO2 emission limits for the Recovery Boiler (EU No. 006) not 

to exceed 250 ppmvd (three hour average); Power Boiler (EU No. 022) not to exceed 340 

nanograms per joule heat input; and the Vent Gas Scrubber System (EU No. 005) not to exceed 

100 ppm (three hour average). The construction project associated with this permit was not 

intended or expected to result in an increase in the production capacity of the mill. 

Implementing these changes significantly lowers the modeled SO2 impact from the Rayonier 

facility on the ambient air of Nassau County, including at the location of the monitor, which 

currently shows compliance with the standard. 

On May 30, 2014, DEP issued a revised Title V air operation permit (0890004-042-AV) to 

incorporate the Rayonier Permit, and authorized Rayonier to operate the facility in accordance 

with the terms and conditions of the revised Title V permit.1 

RockTenn Permit

RockTenn’s Fernandina Beach Mill is located at 600 North 8th Street, Fernandina Beach, Florida 

32034. The RockTenn Mill produces a range of containerboard products.

On January 9, 2015, DEP issued a federally enforceable air construction permit to RockTenn 

(Permit No. 0890003-046-AC) (“RockTenn Permit”), which allows the facility to undertake 

construction and implement a variety of controls associated with its SO2 emissions. The 

RockTenn Permit authorizes two phases of physical and operational changes to the four largest 

SO2 emitting units at the RockTenn facility. Included among these are improvements to each of 

the facility’s two recovery boilers to achieve a more stable and consistent combustion and 

chemical recovery process, and the installation and operation of a piping system to transport noncondensable gases (NCGs) for combustion in the No. 7 Power Boiler. All construction and 

operational changes shall be completed no later than December 1, 2017. The construction 

projects associated with the RockTenn Permit are not intended or expected to result in an 

increase in the production capacity of the mill. Implementing these changes significantly lowers

the modeled SO2 impact from the RockTenn facility on the ambient air of Nassau County. 

All control strategies, physical changes, and emissions limits included in the RockTenn 

construction permit will be incorporated into the facility’s Title V permit upon renewal.

 1 Rayonier’s Title V permit reflected the as-built status of the Vent Gas Scrubbing System stack as 180 feet.
5

SIP Development Process

Section 403.061(35), Florida Statutes, authorizes DEP to “exercise the duties, powers, and 

responsibilities required of the state under the federal Clean Air Act.” These duties and 

responsibilities include the development and periodic updating of Florida’s SIP. Pursuant to this 

authority, DEP has developed this proposed SIP revision.

Pursuant to state administrative procedures and 40 CFR 51.102, on February 17, 2015, DEP 

published a notice in the Florida Administrative Register (FAR) announcing the opportunity for 

the public to provide comments, request a public hearing, and participate in a public hearing to 

be held on March 20, 2015, if requested, regarding the proposed revision to Florida’s SIP. No 

hearing was requested, therefore no hearing was held.

In accordance with the 30-day notice requirement of 40 CFR 51.102, a pre-hearing submittal 

regarding the proposed SIP revision was transmitted to EPA on February 17, 2015, and posted 

on the website for DEP’s Division of Air Resource Management. At the same time, notice of the 

opportunity to submit comments, request a public hearing, and participate in the public hearing, 

if requested, was transmitted to Florida’s local air pollution control programs.

Attainment of the SO2 Standard

Rayonier has completed all construction and process changes associated with the Rayonier 

Permit. Although construction at the RockTenn facility is permitted through December 31,

2017, for reasons detailed below, DEP is confident that attainment of the SO2 standard will be 

met well before the required attainment date of October 4, 2018. In fact, as of the date of this 

proposed SIP revision, the reference monitor that was the basis for designation of the 

nonattainment area already has three years of complete data well within attainment for the 

revised SO2 standard. With specific regard to RockTenn, the facility is implementing a phased 

program of construction to address SO2 emissions from multiple emissions units. The facility is 

implementing a range of SO2 emissions controls under the RockTenn Permit in order to 

demonstrate attainment with the 2010 SO2 NAAQS within the nonattainment area at allowable 

emission rates. Review of actual emission rates provides DEP with reasonable assurance that the 

entire nonattainment area is already attaining the 2010 SO2 NAAQS. Thus, the terms of the 

RockTenn Permit that allow for completion of the final phase of construction after January 1, 

2017—technically indicating full compliance with the control strategy for modeled attainment at 

permitted allowable emissions rates—does not delay expeditious attainment of the NAAQS. The 

NAAQS is currently being met, and DEP fully expects for the area to remain in attainment 

during the period under which RockTenn is implementing its control strategy. In addition, all of 

the SO2 emissions controls and limits required by this proposed SIP revision will be completed 

and in force no later than December 31, 2017, more than nine months before the CAA 

compliance deadline of October 4, 2018. 

Under the CAA, Florida is required to submit to EPA a proposed revision to its SIP that provides 

for attainment and maintenance of the revised SO2 NAAQS as expeditiously as possible, but no 

later than five years after designation of the nonattainment area. The proposed SIP revision is 

due 18 months after designation of the area. DEP has determined that improvements at the 
6

Rayonier and RockTenn facilities, as authorized by their respective air construction permits, will 

provide for expeditious attainment and maintenance of the revised SO2 NAAQS in the Nassau

County nonattainment area. DEP is proposing, therefore, that specific conditions of these air 

construction permits pertaining to emission of SO2, including new SO2 emission limits, operating 

limitations, and stack height increases, as detailed under the section of this submittal titled

“Materials to be Incorporated into the SIP,” be incorporated into Florida’s SIP in satisfaction of 

CAA requirements.
7

SO2 Attainment Demonstration – Technical Document

1. Emissions Inventory

Section 172(c)(3) of the Clean Air Act (CAA) requires that nonattainment plan provisions 

include a comprehensive, accurate base-year inventory of actual emissions from all sources of 

SO2 in the nonattainment area. Rayonier Performance Fibers (Rayonier) is the only point source 

of SO2 emissions in the nonattainment area. An adjacent paper mill owned and operated by 

RockTenn is located just outside of the nonattainment area and is the largest SO2 source in the 

area. Both Rayonier and RockTenn are included in this emissions inventory. 

Designation of the area as nonattainment was based on data for the period 2009-2011. Data from

2011 is representative of the state of the facility that caused the monitored violations that led to 

the area being designated nonattainment for the revised SO2 NAAQS. As such, SO2 emissions 

data for the purposes of the nonattainment area emissions inventory were taken from both 

facilities’ Annual Operating Reports (AOR) for 2011, which contain SO2 emissions from 

Rayonier’s and RockTenn’s stacks. According to these reports, 561.97 tons of SO2 were emitted 

from the Rayonier stacks and 3,716.67 tons of SO2 were emitted from the RockTenn stacks in 

2011. The emission sources from each facility’s 2011 AOR are detailed below in Table 1 and 

Table 2. 

Table 1

Summary of Rayonier's 2011 AOR

Emission Unit Number Unit Description SO2 EMISSIONS (tons)

EU005 Vent Gas Scrubber 10.42

EU006 Recovery Boiler 521.85

EU022 No. 6 Power Boiler 29.70

Total 2011 Rayonier SO2 Stack Emissions 561.97

Table 2

Summary of RockTenn’s 2011 AOR

Emission Unit Number Unit Description SO2 EMISSIONS (tons)

EU006 No. 5 Power Boiler 237.74

EU007 No. 4 Recovery Boiler 113.09

EU011 No. 5 Recovery Boiler 104.37

EU013 No. 4 Smelt Dissolving Tank 1.47

EU014 No. 5 Smelt Dissolving Tank 1.50

EU015 No. 7 Power Boiler 3,160.74

EU021 No. 4 Lime Kiln 97.76

Total 2011 RockTenn SO2 Stack Emissions 3,716.67

In addition to stack (point source) emissions listed in Tables 1 and 2, a small amount of SO2

emitted by onroad mobile, area/nonpoint, and nonroad mobile sources in the nonattainment area 
8

was included in the emissions inventory. Onroad mobile emissions were quantified using EPA’s 

MOVES2014 model in county inventory mode with data from Nassau County and neighboring 

Duval County. Duval County is within the same Core-Based Statistical Area as Nassau County 

and is considered to be representative of the area. All other emissions were estimated by utilizing 

the 2011 National Emissions Inventory (NEI).

2 The use of the NEI is reasonable for the nonroad 

and area/nonpoint source categories given their relative scale to the point source emissions 

(several orders of magnitude smaller). More detailed data is neither warranted nor necessary. The 

county-wide MOVES2014 results along within the NEI emissions were then scaled down based 

on the fraction of the county land area contained within the nonattainment area (13.75 

km2/1673.5 km2 or 0.82%). These other sources amounted to an additional 0.56 tons of SO2

emitted in the nonattainment area in 2011. Given the rural nature of Fernandina Beach and the 

small size of the nonattainment area, this is considered to be a conservative estimation. Table 3a

presents a complete 2011 base year SO2 emissions inventory for the SO2 nonattainment area in 

Nassau County. A detailed description of the source categories and methods can be found in 

Appendix A.

Table 3a

2011 Base Year SO2 Nonattainment Area Emissions Inventory* (tons)

Point Sources Onroad Mobile Sources Nonroad Sources Area/Nonpoint Sources Total 2011 SO2 Emissions

4,278.64 0.08 0.09 0.39 4,279.20

*Includes RockTenn which is physically outside of the nonattainment area.

The hourly SO2 emissions after the SO2 reduction projects at Rayonier and RockTenn, as 

detailed in this plan and as required by enforceable permits, will be significantly reduced. 

Rayonier’s allowable SO2 emissions (total from all three modified units) will be reduced from 

836.5 lb/hr to 502.3 lb/hr – a 40% decrease. RockTenn’s allowable SO2 emissions from the 

power boiler No. 5 will be reduced from 550 lb/hr to 15 lb/hr – a 97% decrease. In addition, the 

recovery boilers will also have SO2 emissions decreases due to the combustion modifications, 

but as there was no previous emission limitation, a specific allowable decrease cannot be 

calculated. The SO2 reduction project at Rayonier has been completed, and this project has 

resulted in significant early reductions in ambient SO2 in the nonattainment area. The SO2

reduction project at RockTenn will be completed no later than December 31, 2017, more than 

nine months before the CAA compliance deadline of October 4, 2018. Data from the reference 

monitor for the nonattainment area already show that the area is in compliance with the revised 

SO2 standard. As described below, the air quality analysis demonstrates that the nonattainment 

area will continue to comply with the revised SO2 NAAQS as the result of significant real 

reductions of SO2 emissions at both the Rayonier facility and the RockTenn facility. 

For reference, an estimated future year emissions inventory has been provided for the attainment 

year 2018 in Table 3b below. The estimated actual emissions for Rayonier and RockTenn were 

 2 The 2011 National Emissions Inventory. U.S. Environmental Protection Agency, Research Triangle Park, North 

Carolina 27711. http://epa.gov/ttnchie1/net/2011inventory.html
9

calculated by multiplying each facility’s 2018 allowable emissions by the ratio of their 2011 

actual to allowable emissions. The onroad mobile category was again quantified using the 

MOVES2014 model. Data inputs to the model were adjusted based on the projected population 

of Nassau County in 2018.

