## STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

PROPOSED REVISION TO STATE IMPLEMENTATION PLAN

SUBMITTAL NUMBER 20 1 5

- 03

SO 2 

## N ONATTAINMENT AREA PLAN

NASSAU COUNTY, FLORIDA

April 3

, 201 5- Page left intentionally blank.

-i STATE OF FLORIDA

DEPARTMENT OF ENVIRONMENTAL PROTECTION

PROPOSED REVISION TO STATE IMPLEMENTATION PLAN

SUBMITTAL NUMBER 20 1 5

- 03

SO 2 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 SO 2 Standard

................................ ................................ ...................... 5

SO 2 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 Pr oposed 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

................................ ................................ ................................ .................... 61ii Response to 40 CFR 5 1.102 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

................................ ................................ ............................. 73iii - Page left intentionally blank.

-1 Letter of Submittal23 

### Proposed Revision to State Implementation Plan

S ubmittal Number 20 1 5

- 03

SO 2 

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

Sulfur Dioxide ( SO 2 ) National Ambient Air Quality Standard (NAAQS) in Florida’s SO 2 nonattainment area located in Nassau County. Florida ’s nonattainment area plan consists of specific conditions from two federally enforceable air construction permit s for two pulp and paper mill facilities in Ferna ndina Beach , Florida

– Rayonier Performance Fibers, LLC ( Rayonier ) and RockTenn CP, LLC (RockTen n)

– as they pertain to emissions of SO 2

.

Background

On June 22 , 20 10 (effective August 23, 2010) , the U.S. Environmental Protection Agency (EPA) promulgated a revised National Ambient Air Quality Standard (NAAQS) for SO 2

. The level of

the revised standard is 75 parts per billion (ppb)

, three

- year average of the annual 99 th percentile

of one

- hour daily maximum concentrations. The revised SO 2 standard is the first one

- hour primary standard promulgated by EPA for this air pol lutant

.

On August 5, 2013 (effective October 4 , 201 3 ), EPA designated a small area ( 2.4 km radius circle) in Nassau County , Florida nonattainment for SO 2 based on air quality monitoring data showing violation of the revised standard over the three

- year period of 200 9 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 1 7, 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 m ajor point source for

SO 2 emissions

– Rayonier’s Fernandina Beach Sulf ite Pulp Mill. DEP determined that a second major point source of SO 2 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 Mi ll. This proposed revision to Florida’s SIP addresses SO 2 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 M ill 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. 08900 0 4

- 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 SO 2 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 t hese changes significantly lower s the modeled SO 2 impact from the Rayonier facility on the amb ient air of Nassau County , including at the location of the monitor, which currently shows compliance with the standard

.

On May 30, 2 01 4, DEP issued a revised Title V air operation permit (0890004

- 042

- AV) to incorporate the Rayonier Permit , and authoriz ed Rayonier to operate the facility in accordance with the terms and conditions of the revised Title V permit. 1

RockTenn Permit

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

32034. The RockTe nn Mill pro duces a range of containerboard products.

On January 9 , 2015 , DEP issued a federally enforceable air construction permit to Rock Tenn (Permit No. 0890003

- 046

- AC ) (“ Rock Tenn Permit”)

, which allows the facility to undertake

construction and implement a variety of controls associated with its SO 2 emissions. The

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

SO 2 emitting units at the RockTenn facilit y

. Included among these are improvements to ea ch of the facility’s two recovery boiler s to achieve a more stable and consistent combustion and

chemical r ecovery process, and the install ation and operation of a piping system to transport non

condensable gases ( NCGs ) for combustion in the No. 7 Power Boiler. All construction and operational changes sh all be complete d no later than December 1, 2017. The construction projec ts 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 lower s the modeled SO 2 impact from the RockTenn facility on the ambient air of Nassau County.

All control strategies, physical changes, and emissions limits included in the R ockTenn 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 und er 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 proced ures 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 , 201 5 , if requested, regarding the prop osed 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 wa s 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 request ed, was transmitted to Florida’s local air pollution control programs.

Attainment of the SO 2 Standard

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

Permit. Although construction at the Rock Tenn facility is perm itted through December 31

, 2017

, for reasons detailed below, DEP is confident that attainment of the S O 2 standard will be met well before the required attainment date of October 4 , 201 8

. 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 SO 2 standard. With specific regard to Rock Tenn, the facility is implementing a phased program of construction to address SO 2 emissions from multiple emissions units. T he facility is implementing a range of SO 2 em issions controls under the Rock Tenn Permit in order to
demonstrate attainment w ith the 2010 SO 2 NAAQS within the nonattainment a rea at allowable

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

enti re nonattainment area is already attain ing the 2010 SO 2 NAA QS. Thus, the terms of the

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

201 7

— technically indicating full compliance with the control strategy for modeled attainment at permitted allowable emissions rate s