3 All other source categories derived from the 2011 NEI were 

increased based on the expected population increase of Nassau County between 2011 and 2018 

(916,733/871,803 or 5.2%).

Table 3b

2018 Future Year SO2 Nonattainment Area Emissions Inventory* (tons)

Point Sources Onroad Mobile Sources Nonroad Sources Area/Nonpoint Sources Total 2018 SO2 Emissions

3,376.26 0.03 0.10 0.41 3,376.80

*Includes RockTenn which is physically outside of the nonattainment area.

2. Construction Permits

DEP has issued final construction permits to both Rayonier (0890004-036-AC) and RockTenn 

(0890003-046-AC) authorizing the facilities to perform SO2 reduction projects in order to lower 

the ambient SO2 concentrations in the nonattainment area and bring the area into compliance

with the revised SO2 1-hr NAAQS.

Rayonier Permit

Rayonier received a construction permit on April 12, 2012 from DEP to lower SO2 maximum 

allowable emission rates on all three of its SO2 emitting units and increase the stack height on its 

Vent Gas Scrubber (Table 4). The project was completed in the second quarter of 2014 and the 

new stack parameters and emission rates were incorporated into the facility’s revised Title V 

Operating Permit (0890004-042-AV) on May 6, 2014. All three SO2 units have in-stack 

continuous emission monitoring systems (CEMS) for SO2 to ensure compliance with their SO2

emission limits in accordance with Section 113(a)(1) of the CAA.

Table 4

Rayonier Facility SO2 Reduction Project Source Changes

Source SO2 Emission Limit* Stack Height

Previous New Previous New

Vent Gas Scrubber 250 ppm (63.2 lb/hr) 100 ppm (25.3 lb/hr) 110 ft 180 ft

Recovery Boiler 300 ppm (353.3 lb/hr) 250 ppm (297 lb/hr) No Change

No. 6 Power Boiler 420 lb/hr 180 lb/hr No Change^

*All SO2 emission limits are 3-hr rolling averages.

^Rayonier was given the option of raising the stack height on the power boiler. They chose instead to impose a 

lower emission limit.

 3 Population projections performed by: Florida Demographic Estimating Conference, February 2014 and the 

University of Florida, Bureau of Economic and Business Research, Florida Population Studies, Bulletin 168, April 

2014. http://edr.state.fl.us/Content/population-demographics/data/Medium_Projections.pdf
10

RockTenn Permit

The construction permit for RockTenn’s SO2 reduction project was issued on January 9, 2015. 

The project will involve physical and operational changes to the four largest SO2 emitting units 

at the RockTenn facility, as summarized in Table 5. The project will be conducted in two 

phases:

• Phase I will be completed no later than December 31, 2016 and will consist of a 

combustion air system upgrade to one of the two recovery boilers (No. 4 or No. 5). The 

improvements to the combustion air system will achieve more stable and consistent 

combustion within the unit. .

• Phase II will be completed no later than December 31, 2017 and will include combustion 

air system upgrades to the other recovery boiler (No. 4 or No. 5), the addition of a white 

liquor scrubber system, and construction of a non-condensable gas (NCG) pipeline to the 

No. 7 Power Boiler. Low volume, high concentration (LVHC) NCG from the batch 

digester system, continuous digester system, turpentine recovery system, evaporator 

systems, and foul condensate collection tank are currently collected and burned in the No. 

5 Power Boiler as the backup control device to the No. 4 Lime Kiln for compliance with 

40 CFR 63, Subpart S. A pipeline will be installed to reroute the NCG to the No. 7 

Power Boiler. Upstream of the introduction of NCGs to the No. 7 Power Boiler, a 

packed column scrubber system will be installed to remove total reduced sulfur (TRS) 

from the NCG stream before combustion. 

This schedule of construction projects at the RockTenn facility is considered to be as 

expeditiously as practicable and will allow for attainment of the SO2 1-hr NAAQS prior to the 

attainment date of October 4, 2018. As previously noted, data from the reference monitor for the 

nonattainment area already show that that area is in compliance with the revised SO2 standard.

For compliance purposes, a mixture of CEMS and stack testing will be required. An SO2 CEMS 

is already operational on the No. 5 Power Boiler. RockTenn is required to install and operate an 

SO2 CEMS on the No. 7 Power Boiler no later than December 31, 2017. The recovery boilers 

will demonstrate compliance with SO2 CEMS data after the air system upgrades. RockTenn may 

elect to establish a relationship between SO2 emissions and key operating parameters, and 

request approval of a combination of periodic compliance testing (e.g., quarterly stack tests that 

collect 24-hours of continuous data) plus continuous parametric monitoring as an alternative to 

the installation and operation of certified CEMS. The CEMS must be recording valid data by 

January 1, 2018. Should Rock-Tenn choose to pursue periodic testing, in lieu of CEMS, initial 

compliance based on this method must be demonstrated by January 1, 2018. 
11

Table 5

RockTenn Facility SO2 Reduction Project Source Changes

Source SO2 Emission Limit Other Changes Current New*

No. 5 Power Boiler 550 lb/hr** 15 lb/hr Removal of NCGs.

No. 4 Recovery Boiler None 300 lb/hr cap Improvements made to combustion air system.

No. 5 Recovery Boiler None Improvements made to combustion air system.

No. 7 Power Boiler No Change Addition of NCG pipeline for backup combustion 

(white liquor scrubber added upstream).

* All new SO2 emission limits are 3-hr rolling averages.

** 24-Hour Average

3. RACM/RACT

Section 172(c)(1) of the CAA requires that SIPs for nonattainment areas “provide for the 

implementation of all reasonably available control measures (RACM) as expeditiously as 

practicable (including such reductions in emissions from existing sources in the area as may be 

obtained through the adoption, at a minimum, of reasonably available control technology 

[RACT]) and shall provide for attainment of the national primary ambient air quality standards.”

As EPA has interpreted section 172(c)(1), a state must “consider all potentially available 

measures to determine whether they [a]re reasonably available for implementation in the area, 

and whether they would advance the [area’s] attainment date.” See Approval & Promulgation of 

Air Quality Implementation Plans, 66 FR 586 at 607 (Jan. 3, 2001); see also Sierra Club v. EPA, 

294 F.3d 155, 162–63 (D.C. Cir. 2002).

EPA has defined RACT as: “the lowest emission limitation that a particular source is capable of 

meeting by the application of control technology that is reasonably available considering 

technological and economic feasibility.” (44 FR 53762; September 17, 1979.) See Memorandum 

from Roger Strelow titled, “Guidance for Determining Acceptability of SIP Regulations in NonAttainment Areas.” (December 9, 1976); see also ‘‘State Implementation Plans; General 

Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990,” 57 FR 

13498 (April 16, 1992). RACT requirements are specifically intended to impose emission 

controls for purposes of attainment and maintenance of the NAAQS within a specific 

nonattainment area. EPA has interpreted the terms RACT and RACM as being the level of 

emissions control that is necessary to provide for expeditious attainment of the NAAQS within a 

nonattainment area. See, e.g. Proposed Rule, 79 FR 32894. Courts have upheld this 

interpretation of the statute with respect to nonattainment SIPs. See NRDC v. EPA, 571 F.3d 

1245, 1252-53 (D.C. Cir. 2009).

DEP’s permitting records for Nassau County demonstrate that Rayonier is the only source of SO2

located in the nonattainment area and, consistent with CAA requirements under 42 U.S.C. § 

7502(c)(1), Rayonier is the only source for which a RACM/RACT analysis is required.

4

 4 As noted above, Section 172(c)(1) of the Clean Air Act requires that SIPs for nonattainment areas undertake 

RACM/RACT analyses at “existing sources in the area.” 42 U.S.C. § 7502(c)(1). A formal RACM/RACT analysis 

was not undertaken for RockTenn, as the facility is located outside of the nonattainment area, and the SIP attainment 

demonstration requires an area-specific analysis that there are no additional economically and technologically 
12

DEP reviewed a variety of measures and technology that could be implemented by Rayonier in 

order to reduce ambient SO2 concentrations and comply with the revised SO2 NAAQS. DEP 

considered a range of potentially available control technologies to determine whether they were 

reasonably available for Rayonier to implement, and whether they would advance the area’s

attainment date. DEP specifically considered three general approaches to SO2 emission 

reduction: 

• More efficient scrubber operation: All three SO2 sources at the Rayonier facility are 

already equipped with SO2 scrubber systems. These scrubbers are the primary method of 

SO2 control and can achieve significant reductions in emissions. Although these 

scrubbers began operation before the nonattainment designation, they have historically 

been operated to maintain compliance with the less-strict 1971 SO2 NAAQS and can be 

operated in a more efficient manner.

• Restriction of high-sulfur fuels: Fuel sulfur content can have a significant effect on SO2

emissions. Both the Sulfite Recovery Boiler and the No.6 Power Boiler are authorized to 

fire No. 6 fuel oil with a sulfur content of up to 2.5% by weight. This is a significantly

higher sulfur content than other alternate fuels.

• Increases in stack height: Shorter stacks can subject the plume to the effects of building 

downwash. This meteorological process can result in a concentrated plume reaching 

ground level very rapidly. An increased release height can decrease ambient 

concentrations of SO2 by allowing the plume more time to disperse more efficiently away 

from turbulent air within the planetary boundary layer.

DEP’s final RACM/RACT determinations for each source are as follows:

• Sulfite Recovery Boiler: The Sulfite Recovery Boiler is the largest SO2 source at the 

Rayonier facility. The boiler fires spent liquor for the purposes of producing both 

combustion gases that contain recoverable SO2 and heat for steam generation. Flue gases 

exiting the boiler are routed to an existing multi-stage wet scrubber. The scrubber serves 

dual roles of process equipment to recover SO2 and air pollution control to reduce 

emissions of particulate matter and SO2. The initial stage of scrubbing reduces emissions 

of particulate matter through the quench tower and the scrubber heat removal sections. 

The final stage of scrubbing consists of a two-section absorber that utilizes ammonium 

hydroxide as a scrubbing medium. Water and aqueous ammonia are added to the upper 

section for pH control and a constant ammonia flow is added to the lower section. To 

optimize the control of SO2 emissions, the upper absorber pH target and the lower 

 feasible control measures that will advance the attainment date. As previously observed, the reference monitor that 

was the basis for designation of the nonattainment area already has three years of complete data well within 

attainment for the revised SO2 standard. DEP has developed a control strategy for RockTenn incorporating a range 

of SO2 emissions control measures that will ensure that the designated nonattainment area remains in attainment and 

models attainment throughout the nonattainment area at permitted emissions levels, and RockTenn is required to 

fully implement this control strategy by December 31, 2017, more than nine months prior to the CAA attainment 

deadline.
13

absorber ammonia addition rate can be adjusted. SO2 is recovered from the cooled flue 

gases in this final stage by reaction with fresh aqueous ammonia to form an ammonium 

bisulfite solution. Exit gases from the scrubber are routed to a high velocity mist 

eliminator, the Brinks Demister, to reduce the fine particulate matter byproduct of the 

ammonium bisulfite absorption. DEP has determined that careful adjustment and 

monitoring of the amount of ammonia injected into the scrubber provides reasonable 

assurance that the facility is capable of decreasing the emissions of SO2 from this unit 

without increasing emissions of the fine particulate byproduct. DEP determined that this 

was the only reasonable control measure for the recovery boiler as it is run at an optimal 

SO2 recovery target for process purposes (recovery of chemicals) regardless of fuel 

source; therefore, an increase or decrease in fuel sulfur content is not expected to have an 

impact on SO2 emissions. In addition, the stack height is sufficient to avoid downwash 

effects. Rayonier proposed a reduction in their maximum allowable SO2 emission limit 

from 300 ppm to 250 ppm reflecting the improvements in the scrubber operation. DEP 

determined that this reduction was achievable and reflects the operation of reasonable 

control measures for this unit.

• No. 6 Power Boiler: The primary fuel fired in the No. 6 Power Boiler is biomass (wood 

bark, chips, and waste). Alternate fuels include No. 6 fuel oil with a maximum sulfur 

content of 2.5%. It is equipped with a wet alkaline scrubber for control of SO2 emissions. 

DEP considered further restricting the use of No. 6 fuel oil but it was determined that this 

would have a limited effect on SO2 emissions as it is only fired during startup, shutdown, 

and solid fuel feed upsets. The boiler emitted just 6.3 tons of SO2 in 2013 due to the 

effective use of the scrubber, restricted operating parameters, and limited use of No. 6 

fuel oil. The existing control equipment, restricted operating parameters, and 

demonstrated actual emissions in 2013 provide reasonable assurance that the unit can 

meet a reduced SO2 emission limit. As with the Sulfite Recovery Boiler, the current 

stack height is sufficient to avoid building downwash effects. Rayonier proposed a 

reduction in the enforceable SO2 emission limit for this unit from 420 lb/hr to 180 lb/hr.

• Vent Gas Scrubber: The Vent Gas Scrubber is in itself SO2 control equipment. This wet 

scrubber controls emissions from numerous vents from the cooking acid plant, the red 

stock washers, the unwashed stock tank, the spent sulfite liquor storage tanks, the spent 

sulfite liquor washer area, the digesters, and the blow pits. The scrubber consists of a 

packed tower split into two sections with gases flowing upward through the packing. The 

lower section is designed to control emissions of SO2 through gas absorption using 

alkaline scrubbing media. The upper section of the scrubber is designed as a direct 

contact condenser that is used to collect methanol. A distributive control system is used 

manage operating problems and calculates one-hour and 24-hour running averages of the 

SO2 concentration. The stack for this scrubber is only 110 feet in height, which is lower

than the good engineering practice (GEP) height. An increase in the height of this stack

would provide for potentially significant reductions in ground-level SO2 concentrations 

near the facility. This strategy was deemed reasonable because the relatively low older 

stack was subject to building downwash effects. An increase in stack height allows more 

efficient and effective dispersion of the SO2 emissions over a larger area. Rayonier 
14

proposed to increase this stack from 110 feet to 180 feet. In addition, Rayonier proposed 

to reduce the maximum allowable SO2 emission limit from 250 ppm to 100 ppm. 

DEP determined that these measures at its three SO2 sources constitute RACM/RACT for the 

Fernandina Beach SO2 nonattainment area. Rayonier will obtain the lowest emission limitation 

that the source is capable of meeting by the application of control technologies that DEP has 

determined to be both technologically and economically feasible. The reduced SO2 emission 

limits made possible by these changes will allow for expeditious attainment and maintenance of 

the revised SO2 NAAQS in the nonattainment area. In fact, data from the reference monitor for 

the nonattainment area already show that the area is in compliance with the revised SO2 standard.

On October 14, 2014, DEP received an application for a minor air construction permit requesting 

authorization to construct a new natural gas-fired combustion turbine cogeneration system within 

the Nassau County nonattainment area. The new facility would be located on existing Rayonier 

property. The proposed combustion turbine would generate up to 21 MW supplied to the 

electrical grid. The proposed heat recovery steam generator would produce approximately 

74,000 lb/hr of process steam to deliver to the co-located Rayonier plant and an additional 

126,000 lb/hr of steam could be generated during supplemental firing of natural gas in the heat 

recovery generator duct burners. Maximum annual SO2 emissions would be less than 7 tons per 

year. Although this proposed new facility will not be subject to new source review, DEP has 

evaluated the SO2 emissions increase attributable to this proposed construction project and 

determined that the small increase in SO2 emissions would not interfere with the state’s 

attainment plan. 
15

4. Air Quality Modeling Demonstration

4.1 Model Selection and Control Options

The AERMOD modeling system (including the terrain processor, AERMAP, and the 

meteorological data processor, AERMET) was used to analyze the impact of the modified 

facilities on the ambient SO2 concentrations in the nonattainment area. Federally enforceable 

permit emission limits were used as model inputs. The modeling demonstration utilized the most 

current versions of the AERMOD models available at the time the modeling demonstration was 

performed. The model versions used are listed below in Table 6.

Table 6

Model Versions Used in the SO2 Air Quality Modeling Attainment Demonstration

Model Version

AERMOD 14134

AERMET 14134

AERMAP 11103

A series of specific model features in AERMOD recommended by EPA, referred to as the 

regulatory options, were used in the modeling analysis.

4.2 Modeled Sources

This air quality modeling demonstration includes all SO2-emitting sources for the Rayonier 

facility as well as the RockTenn facility, the only significant sources of SO2 emissions within 25 

km of the nonattainment area (Figure 1). A number of other sources in the area were considered 

for inclusion but were determined to not have a significant contribution to SO2 levels in the 

nonattainment area based on monitoring data. These sources are accounted for in the added 

background concentration. Stack parameters and other source characteristics for Rayonier and 

RockTenn were obtained from the construction permits. Table 7 and Table 8 summarize the

source parameters and SO2 emission rates for all modeled point sources at the Rayonier and 

RockTenn facilities.
16

Figure 1. Nassau County, Florida SO2 Nonattainment Area

Table 7

Fernandina Beach SO2 Attainment Demonstration – Modeled SO2 Emission Rates

Source ID Type Company Description EU ID Modeled Emission Rate

grams/second pounds/hour

RAYVGS Point Rayonier Vent Gas Scrubber 5 4.99 39.62

RAYRECB Point Rayonier Sulfite Recovery Boiler 6 38.26 303.68

RAY6 Point Rayonier No. 6 Power Boiler 22 24.05 190.88

RTN6 Point RockTenn No. 5 Power Boiler 6 2.04 16.20

RTN15 Point RockTenn No.7 Power Boiler 15 156.09 1238.85

RTN7 Point RockTenn No. 4 Recovery Boiler 7 18.98 150.60

RTN11S Point RockTenn No. 5 Recovery Boiler South Stack 11 9.47 75.15

RTN11N Point RockTenn No. 5 Recovery Boiler North Stack 11 9.47 75.15

RTN21 Point RockTenn No. 4 Lime Kiln 21 2.65 21.00

4SDT Point RockTenn No. 4 Smelt Dissolving Tank 13 0.13 1.03

5SDT Point RockTenn No. 5 Smelt Dissolving Tank 14 0.15 1.18
17

Table 8

Fernandina Beach SO2 Attainment Demonstration – Modeled Source Parameters

Source

Coordinates Base Elevation Flowrate Diameter Exit Velocity Temperature Stack Height

UTMx (m) UTMy (m) (ft) (m) (ft3/min) (m3/sec) (in) (m) (ft/sec) (m/sec) (F) (K) (ft) (m)

RAYVGS 454,896.18 3,392,372.58 7.55 2.30 28,331.54 13.37 60.00 1.52 24.05 7.33 122.09 323.20 180.00 54.86

RAYRECB 454,709.49 3,392,187.40 9.32 2.84 144,004.78 67.89 88.00 2.23 56.82 17.32 113.99 318.70 250.00 76.20

RAY6 454,998.57 3,392,492.97 12.47 3.80 256,955.08 121.27 120.00 3.05 54.53 16.62 286.97 414.80 190.00 57.91

RTN6 456,293.23 3,394,423.21 12.99 3.96 238,739.02 112.70 114.00 2.90 56.14 17.11 427.73 493.00 260.00 79.25

RTN15 456,256.65 3,394,391.51 13.32 4.06 384,610.11 181.48 156.00 3.96 48.29 14.72 397.13 476.00 342.65 104.44

RTN7 456,320.64 3,394,493.25 14.67 4.47 314,878.19 148.59 138.00 3.51 50.52 15.40 442.13 501.00 250.33 76.30

RTN11S 456,430.12 3,394,501.18 15.85 4.83 190,350.84 89.82 108.00 2.74 49.87 15.20 431.33 495.00 288.65 87.98

RTN11N 456,441.28 3,394,514.19 15.85 4.83 190,350.84 89.82 108.00 2.74 49.87 15.20 431.33 495.00 288.65 87.98

RTN21 456,547.48 3,394,530.29 12.63 3.85 88,898.42 41.96 60.00 1.52 75.46 23.00 379.13 466.00 100.49 30.63

4SDT 456,320.58 3,394,479.65 14.67 4.47 37,569.24 17.73 72.00 1.83 22.15 6.75 164.93 347.00 249.00 75.90

5SDT 456,424.65 3,394,499.68 15.85 4.83 32,652.78 15.41 48.00 1.22 43.31 13.20 168.53 349.00 288.16 87.83

4.3 Modeled Emission Rate Averaging Times

If a compliance averaging time for a SIP emission limit is longer than the averaging time for the 

applicable NAAQS (here, one hour), EPA guidance provides a method of calculating an 

“equivalent” longer-term emission limit where appropriate.5 The method involves finding the 

“critical emission value” – the emission rate at which the model would predict ambient SO2

concentrations at the level of the one-hour SO2 NAAQS – then adjusting this rate downward so 

as to achieve a comparable stringency to the modeled one-hour average emission limit. The 

premise of this approach is that a lower limit will sufficiently constrain the frequency and 

magnitude of occasional high emission rates within the chosen longer-term averaging period. 

The adjustment method suggested by EPA is to scale the longer-term average emission limit by 

the ratio of each source’s historic 99th percentile one-hour average emission rate to its 99th

percentile longer-term average emission rate. Further, the guidance states that “. . . if the new 

emission limit requires more stringent emission control than is currently in place at a source, the 

analyses should be designed, to the extent practicable, to reflect the hourly emissions variability 

that can be expected once the emission limit is in place.” With specific regard to RockTenn’s

Recovery Boilers No. 4 and No. 5, compliance with the new emissions limits will require the 

exclusive use of ultra-low sulfur diesel (ULSD), with a maximum sulfur content of 15 parts per 

million (0.0015 percent), as a fuel oil. The facility is allowed by permit to burn ULSD, and the 

use of ULSD was used in determining the critical emissions values for Recovery Boilers No. 4 

and No. 5.6

 

This analysis along with an overall analysis of each unit’s emissions variability was completed 

for both facilities and is summarized in Table 9. Based on this analysis, consistent with EPA’s 

Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions, DEP has adjusted both 

 5 Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions, Office of Air Quality Planning and Standards, 

U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711. 

http://www.epa.gov/ttn/oarpg/t1pgm.html 6 As noted in the “Materials to be Incorporated into the SIP” section of this submittal, effective January 1, 2018, fuel 

oil usage at Recovery Boilers No. 4 and No. 5 will be limited to ULSD.
18

Rayonier’s and RockTenn’s 1-hour modeled emission rates in Table 7 down to the “equivalent” 

longer-term compliance average emission limits given in Table 4 and Table 5. For reference, 

Table 10 provides a summary of this adjustment calculation.

Table 9

Source Emission Rate Variability Analysis

Company Source 99th Percentile Rate (grams/sec) Ratio 

1-Hr Average 3-Hr Average 3-Hr/1-Hr

Rayonier Vent Gas Scrubber* 3.56 2.27 0.639

Rayonier Sulfite Recovery Boiler* 37.17 36.36 0.978

Rayonier No. 6 Power Boiler* 6.96 6.56 0.943

RockTenn No. 5 Power Boiler^ 55.07 51.00 0.926

RockTenn No. 7 Power Boiler` 106.83 105.64 0.989

RockTenn No. 4 Recovery Boiler` 1.99 1.99 0.999

RockTenn No. 5 Recovery Boiler` 2.06 2.05 0.998

*Calculations based on CEMS data from 1/1/2010 – 12/31/2012.

^Calculations based on CEMS data from 1/1/2010 – 10/14/2013.

`Calculations based on calculated emission rates from 1/1/2010 – 10/14/2013.

See Appendix B

Table 10

Note: Compliance emission limits are less than or equal to the modeled rate x adjustment factor.

4.4 Meteorological Data Selection

The AERMET meteorological data used for this analysis consisted of a continuous five-year 

period of hourly surface weather observations and twice-daily upper air soundings from the 

Jacksonville National Weather Service Office at Jacksonville International Airport; the nearest 

surface weather observing station with a complete five-year dataset.7 The five-year period of 

meteorological data was from 2008 through 2012. This meteorological data set was compiled by 

 7 Although there are some meteorological data available from a location in Fernandina Beach, DEP elected not to 

utilize these data in its analysis for a number of reasons. Data prior to 2011 are not available from this location, and 

one-minute data are not available. The Jacksonville International airport data are the only complete available data 

representative of the Fernandina Beach area.

Source

Modeled 

Emissions Rate 

(lb/hr)

Averaging Time 

Adjustment Factor Based on:

Compliance 

(Permitted ) 

Limit (lb/hr)

Averaging 

Time

Rayonier

Vent Gas Scrubber 39.62 0.639 hourly CEMS 25.3 3-hour

Sulfite Recovery Boiler 303.68 0.978 hourly CEMS 297 3-hour

No. 6 Power Boiler 190.88 0.943 hourly CEMS 180 3-hour

Rock Tenn

No. 5 Power Boiler 16.2 0.926 hourly CEMS 15 3-hour

No. 7 Power Boiler 1238.85 0.989 hourly fuel use and emis. Factor 1225.25 3-hour

No. 4 Recovery Boiler 150.6 0.999 hourly fuel use and emis. Factor 150 3-hour

No. 5 Recovery Boiler 150.3 0.998 hourly fuel use and emis. Factor 150 3-hour

2-unit cap 300.9 0.997 hourly fuel use and emis. Factor 300 3-hour

Derivation of Compliance Emission Limits
19

DEP and processed using AERMINUTE in order to reduce the number of calms and missing 

winds in the surface data. EPA has established criteria for the use of meteorological data for 

modeling purposes that states that meteorological data should be 90% complete on a quarterly 

basis before any substitutions are made.8 The 2008-2012 dataset satisfies the 90% completeness 

requirement.

4.5 Surface Characteristics

Prior to running AERMET, it is necessary to specify the surface characteristics of the location 

being modeled. For this task, DEP used the AERMET preprocessor AERSURFACE. 

AERSUFACE utilized the 1992 National Land Cover Dataset (NLCD) for Florida to extract 

surface characteristics for a one-kilometer radius area around both the Jacksonville International 

Airport and the nonattainment area. Surface characteristics were computed monthly and surface 

roughness was varied over 12 sectors. The resulting average surface characteristics are 

summarized in Table 11. The values at both sites are very similar. In addition, the airport is just 

28 kilometers southwest of the nonattainment area, the land in between is generally flat, and both 

areas have similar rural topography. Based on this analysis, the Jacksonville International 

Airport surface dataset was considered to be representative of the domain for this modeling 

demonstration.

Table 11

Average Surface Characteristics Computed by AERSURFACE

Location Albedo Bowen Ratio Surface Roughness (zo)

Jacksonville International Airport 0.14 0.44 0.058

Fernandina Beach SO2 Nonattainment Area 0.13 0.21 0.321

4.6 Land Use Classification

Land-use classification was determined using Auer’s9 method and confirmed with population 

density data. The Auer method requires an analysis of the land use within a three-kilometer 

radius around a facility to determine if the majority of the land can be classified as either rural or 

urban. If more than fifty percent of the area consists of Auer land-use industrial, commercial, or 

residential land types, then urban dispersion coefficients are used in modeling; otherwise, rural 

dispersion coefficients are used. As shown in Figure 2 below, rural land use constitutes a 

majority (80%) of the combined three-kilometer radii around each facility. According to the 

U.S. Census Bureau, the population density of the city of Fernandina Beach was approximately 

408 people/km2 in 2013 which is below the EPA suggested urban threshold of 750 people/km2

. 

Based on this analysis, the rural dispersion coefficients were used in AERMOD.10

 8 Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, EPA-454/R-99-005, 

Meteorological Monitoring Guidance for Regulatory Modeling Applications, (February 2000). 9 Auer, Jr., A.H. “Correlation of Land Use and Cover with Meteorological Anomalies”. Journal of Applied 

Meteorology, 17:636-643, 1978. 10 State & County QuickFacts, United States Census Bureau. 

http://quickfacts.census.gov/qfd/states/12/1222175.html
20

Figure 2. Nassau County, Florida – SO2 Nonattainment Area Land Use

4.7 Terrain Data

Terrain elevations were incorporated into the modeling using AERMAP. For this modeling 

exercise, terrain data were extracted from National Elevation Dataset (NED) GeoTIFF files with 

a 1/3 arcsecond (~10m) grid spacing that were produced by the United States Geological Survey 

(USGS).

4.8 Building Downwash

For this air quality modeling demonstration, the EPA-approved Plume Rise Model 

Enhancements (PRIME) algorithm was utilized to determine the direction-specific building 

downwash parameters. Concentrations were predicted in both the near and far wake regions, 

with the plume mass captured by the near wake treated separately from the uncaptured primary 

plume, and reemitted to the far wake as a volume source. Direction-specific downwash 

parameters were used for all sources for which downwash was considered. The stacks associated 

with the project all satisfied the GEP stack height criteria. Modeled building parameters are 

available upon request.

4.9 Receptor Grid

A discrete Cartesian grid of 2,329 receptors with 100 meter spacing (50 meters along property 

boundaries) was used. The grid encompasses the entire nonattainment area, except facility 
21

property, extending up to 2.4 kilometers away from the nonattainment monitor in all directions 

as depicted in Figure 3. The RockTenn facility property boundary is completely fenced on the 

north, south, and east sides, and is bounded on the west by a secured frontage on the Amelia 

River, precluding the general public from accessing the facility. The Rayonier facility property 

boundary is comprised of fencing and natural barriers such as wetlands and dikes that preclude 

public access. A large area of adjacent Rayonier-owned property to the south of the facility was 

modeled as ambient air due to a lack of physical boundaries to prevent public access to the 

property. 

Figure 3. Nassau County, Florida Nonattainment Area Receptor Grid

4.10 Background Concentration

A set of background concentrations to account for all SO2 sources not explicitly modeled was 

developed for each hour of the day by season from local monitoring data. The procedure 

followed is outlined in EPA’s SO2 National Ambient Air Quality Standards Designations 

Modeling Technical Assistance Document.11 The data used were obtained from the Florida Air 

Monitoring and Assessment System (FAMAS) from monitoring station No. 12-089-0005 for the 

period January 2012 to December 2013. Due to a significant, multi-year decline in monitored 

SO2 concentrations at this site – illustrated in Table 12 – only the most recent two years of data 

were used rather than the recommended three years. 

 11 SO2 National Ambient Air Quality Standards Designations Modeling Technical Assistance Document. U.S. 

Environmental Protection Agency, Research Triangle Park, North Carolina 27711. 

http://epa.gov/airquality/sulfurdioxide/pdfs!S02ModelingTAD.pdf
22

Table 12

2003 – 2014 Monitored SO2 Design Values for Monitor ID: 12-089-0005-42401-1

Year Ranked 1-hr Averages Ranked 3-hr Averages Ranked 24-hr Averages Annual 99th Percentile Design

1st 2nd 1st 2nd 1st 2nd Average Complete Valid Value

2003 204 (04/22) 150 (05/12) 171 (04/22:21) 137 (05/12:21) 42 (04/22) 30 (05/12) 3.3 115 115 135

2004 103 (04/27) 97 (04/04) 75 (04/04:18) 67 (03/17:09) 30 (03/17) 30 (04/01) 3.0* 91* 91* 128*

2005 173 (04/13) 132 (02/12) 90 (04/13:18) 73 (02/12:00) 41 (09/13) 34 (02/11) 3.9* 98* 98* 101*

2006 278 (03/03) 273 (03/25) 157 (03/25:18) 149 (03/03:15) 63 (03/03) 40 (03/25) 4.5 176 176 122

2007 203 (03/22) 101 (03/04) 102 (03/22:21) 60 (03/04:06) 28 (03/04) 27 (01/25) 3.9 82 82 119

2008 146 (12/12) 100 (01/13) 83 (12/12:18) 79 (01/13:21) 30 (01/14) 28 (01/01) 3.3* 98* 98* 119*

2009 145 (03/02) 121 (09/29) 52 (03/03:00) 49 (09/29:18) 22 (12/20) 21 (12/26) 2.2 73 73 84

2010 345 (01/12) 344 (02/13) 317 (02/13:18) 159 (02/16:03) 68 (02/13) 58 (02/16) 4.3 216 216 129

2011 194 (01/12) 100 (02/13) 80 (10/28:06) 74 (06/01:06) 31 (01/12) 24 (11/10) 3.4 97 97 129

2012 117 (01/03) 88 (01/18) 58 (01/18:21) 56 (01/03:06) 23 (10/28) 19 (01/03) 2.1 54 54 122

2013 76 (05/24) 70 (02/01) 64 (05/24:12) 58 (02/01:18) 20 (05/24) 14 (01/21) 0.9 60 60 70

2014 48 (06/28) 40 (01/22) 28 (01/22:00) 26 (01/12:03) 13 (03/30) 12 (01/22) 2.2* 36* 36* 50*

* DEP anticipates that the complete design value for 2012-2014 will be available at the end of calendar year 2014.

As shown in Figure 3, the monitor is approximately 0.9 km to the southeast of Rayonier and is 

also the nonattainment monitor. Due to its close proximity to the Rayonier facility, monitored 

concentrations at this station are strongly influenced by facility emissions as illustrated in Figure 

4. The RockTenn facility is just 2.5 km to the north of the monitor and has a significant impact 

on recorded concentrations as well. As a result, the data were filtered to remove measurements 

where the wind direction could transport pollutants from either Rayonier or RockTenn to the 

station.

12 More specifically, the data were filtered to remove measurements where the hourly 

wind direction was in the range of 263o to 61o as shown in Figure 5. The 99th percentile 

concentration for each hour by season was then averaged across the two years and the resulting 

array was input to AERMOD with the BACKGRND SEASHR keyword. The final set of 

background concentrations is summarized in Table 13.

 12 This is a common practice used for developing background concentrations. Details of the procedures are outlined 

in 40 CFR Part 51 Appendix W – EPA’s Guideline on Air Quality Models.
23

Figure 4. 2012-2013 Average Ambient SO2 Concentration 

by Wind Direction at Monitor 089-005 in Fernandina Beach, Florida

Figure 5. Data filtered to remove measurements where 

the hourly wind direction was in the range of 263o to 61o.
24

Table 13

SO2 Background Concentrations by Hour-of-Day by Season for Monitor 089-0005 (ppb)

Hour Winter Spring Summer Fall Hour Winter Spring Summer Fall

0:00 2.0 1.0 2.0 4.5 12:00 4.0 3.0 3.0 3.0

1:00 2.0 1.0 1.0 3.5 13:00 3.0 3.0 2.0 2.0

2:00 3.0 1.0 1.5 2.5 14:00 2.5 3.5 2.0 2.5

3:00 2.5 1.0 1.5 1.5 15:00 2.5 2.0 2.0 2.5

4:00 2.5 1.0 1.5 2.5 16:00 2.0 1.5 2.5 2.5

5:00 2.0 1.5 2.5 4.5 17:00 1.0 1.0 1.5 3.0

6:00 3.0 1.5 2.0 4.0 18:00 2.0 2.0 3.0 2.5

7:00 2.0 1.5 3.0 4.5 19:00 1.0 1.5 1.5 2.5

8:00 2.0 1.5 3.5 5.0 20:00 1.0 1.5 1.0 1.5

9:00 4.0 2.0 7.5 4.5 21:00 2.0 1.0 1.0 3.0

10:00 4.5 4.0 6.0 4.5 22:00 1.0 1.0 1.0 3.5

11:00 6.0 2.5 6.0 4.5 23:00 1.5 1.5 3.0 2.5

4.11 Summary of Modeling Results

The EPA-recommended dispersion model AERMOD was used to evaluate the impact of the 

modified facilities on the ambient SO2 values within the nonattainment area. The model was run 

from 2008-2012 and the 99th percentile (4th high) maximum daily one-hour average 

concentration for each year at each receptor was averaged across all five years. 

As detailed previously, DEP established individual emission limits for most emission sources at 

Rayonier and RockTenn. However, a two-unit emissions cap was developed for RockTenn’s 

two recovery boilers in order to provide the facility with increased operational flexibility while 

simultaneously reducing SO2 emissions from these two units. To ensure protection of the 

NAAQS, DEP identified the worst case scenario of emissions distributions from these two units 

by performing three distinct modeling scenarios: the entire emissions cap emitted from the No. 4 

Recovery Boiler, the entire emissions cap emitted from the No. 5 Recovery Boiler, and the 

emissions cap distributed equally between the two units. Each of these scenarios was modeled 

with all other parameters remaining the same. The maximum predicted impact from each of the 

three model runs is summarized in Table 14.

Table 14

Maximum Modeled SO2 Impact in Nonattainment Area (μg/m3)

Model Scenario Averaging 

Time

Max Predicted Impact Background Total 

Impact 

SO2 1-Hour 

NAAQS

Greater Than 

Rayonier RockTenn NAAQS?

Unmodified 1-Hour 0.00* 2,957.80 4.19 2,961.99 196.4 Yes

Equal Cap Distribution 1-Hour 114.45 67.69 10.72 192.87 196.4 No

Entire Cap – No. 4 RB 1-Hour 110.93 71.56 9.16 191.65 196.4 No

Entire Cap – No. 5 RB 1-Hour 117.51 63.79 12.82 194.11 196.4 No

*The area of maximum impact contains no contribution from Rayonier at the time of the predicted maximum impact. 

Due to the close proximity of the RockTenn recovery boiler stacks and their distance from the 

nonattainment area, it was determined that modeled compliance is maintained regardless of the 

distribution of the emissions cap between these units. Figure 6 presents the maximum of the 
25

five-year average of 99th percentile maximum daily concentrations at each receptor in the 

nonattainment area for the equal cap distribution scenario – the scenario most representative of 

day-to-day operations. The area of highest concentration is found adjacent to the southwest 

corner of the Rayonier facility, on Rayonier-owned property, where emissions from sources at 

both facilities align. Under the scenario where the entire cap is shifted to the No. 5 Recovery 

Boiler, the area of maximum concentration occurs north of Rayonier near the RockTenn 

facility.

13

In accordance with EPA’s Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions, 

(April 2014), DEP modeled a suitable network of receptors representing the entire nonattainment 

area and included the sources both inside and outside the nonattainment area that were 

significant contributors to elevated SO2 levels in the area.

14 As shown, the modeling results 

predict no violations of the revised SO2 NAAQS within the nonattainment area. For comparison, 

Figure 7 shows a plot of the pre-modification potential emissions in the area on the same scale

as Figure 6 indicating a decrease in modeled ambient SO2 concentrations of more than 90%. 

Figure 6. Post-Modification Modeling Maximum Allowable SO2 Emissions

 13 A secondary maximum is located near the edge of the modeled area. DEP notes that EPA’s proposed Data 

Requirements Rule (79 FR 27446) sets forth a regulatory process to address modeled SO2 concentrations outside of 

designated nonattainment areas.

14 “The modeling for the attainment demonstration should include results for a suitable network of receptors 

representing the entire nonattainment area, and should exhibit modeling showing attainment of the NAAQS for the 

entire area by the statutory attainment date.” Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions (April 

2014), Section V.C. Attainment Demonstration, p. 12. “The modeling domain should at a minimum encompass the 

nonattainment area and include the sources thought most likely to cause or contribute to NAAQS violations in and 

around the nonattainment area.” Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions (April 2014), 

Appendix A, Section 5. Modeling Domain, p. A-7.

Maximum Concentration:

193 μg/m3

Post-Modification Allowable Emissions RockTenn
26

Figure 7. Pre-Modification Modeling Maximum Allowable SO2 Emissions

5. Conformity

CAA Section 176(c) requires that federal actions not cause or worsen air quality violations or 

delay attainment of a relevant NAAQS. This General Conformity Rule applies to any federal 

action within a nonattainment or maintenance area. Florida seeks through this SIP submittal 

approval of the state’s nonattainment area plan for Nassau County, in the form of federallyenforceable air permit conditions addressing SO2 emissions from two facilities, as detailed 

above. EPA’s approval of this SIP will not cause or contribute to a violation of any NAAQS. On 

the contrary, EPA’s approval of this SIP will provide assurance that the Nassau County 

nonattainment area attains the standard as expeditiously as practicable. 

6. Reasonable Further Progress

Reasonable further progress (RFP) generally applies to regional air pollutants that are emitted by 

numerous sources where the relationship between these sources and pollutant concentrations is 

indirect and/or poorly understood. EPA has stated that the RFP concept is less applicable to SO2, 

as SO2 is a localized pollutant with limited sources.15 Data from the reference monitor for the 

Nassau County nonattainment area already show that the area is in compliance with the revised

SO2 standard. As previously mentioned, Rayonier has completed its SO2 reduction project, and 

RockTenn is on a strict compliance schedule, as detailed in the construction permit attached to 

this SIP revision, which will ensure continued attainment of the revised SO2 standard. By 

 15 SO2 Guideline Document. Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency, 

Research Triangle Park, North Carolina 27711. 

Pre-Modification Potential Emissions RockTenn

Maximum Concentration:

2,962 μg/m3
27

implementing the control measures specified in this SIP revision as expeditiously as practicable, 

and by maintaining those control measures that have already been implemented, Rayonier and 

RockTenn will be in compliance with RFP as defined in Section 171(1) of the CAA.16

7. Contingency Measures

Section 172(c)(9) of the Clean Air Act requires that nonattainment plan provisions provide for 

the implementation of specific measures to be undertaken if the area fails to attain the revised 

SO2 NAAQS by the attainment date of October 4, 2018. In the “General Preamble for the 

Implementation of Title I of the Clean Air Act Amendments of 1990,” published on April 16, 

1992 at 57 FR 13498, EPA expressly discussed contingency measures for SO2. This guidance 

states that in many cases, as is the case with Florida’s Nassau County nonattainment area, 

attainment revolves around compliance of a single source or small set of sources with emission 

limits shown to provide for attainment. This guidance concludes that in such cases, “EPA 

interprets ‘contingency measures’ to mean that the state agency has a comprehensive program to 

identify sources of violations of the SO2 NAAQS and to undertake an aggressive follow-up for 

compliance and enforcement including expedited procedures for establishing enforceable 

consent agreements pending the adoption of revised SIPs.”17

Upon notification by DEP that a reference monitor for the area has registered SO2 levels in 

excess of the standard (75 ppb 1-hour daily maximum concentration) for a fourth time during a 

calendar year prior to the attainment date, or upon notification by DEP that the area has failed to 

attain the revised SO2 NAAQS by the attainment date, Rayonier and RockTenn will, without any 

further action by DEP or the U.S. Environmental Protection Agency, immediately undertake a 

full system audit of all emissions units subject to control under this nonattainment area plan. 

Rayonier and RockTenn will each independently submit to DEP in writing, within 10 days of 

notification of the fourth registered exceedance, a written system audit report detailing the 

operating parameters of all emissions units for four 10-day periods up to and including the dates

upon which the reference monitor registered each of the four exceedances, together with 

recommended provisional SO2 emission control strategies for each affected unit and evidence 

that these control strategies have been deployed, as appropriate. Upon receipt of these written 

system audit reports, DEP will immediately begin a 30-day evaluation period to diagnose the 

cause of the monitored exceedance. This will be followed by a 30-day consultation period with 

Rayonier and RockTenn to develop and implement operational changes necessary to prevent any 

future monitored violation of the standard. These changes could include, but would not be 

limited to, fuel switching to reduce or eliminate the use of sulfur-containing fuels, combustion air 

system enhancement, vent gas scrubber enhancement, white liquor scrubber system

enhancement, and physical or operational reduction of production capacity, as appropriate. DEP 

would rely on its authority described in Rule 62-4.080, F.A.C., which expressly authorizes DEP 

to require the permittee to conform to new or additional conditions if there is a showing of any 

 16 As noted in EPA’s Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions (April 2014), “[F]or S02, with 

its discernible relationship between emissions and air quality, and significant and immediate air quality 

improvements, we explained in the General Preamble that RFP is best construed as “adherence to an ambitious 

compliance schedule.” See 74 FR 13547, April 16, 1992. This means that the air agency needs to ensure that 

affected sources implement appropriate control measures as expeditiously as practicable in order to ensure 

attainment of the standard by the applicable attainment date.” Section V.E., RFP (p. 40). 17 See 57 FR 13547.
28

change in the environment or surrounding conditions that requires a modification to conform to 

applicable air quality standards. Depending on the present circumstances, DEP would exercise 

this authority to work expeditiously with Rayonier and RockTenn to make necessary permit 

modifications. If a permit modification is deemed necessary, DEP would issue a final permit 

within the statutory timeframes required in Sections 120 and 403, Florida Statues, and any new 

emissions limits required by such a permit would be submitted to EPA as a SIP revision.

Upon notification by DEP that a reference monitor for the area has registered SO2 levels in 

excess of the standard (75 ppb 1-hour daily maximum concentration) for a fourth time during a 

calendar year after the attainment date, or upon notification by DEP that a monitored SO2

violation based on the design value has occurred after the attainment date, Rayonier and 

RockTenn will, without any further action by DEP or the U.S. Environmental Protection 

Agency, immediately undertake a full system audit of all emissions units subject to control under 

this nonattainment area plan. Rayonier and RockTenn will each independently submit to DEP in 

writing, within 10 days of the fourth registered exceedance, a written system audit report 

detailing the operating parameters of all emissions units for four 10-day periods up to and 

including the dates upon which the reference monitor registered each of the four exceedances, 

together with recommended provisional SO2 emission control strategies for each affected unit 

and evidence that these control strategies have been deployed, as appropriate. Upon receipt of 

these written system audit reports, DEP will immediately begin a 30-day evaluation period to 

diagnose the cause of the monitored exceedance. This will be followed by a 30-day consultation 

period with Rayonier and RockTenn to develop and implement operational changes necessary to 

prevent any future monitored violation of the standard. These changes could include, but would 

not be limited to, fuel switching to reduce or eliminate the use of sulfur-containing fuels, 

combustion air system enhancement, vent gas scrubber enhancement, white liquor scrubber 

system enhancement, and physical or operational reduction of production capacity, as 

appropriate. DEP would rely on its authority outlined in Rule 62-4.080, F.A.C., which expressly 

authorizes DEP to require the permittee to conform to new or additional conditions if there is a 

showing of any change in the environment or surrounding conditions that requires a modification 

to conform to applicable air quality standards. If a permit modification is deemed necessary, 

DEP would issue a final permit within the statutory timeframes required in Sections 120 and 403, 

Florida Statues, and any new emissions limits required by such a permit would be submitted to 

EPA as a SIP revision.

8. Future Growth

The Department is unaware of any specific plans for growth in or around the nonattainment area.

Normal minor source growth is anticipated and may occur, however any such growth is not 

expected to result in a significant increase of SO2 emissions in the area. In the event that any new 

or modified major stationary sources of SO2 were proposed for construction, Florida’s 

Nonattainment area New Source Review regulations at Section 62-212.500, F.A.C., would apply 

to the designated nonattainment area for the 2010 SO2 NAAQS. Consistent with Section 62-

212.500, F.A.C., any such new or modified sources would be required to comply with 

nonattainment new source review requirements including lowest achievable emission rates, 

offsets, and public hearing requirements, in accordance with 40 CFR 51.165.
29

9. Conclusion

In satisfaction of CAA requirements, DEP proposes that EPA approve and incorporate into 

Florida’s SIP specified SO2 emission limits from the air construction permits authorizing the SO2

reduction projects at the Rayonier and RockTenn facilities including operating limitations and 

stack height increases, as detailed under the section of this submittal titled “Materials Proposed

to be Incorporated into the SIP.” As demonstrated above, these measures will provide for 

attainment and maintenance of the revised SO2 NAAQS in the Nassau County nonattainment 

area before the attainment date of October 4, 2018. 
30

Response to 40 CFR Part 51, Appendix V, Criteria

Pursuant to 40 CFR Part 51, Appendix V, the following shall be included in SIP submissions for 

review by EPA:

2.1. Administrative Materials

(a) A formal letter of submittal from the Governor or his designee, requesting EPA 

approval of the plan or revision thereof (hereafter “the plan”).

A copy of the “Letter of Submittal,” signed by the Director of the Division of Air Resource 

Management, Florida Department of Environmental Protection, on behalf of the Governor of the 

State of Florida, is located at the front of this document.

(b) Evidence that the State has adopted the plan in the State code or body of regulations; or 

issued the permit, order, consent agreement (hereafter “document”) in final form. That 

evidence shall include the date of adoption or final issuance as well as the effective date of 

the plan, if different from the adoption/issuance date.

This proposed revision to Florida’s SIP consists of specific provisions of two federally 

enforceable air construction permits, Permit No. 0890004-036-AC, issued in final form to 

Rayonier on April 12, 2012, and Permit No. 0890003-046-AC, issued in final form to RockTenn 

on January 9, 2015. A copy of each of these permits may be found in the “Materials Proposed to 

be Incorporated in the SIP” section of this submittal.

(c) Evidence that the State has the necessary legal authority under State law to adopt and 

implement the plan.

DEP has the necessary legal authority to adopt and implement this proposed revision to Florida’s 

SIP. References to the pertinent Florida Statutes and Florida Administrative Code rules may be 

found in the “Legal Authority” section of this submittal.

(d) A copy of the actual regulation, or document submitted for approval and incorporation 

by reference into the plan, including indication of the changes made (such as, 

redline/strikethrough) to the existing approved plan, where applicable. The submittal shall 

be a copy of the official State regulation/document signed, stamped and dated by the 

appropriate State official indicating that it is fully enforceable by the State. The effective 

date of the regulation/document shall, whenever possible, be indicated in the document 

itself. If the State submits an electronic copy, it must be an exact duplicate of the hard copy 

with changes indicated, signed documents need to be in portable document format, rules need 

to be in text format and files need to be submitted in manageable amounts (e.g., a file for each 

section or chapter, depending on size, and separate files for each distinct document) unless 

otherwise agreed to by the State and Regional Office.

This proposed revision to Florida’s SIP consists of specific provisions of two federally 

enforceable air construction permits, Permit No. 0890004-036-AC, issued in final form to 

Rayonier on April 12, 2012, and Permit No. 0890003-046-AC, issued in final form to RockTenn 
31

on January 9, 2015. A copy of each of these permits may be found in the “Materials Proposed to 

be Incorporated in the SIP” section of this submittal. 

(e) Evidence that the State followed all of the procedural requirements of the State's laws 

and constitution in conducting and completing the adoption/issuance of the plan.

State law (Section 120.525, F.S.) requires DEP to give notice of public meetings, hearings, and 

workshops by publication in the Florida Administrative Register (FAR) not less than seven days 

before the event. Through publication in the FAR of the notice of opportunity to participate in a 

public hearing, if requested, at least 30 days before the event, DEP has complied with all state 

procedural requirements relevant to the development of this proposed SIP revision. A copy of the 

notice of proposed SIP revision may be found in the “Public Participation” section of this 

submittal.

(f) Evidence that public notice was given of the proposed change consistent with procedures 

approved by EPA, including the date of publication of such notice.

DEP has complied with all public notice requirements of 40 CFR 51.102. Copies of the relevant 

notices and notifications may be found in the “Public Participation” and “Pre-Hearing Submittal 

to EPA” sections of this submittal.

(g) Certification that public hearing(s) were held in accordance with the information 

provided in the public notice and the State's laws and constitution, if applicable and 

consistent with the public hearing requirements in 40 CFR 51.102.

Certification of compliance with all state and federal public notice and hearing requirements is 

provided in the “Letter of Submittal.”

(h) Compilation of public comments and the State's response thereto.

Written comments received during the public notice period on this proposed SIP revision, and 

DEP’s response thereto, may be found in the “Public Participation” and “Pre-Hearing Submittal 

to EPA” sections of this submittal.

2.2. Technical Support

(a) Identification of all regulated pollutants affected by the plan.

This SIP revision addresses only the air pollutant sulfur dioxide (SO2).

(b) Identification of the locations of affected sources including the EPA 

attainment/nonattainment designation of the locations and the status of the attainment plan 

for the affected areas(s).

This SIP revision applies to the SO2 nonattainment area located in Nassau County, Florida. The 

designated nonattainment area is described as follows:

That portion of Nassau County encompassing the circular boundary with the 

center being UTMEasting 455530 meters, UTM Northing 3391737 meters, UTM 
32

zone 17, using the NAD83 datum (the location of the violating ambient monitor) 

and the radius being 2.4 kilometers.

The nonattainment area contains within its boundaries one major point source for SO2 emissions 

– Rayonier’s Fernandina Beach Sulfite Pulp Mill. DEP determined that a second major point 

source of SO2 emissions in the immediate vicinity of the nonattainment area is a significant 

contributor to elevated concentrations within the defined nonattainment area – RockTenn’s 

Fernandina Beach Mill. 

Through this SIP revision, DEP seeks EPA’s approval of Florida’s SO2 nonattainment plan for 

the affected area.

(c) Quantification of the changes in plan allowable emissions from the affected sources; 

estimates of changes in current actual emissions from affected sources or, where 

appropriate, quantification of changes in actual emissions from affected sources through 

calculations of the differences between certain baseline levels and allowable emissions 

anticipated as a result of the revision.

See the “Sulfur Dioxide (SO2) Attainment Demonstration – Technical Document” section of this 

submittal.

(d) The State's demonstration that the national ambient air quality standards, prevention 

of significant deterioration increments, reasonable further progress demonstration, and 

visibility, as applicable, are protected if the plan is approved and implemented. For all 

requests to redesignate an area to attainment for a national primary ambient air quality 

standard, under section 107 of the Act, a revision must be submitted to provide for the 

maintenance of the national primary ambient air quality standards for at least 10 years as 

required by section 175A of the Act.

See “Sulfur Dioxide (SO2) Attainment Demonstration – Technical Document” section of this 

submittal.

(e) Modeling information required to support the proposed revision, including input data, 

output data, models used, justification of model selections, ambient monitoring data used, 

meteorological data used, justification for use of offsite data (where used), modes of models 

used, assumptions, and other information relevant to the determination of adequacy of the 

modeling analysis.

See “Sulfur Dioxide (SO2) Attainment Demonstration – Technical Document” section of this 

submittal. See also CD containing an electronic copy of this document together with all SO2 air 

quality modeling files.

(f) Evidence, where necessary, that emission limitations are based on continuous emission 

reduction technology.

See Rayonier and RockTenn Air Construction Permits (0890004-036-AC and 0890003-046-AC, 

respectively) in the “Materials Proposed to be Incorporated into the SIP” section of this 

submittal.
33

(g) Evidence that the plan contains emission limitations, work practice standards and 

recordkeeping/reporting requirements, where necessary, to ensure emission levels.

See SO2 emissions limits for each affected unit, specified operating parameters, and specified

compliance measures from the Rayonier and RockTenn Air Construction Permits (0890004-036-

AC and 0890003-046-AC, respectively) detailed under the “Materials Proposed to be 

Incorporated into the SIP” section of this submittal.

(h) Compliance/enforcement strategies, including how compliance will be determined in 

practice.

See specified operating parameters and compliance measures from the Rayonier and RockTenn 

Air Construction Permits (0890004-036-AC and 0890003-046-AC, respectively) detailed under 

the “Materials Proposed to be Incorporated into the SIP” section of this submittal.

(i) Special economic and technological justifications required by any applicable EPA 

policies, or an explanation of why such justifications are not necessary.

Not applicable.

2.3. Exceptions

Not applicable.
34

Legal Authority

Chapter 403 of the Florida Statutes (F.S.), entitled “Environmental Control,” provides the legal 

framework for most of the activities of the air resource management program within DEP.

Except as provided at sections 403.8055 and 403.201, F.S., for fast-track rulemaking and the 

granting of variances under Chapter 403, F.S., respectively, Chapter 120, F.S., Florida’s 

“Administrative Procedure Act,” sets forth the procedures DEP must follow for rulemaking, 

variances, and public meetings. The most recent version of the Florida Statutes can be found 

online at http://www.leg.state.fl.us/Statutes. 

The principal sections of Chapter 403, F.S., that grant DEP authority to operate its air program 

are listed below. Authority to develop and update Florida’s SIP and 111(d) Designated Facilities 

Plan is expressly provided by subsection 403.061(35), F.S., which provides that “the department 

shall have the power and the duty to control and prohibit pollution of air and water in accordance 

with the law and rules adopted and promulgated by it and, for this purpose, to ... exercise the 

duties, powers, and responsibilities required of the state under the federal Clean Air Act, 42 

U.S.C. ss. 7401 et seq.”

403.031 Definitions, including the definition of “regulated air pollutant” (403.031(19)).

403.061 Authority to promulgate plans to provide for air quality control and pollution 

abatement (403.061(1)); adopt rules for the control of air pollution in the state

(403.061(7)); take enforcement action against violators of air pollution laws, rules 

and permits (403.061(8)); establish and administer an air pollution control program

(403.061(9)); set ambient air quality standards (403.061(11)); monitor air quality

(403.061(12)); require reports from air pollutant emission sources (403.061(13));

require permits for construction, operation, and modification of air pollutant 

emission sources (403.061(14)); and exercise the duties, powers, and responsibilities 

required of the state under the federal Clean Air Act (403.061(35)).

403.087 Authority to issue, deny, modify and revoke permits.

403.0872 Authority to establish an air operating permit program as required by Title V of the 

Clean Air Amendments of 1990.

403.0877 Authority to require engineering certification of permit applications.

403.121 Authority to seek judicial and administrative remedies for violations.

403.131 Authority to seek injunctive relief for violations.

403.141 Authority to find civil liability for violations.

403.161 Authority to assess civil and criminal penalties for violations.

403.182 Authority for local pollution control programs.

403.201 Authority to grant variances.

403.716 Authority to require training of medical waste incinerator operators.

403.8052 Authority to establish a Small Business Assistance Program for small-business 

sources of air pollutant emissions.
35

403.8055 Authority to adopt U.S. Environmental Protection Agency (EPA) standards by 

reference through a fast-track process.

403.814 Authority to allow use of general permits (permits-by-rule) for minor sources.

Other statutory authorities (outside of Chapter 403, F.S.) for Florida’s air resource management 

program are as follows:

120.569 Authority of agency head to issue an emergency order in response to an immediate 

threat to public health, safety, or welfare.

316.2935 Authority to prohibit the sale and operation of motor vehicles whose emission 

control systems have been tampered with and to prohibit the operation of motor 

vehicles that emit excessive smoke.

320.03 Authority to establish an Air Pollution Control Trust Fund and use $1 fee on every 

motor vehicle license registration sold in the state for air pollution control purposes, 

including support of approved local air pollution control programs.

376.60 Authority to establish a fee for asbestos removal projects.

Rules adopted by DEP under its statutory authority are codified in the Florida Administrative 

Code (F.A.C.). The most recent versions of the F.A.C. rules can be found online at 

https://www.flrules.org. Rule chapters containing SIP or 111(d) State Plan provisions are as 

follows:

62-204 Air Pollution Control – General Provisions

62-210 Stationary Sources – General Requirements

62-212 Stationary Sources – Preconstruction Review

62-243 Tampering with Motor Vehicle Air Pollution Control Equipment

62-252 Gasoline Vapor Control

62-256 Open Burning

62-296 Stationary Sources – Emission Standards

62-297 Stationary Sources – Emissions Monitoring

Other air-related DEP rule chapters—not part of the SIP or 111(d) State Plan—include:

62-213 Operation Permits for Major Sources of Air Pollution (Title V)

62-214 Requirements for Sources Subject to the Federal Acid Rain Program

62-257 Asbestos Program
36

Materials Proposed to be Incorporated into the SIP

DEP is proposing that the following SO2 emission limits and operating and compliance 

parameters be incorporated into Florida’s SIP in satisfaction of the Clean Air Act requirements 

for attainment and maintenance of the revised SO2 NAAQS in the nonattainment area located in 

Nassau County.

Specified Limits and Conditions from Rayonier Permit (Permit No. 0890004-036-AC)

DEP is proposing that the following emission limits and operating parameters from the Rayonier 

Permit be incorporated into Florida’s SIP in satisfaction of the Clean Air Act requirements for 

attainment and maintenance of the revised SO2 National Ambient Air Quality Standard 

(NAAQS) in the nonattainment area located in Nassau County.

EU 005 – Vent Gas Scrubber and Direct Contact Condenser

SO2 Emission Limits: 100 ppm (3-hour average) SO2 limit. 

Compliance Monitoring: SO2 concentrations in the stack is measured 

continuously using a CEMS.

Emission Reporting: Reporting Requirements A.5. (Page 8 of 12). (NOTE: asbuilt stack parameter of 180 feet recorded in Rayonier’s Title V Permit [Permit 

No. 0890004-042-AV].)

EU 006 – Recovery Boiler

SO2 Emission Limits: 250 ppmvd (3-hour average) SO2 limit. 

Compliance Monitoring: SO2 concentrations in the stack is measured 

continuously using a CEMS.

EU 022 – No. 6 Power Boiler

SO2 Emission Limits: 180 lbs/hour (3-hour average) SO2 limit at the stack height 

of 190 feet. 

Compliance Monitoring: SO2 emissions are monitored by a CEMS.

These proposed specific operating conditions and emissions limits for the Rayonier facility, 

which Florida is requesting that EPA approve for incorporation into Florida’s SIP, are new 

conditions and limits. There were no pre-existing SIP conditions or limits specific to the 

Rayonier facility.

For ease of reference, DEP provides on the following pages a facsimile of the Rayonier Permit

(Permit No. 0890004-036-AC) in its entirety.
37
38
39
40
41
42
43
44
45
46
47
48
49

Specified Limits and Conditions from RockTenn Permit (Permit No. 0890003-046-AC)

DEP is proposing that the following emission limits and operating parameters from the 

RockTenn Permit be incorporated into Florida’s SIP in satisfaction of the Clean Air Act 

requirements for attainment and maintenance of the revised SO2 National Ambient Air Quality 

Standard (NAAQS) in the nonattainment area located in Nassau County.

EU 006 – No. 5 Power Boiler

SO2 Emission Limits: Effective January 31, 2016 through November 30, 2017, SO2

emissions from the No. 5 Power Boiler shall not exceed 15.0 lb/hour based on a 3-hour 

block average as determined by data collected from a continuous emissions monitoring 

system (CEMS), during all periods of operation except when operating as a backup 

control device firing NCGs. Effective December 1, 2017, SO2 emissions from the No. 5 

Power Boiler shall not exceed 15.0 lb/hour based on a 3-hour block average as 

determined by data collected from a CEMS during all periods of operation. 

Compliance Monitoring: The CEMS shall be measuring and recording in units of the 

SO2 emissions standard by the first effective date for this new emission standard. 

EU 015 – No. 7 Power Boiler

SO2 Emission Limits: Effective January 31, 2016, SO2 emissions from the No. 7 Power 

Boiler shall not exceed 1225.20 lb SO2/hour based on a 3-hour block average as 

determined by the current compliance demonstration methods in the Title V air operation 

permit (e.g., stack testing, fuel sulfur monitoring and fuel consumption monitoring). The 

new emissions standard applies at all times including periods of startup and shutdown. 

Effective December 1, 2017, SO2 emissions from the No. 7 Power Boiler shall not exceed 

1225.20 lb SO2/hour based on a 3-hour block average as determined by data collected 

from a certified CEMS. The new emissions standard applies at all times including periods 

of startup, shutdown, and the firing of NCGs. 

Compliance Monitoring: The permittee shall install, calibrate, maintain and operate a 

CEMS to measure and record SO2 emissions and exhaust flow for reporting in units of 

the applicable standard. Emissions shall be monitored and recorded during all periods of 

boiler operation including startup, shutdown and malfunction. The permittee shall install 

and operate the CEMS in accordance with the applicable performance specifications, 

quality assurance procedures, and quality control requirements summarized in Appendix 

D (Standard CEMS Requirements) of the permit. The CEMS shall be installed, certified 

and recording valid data in units of the SO2 emissions standard prior to the No. 7 Power 

Boiler being connected to the NCG piping for use as a backup control device, but no later 

than December 1, 2017.
50

EU 007 – No. 4 Recovery Boiler

EU 011 – No. 5 Recovery Boiler

SO2 Emission Limits: Effective January 1, 2018, SO2 emissions from each recovery 

boiler shall not exceed 150.0 lb/hour based on a 3-hour block average as determined by 

data collected from a certified CEMS or other methods approved by the Division of Air 

Resource Management. Alternatively, the permittee may elect to comply with the 

following combined SO2 emissions cap: Effective January 1, 2018, combined SO2

emissions from the Nos. 4 and 5 recovery boilers shall not exceed 300.0 lb/hour based on 

a 3-hour block average as determined by data collected from a certified CEMS. 

Compliance Monitoring: Unless otherwise approved by the Division of Air Resource 

Management, compliance with the SO2 emissions standard shall be demonstrated by data 

collected from a certified CEMS. The permittee shall install, calibrate, maintain and 

operate a CEMS on each recovery boiler to measure and record SO2 emissions and 

exhaust flow for reporting in units of the applicable standard. Emissions shall be 

monitored and recorded during all periods of recovery boiler operation including startup, 

shutdown and malfunction. The permittee shall install and operate the CEMS in 

accordance with the applicable performance specifications, quality assurance procedures, 

and quality control requirements summarized in Appendix D (Standard CEMS 

Requirements) of the permit. If the permittee elects the combined SO2 emissions cap, 

compliance must be demonstrated with CEMS data. The CEMS shall be measuring and 

recording valid data in units of the SO2 emissions standard by January 1, 2018.

In addition to the conditions from the RockTenn permit detailed above, DEP also 

proposes to incorporate the following condition into Florida’s SIP:

Fuel Limitation: Effective January 1, 2018, fuel oil usage at Recovery Boilers No. 4 and 

No. 5 shall be limited to ultra low sulfur diesel (ULSD) with a maximum sulfur content 

of 15 parts per million (0.0015 percent).

These proposed specific operating conditions and emissions limits for the RockTenn facility, 

which Florida is requesting that EPA approve for incorporation into Florida’s SIP, are new 

conditions and limits. In Florida’s existing SIP, Power Boiler 5 has an SO2 emissions limit of 

550 lb/hr, 24-hour average. For Power Boiler 7, DEP is required to review the status of the 

unit’s compliance with the Boiler MACT rule as part of Florida’s continuing periodic review of 

the state’s compliance with regional haze requirements. 

For ease of reference, DEP provides on the following pages a facsimile of the RockTenn Permit 

(Permit No. 0890003-046-AC) in its entirety.
51
52
53
54
55
56
57
58
59
60
61

Public Participation

Response to 40 CFR 51.102 Requirements

(a) Except as otherwise provided in paragraph (c) of this section and within the 30 day 

notification period as required by paragraph (d) of this section, States must provide notice, 

provide the opportunity to submit written comments and allow the public the opportunity 

to request a public hearing. The State must hold a public hearing or provide the public the 

opportunity to request a public hearing. The notice announcing the 30 day notification 

period must include the date, place and time of the public hearing. If the State provides the 

public the opportunity to request a public hearing and a request is received the State must 

hold the scheduled hearing or schedule a public hearing (as required by paragraph (d) of 

this section). The State may cancel the public hearing through a method it identifies if no 

request for a public hearing is received during the 30 day notification period and the 

original notice announcing the 30 day notification period clearly states: If no request for a 

public hearing is received the hearing will be cancelled; identifies the method and time for 

announcing that the hearing has been cancelled; and provides a contact phone number for 

the public to call to find out if the hearing has been cancelled.

The opportunity to submit written comments, request a public hearing, and participate in a public 

hearing, if requested, on the proposed SIP revision was advertised in the Florida Administrative 

Register (FAR) at least 30 days prior to the scheduled date of the hearing. Information regarding

the date, place, and time of the public hearing was included in the notice along with information 

on how to request the hearing or ascertain whether the hearing would be cancelled. A copy of the 

notice is included in this section. No hearing was requested, therefor no hearing was held.

(b) Separate hearings may be held for plans to implement primary and secondary 

standards.

Not applicable.

(c) No hearing will be required for any change to an increment of progress in an approved 

individual compliance schedule unless such change is likely to cause the source to be unable 

to comply with the final compliance date in the schedule. The requirements of §§51.104 and 

51.105 will be applicable to such schedules, however.

Not applicable.

(d) Any hearing required by paragraph (a) of this section will be held only after reasonable 

notice, which will be considered to include, at least 30 days prior to the date of such 

hearing(s):

(1) Notice given to the public by prominent advertisement in the area affected 

announcing the date(s), time(s), and place(s) of such hearing(s);

The opportunity to submit comments, request a public hearing, and participate in a public 

hearing, if requested, on the proposed SIP revision was advertised in the FAR at least 30 days 

prior to the scheduled date of the hearing (see response (a)).
62

(2) Availability of each proposed plan or revision for public inspection in at least one 

location in each region to which it will apply, and the availability of each compliance

schedule for public inspection in at least one location in the region in which the affected 

source is located;

The materials proposed to be incorporated into the SIP were made available for public 

inspection in the offices of DEP’s Division of Air Resource Management (DARM) and on 

the DARM website. The materials were also made accessible to the public through each of 

the DEP’s district offices and in the offices of each DEP-approved local air pollution control 

program. The notifications that such information be made available by the district and local 

offices are included in this section.

(3) Notification to the Administrator (through the appropriate Regional Office);

The Region 4 office of the EPA was notified at least 30 days in advance of the scheduled 

hearing date and provided with copies of the materials proposed to be incorporated into the 

SIP. The pre-hearing submittal letter is included in the “Pre-Hearing Submittal to EPA” 

section of this submittal.

(4) Notification to each local air pollution control agency which will be significantly 

impacted by such plan, schedule or revision;

Notification to affected local programs occurred with the transmittal of e-mails requesting 

that the material proposed to be incorporated into the SIP be made available for public 

inspection (see response (d)(2)).

(5) In the case of an interstate region, notification to any other States included, in whole 

or in part, in the regions which are significantly impacted by such plan or schedule or 

revision.

Not applicable.

(e) The State must prepare and retain, for inspection by the Administrator upon request, a 

record of each hearing. The record must contain, as a minimum, a list of witnesses together 

with the text of each presentation.

No hearing was requested, therefore no hearing was held.

(f) The State must submit with the plan, revision, or schedule, a certification that the 

requirements in paragraph (a) and (d) of this section were met. Such certification will 

include the date and place of any public hearing(s) held or that no public hearing was 

requested during the 30 day notification period.

Certification is provided in the letter of submittal that the opportunity to submit comments, 

request a public hearing, and participate in a public hearing on the proposed SIP revision was 

noticed in accordance with the requirements of 40 CFR 51.102. No hearing was requested, 

therefore no hearing was held.

(g) Upon written application by a State agency (through the appropriate Regional Office), 

the Administrator may approve State procedures for public hearings. [...]

Not applicable.
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Notice of Opportunity to Submit Comments and Participate in Public Hearing
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Requests for Districts/Locals to Provide Assistance to Public
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Public Comments on SIP Notice

During the public comment period, RockTenn CP, LLC (RockTenn) contacted DEP and noted 

that the pre-hearing draft “Appendix A” (Averaging Times for Emission Rate Adjustment) 

should be revised to include an updated data set regarding fuel oil emissions calculations for 

Recovery Boilers No. 4 and No. 5. RockTenn further indicated that in order to meet the new 

enforceable SO2 emission limit at these units, the units would combust ultra low sulfur diesel 

(ULSD), a fuel allowed under the facility’s existing Title V permit (Permit No. 0890003-044-

AV). RockTenn suggested that ULSD would be the most appropriate fuel for DEP to use in 

determining compliance averaging time adjustment factors for Recovery Boilers No. 4 and No. 

5. DEP subsequently received an updated data set from RockTenn. 
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DEP Response to Public Comments

Response to RockTenn comments by way of communication between Mr. Preston McLane,

Division of Air Resource Management, and Ms. Nina Butler and Ms. Corey Brandt, 

RockTenn CP, LLC.

Based on the revised data provided by RockTenn, DEP has corrected the hourly SO2 emissions 

data included in Appendix A of the pre-hearing draft. (Note: In the final version of the SIP this 

appendix has been re-named as Appendix B to accommodate the addition of a new appendix 

created in response to an EPA comment.) The revised data corrected for an incorrect emission 

factor used by RockTenn for determining SO2 emissions from fuel oil use in Recovery Boilers 

No. 4 and No. 5. 

RockTenn also communicated that the development of the compliance period averaging time 

adjustment factor based on these data should be based on the use of ultra low sulfur diesel 

(ULSD) fuel oil since the use of this fuel will be necessary to meet the new emissions limits 

imposed on Recovery Boilers No. 4 and No. 5. DEP agrees with RockTenn that the use of ULSD 

is necessary and appropriate to determine the future variability of hourly emissions. Consistent 

with this fact, DEP has included a provision in this SIP providing that effective January 1, 2018, 

fuel oil usage at Recovery Boilers No. 4 and No. 5 shall be limited to ultra low sulfur diesel 

(ULSD) with a maximum sulfur content of 15 parts per million (0.0015 percent). See “Materials 

to be Incorporated into the SIP” section of this SIP submittal. 

DEP notes that EPA’s “Guidance for 1-Hour SO2 Nonattainment Area SIP Submissions” states

as follows: “. . . if the new emission limit requires more stringent emission control than is 

currently in place at a source, the analyses should be designed, to the extent practicable, to reflect 

the hourly emissions variability that can be expected once the emission limit is in place.” DEP 

has recalculated the adjustment factors for both recovery boilers using both the corrected data 

and the use of ULSD fuel oil. DEP substituted ULSD when fuel oil was used in the historical 

data to reflect the appropriate quantity and frequency of oil usage. For Recovery Boiler No. 4, 

the 1-hour to 3-hour adjustment changed (from the pre-hearing draft) from 0.996 to 0.999. No 

change in the SIP emission limit for Recovery Boiler No. 4 is necessary due to this exceedingly 

small change in the adjustment factor. For Recovery Boiler No. 5, there was no change in the 

adjustment factor. 
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Pre-Hearing Submittal to EPA

Pre-Hearing Submittal Letter
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70

Materials Enclosed with Pre-Hearing Submittal

• Notice of Proposed SIP Revision. See “Notice of Opportunity to Submit Comments and

Participate in Public Hearing” section of this submittal.

• Rayonier Air Construction Permit (Permit No. 0890004-036-AC). See “Materials 

Proposed to be Incorporated into the SIP” section of this submittal.

• RockTenn Air Construction Permit (Permit No 0890003-046-AC). See “Materials 

Proposed to be Incorporated into the SIP” section of this submittal.

• Air Quality Modeling Files. These files are included on the CD containing the electronic 

copy of this proposed SIP submittal.

The materials listed as enclosures in the Pre-Hearing Submittal letter are the same materials that 

were made available for public inspection on the website for DEP’s Division of Air Resource 

Management. The materials being proposed for incorporation into the SIP are unchanged from 

the materials made available for public inspection.
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EPA Comments on Pre-Hearing Submittal
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DEP Response to EPA Comments

Response to EPA Comments: March 19, 2015, letter to Mr. Preston McLane, Division of

Air Resource Management, from Mr. R. Scott Davis, Chief, Air Planning Branch, U. S. 

Environmental Protection Agency, Region 4.

I. Key Comments

i. Emissions Inventory: DEP has recalculated its mobile source emissions using 

MOVES2014. The program was run for Nassau County using the characterization 

data derived from both Nassau County and the adjacent Duval County for both the 

base year 2011 and the projection year of 2018. Both counties are within the same 

Core Business Statistical Area. Because the nonattainment area is a subset of the 

county, emissions for this area were apportioned in accordance with the fraction of 

population in the area. Tables 3a. and 3b. have been updated with the revised values. 

DEP has also added a new Appendix A to this SIP submittal documenting the 

emissions inventory procedures and calculations. The use of MOVES2014 and revision 

of the emission inventory values did not result in any substantive change to the 

technical analyses or attainment demonstration.

ii. Materials Proposed to be Incorporated into the SIP: DEP has added clarifying 

language under the section of this submittal entitled “Materials Proposed to be 

Incorporated into the SIP.” Florida is expressly requesting that EPA consider for 

incorporation and approval into the SIP new SO2 emissions limits for each affected unit, 

specified operating parameters, and the compliance measures detailed under the 

“Materials Proposed to be Incorporated into the SIP” section of this submittal.

II. General Comments 

i.a. DEP directly determined the large point source emissions based upon annual reporting 

requirements. Onroad mobile emissions were determined using MOVES2014. DEP 

utilized the NEI only to account for the very small additional SO2 emissions within the 

nonattainment area. Given the small nonattainment area addressed in this SIP, DEP 

believes that NEI data for the area source category and nonroad mobile source categories 

are sufficient. The inventory is comprehensive – the NEI accounts for all source 

categories; accurate – the point source emissions account for over 99 percent of the 

emissions and are judged accurate, the additional emissions from other sources would not 

significantly alter this accuracy, and current – the 2011 inventory represents the most 

recent pre-SIP-revision inventory. 

i.b. DEP did not include a miscellaneous category in Tables 3a and 3b in the pre-hearing

draft because the value was so small. This category derives from the NEI. After 

reevaluating the emissions categories used in the NEI, DEP has remapped the tables to 

conform to the approach used in previous SIP emission inventories: point, area, onroad 

mobile, and nonroad mobile categories. Point sources were directly accounted for using 

emissions data reported to the DEP for year 2011. Onroad mobile sources were estimated 

using the MOVES2014 emissions processor. Area and nonroad mobile data were derived 
74

from the NEI, and include the miscellaneous category. 

i.c. In the pre-hearing draft, DEP assumed no growth in emissions from the area, onroad 

mobile, and nonroad mobile sources to the year 2018. In the final SIP submittal, DEP has 

used the MOVES2014 emissions processor to estimate 2018 onroad mobile emissions, 

and imposed a growth factor to the area and nonroad mobile emissions based on projected 

population increases to estimate emissions in 2018. The use of MOVES2014 and 

revision of the estimated onroad mobile emission values did not result in any substantive 

change to the technical analyses or attainment demonstration.

ii. DEP has added a table to the SIP submittal summarizing how final emission limits were 

calculated to account for the adjusted compliance averaging time and incorporated related 

discussion into the text of the attainment demonstration.