— does not delay expeditious attainm ent of the NAAQS. The

N AAQS is currently being met , and DEP fully expects for t he area to remain in attainment

dur ing the period under which Rock Tenn is implementing its control strategy. In addition, all of

the SO 2 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 C AA , Florida is required to submit to EPA a proposed revision t o its SIP that provides

for attainment and maintenance of the revised SO 2 NAAQS as expeditiously as possible

, but no later than five years after designation of the nonattainment area. The proposed SIP revision is

due 18 month s after designation of the are a . DEP has determined that improvements at the6 Rayonier and RockTenn facilities , as authorized by the ir respective air construction permit s , will provide for expeditious attainment and maintenance of the revised SO 2 NAAQS in the Nassau County nonattainment area. DEP is proposing , therefore, that specif i c conditions of the se air construction permit s pertain ing to emission of SO 2 , including new SO 2 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

C AA requirements.7 

### SO 2 

### Attainment Demonstration

– Technical Document

1. Emissions Inventory

Section 172(c)(3) of the C lean Air Act (CAA) requires that nonattainment plan provisions include a comprehensive, accurate base

- year inventory of actual emissions from all sources of

SO 2 in the nonattainment area. Rayonier Performance Fibers (Rayonier) is the only point source

of SO 2 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 SO 2 source in the

area. B oth Rayonier and RockTenn are includ ed in this emissions inventory.

Designation of the area as nonattainment was based o n 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 SO 2 NAAQS. As such, SO 2 emissions data for the purposes of the nonattainment area emissions inventory were taken from both facilities’ Annual Operating Reports (AOR) for 2011

, which contain SO 2 e missions from Rayonier’s and RockTenn’s stacks. According to these reports, 561.97 tons of SO 2 were emitted from the Rayonier stacks and 3,716.67 tons of SO 2 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 SO 2 EMISSIONS (tons)

EU005 Vent Gas Scrubber 10.42

EU006 Recovery Boiler 521.85

EU022 No. 6 Power Boiler 29.7 0

Total 2011 Rayonier SO 2 Stack Emissions 561.97

Table 2

Summary of RockTenn’s 2011 AOR

Emission Unit Number Unit Description SO 2 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 1.5 0

EU015 No. 7 Power Boiler 3,160.74

EU021 No. 4 Lime Kiln 97.76

Total 2011 RockTenn SO 2 Stack Emissions 3,716.67

In addition to stack (point source) emissions listed in T ables 1 and 2 , a small amount of SO 2 emitted by onroad mobile, area/nonpoint, and nonroad mobile sources in the nonattainment area8 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 rep resentative 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 emiss ions ( 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 non attainment area ( 13.75

km 2 /1673.5 km 2 or 0.82%). Th ese other sources amounted to an additional 0.56 tons of SO 2 emitted in the nonattainment area in 2011. Given the rura l nat ure of Fernandina Beach and the small size of the nonattainment area, this is co nsidered to be a conservative estimation. Table 3 a presents a complete 2011 base year SO 2 emissions inventory for the SO 2 nonattainment area in Nassau County. A detailed description of the source categories and methods can be found in Appendix A

.

Table 3 a

2011 Base Year SO 2 Nonattainment Area Emissions Inventory * (tons)

Point Sources Onroad Mobile Sources Nonroad Sources Area/Nonpoint Sources Total 2011 SO 2 Emissions

4,27 8.64 0.08 0.09 0.39 4,2 79. 20

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

The hourly SO 2 emissions after the SO 2 reduction projects at Rayonier and RockTenn

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

. Rayonier’s allowable SO 2 emissions (total from all three modified units) will be reduce d from

836.5 lb/hr to 502. 3 lb/hr

– a 40% decrease. Rock Tenn’s allowable SO 2 emissions from the power boiler No. 5 will be reduce d from 550 lb/hr to 15 lb/hr

– a 97% decrease. In addition, the recovery boilers will also have SO 2 emissions decreases due to the combustion modificat ions,

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

calculated

. The SO 2 reduction project at Rayonier has been completed, and this project has resulted in significant early reductions in ambient SO 2 in the nonat tainment area. The SO 2 reduction project at RockTenn will be completed no later than December 31, 2017, more than nine months before the CAA complia nce deadline of October 4, 2018

. Data from the reference monitor for the nonattainment area already show th at the area is in compliance with the revised

SO 2 standard. As described below, the air quality analysis demonstrates that the nonattainment

area will continue to comply with the revised SO 2 NAAQS as the result of significant real

reductions of SO 2 emissio ns 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/ttnchie 1/net/2011inventory.html9 calcul ated 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 A ll 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 3 b

2018 Future Year SO 2 Nonattainment Area Emissions Inventory * (tons)

Point Sources Onroad Mobile Sources Nonroad Sources Area/Nonpoint Sources Total 2018 SO 2 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 Permit s

DEP has issued f inal construction permits to both Rayonier ( 0890004

- 036

- AC ) and RockTenn ( 08900 03

- 046

- AC ) authorizing the facilities to perform SO 2 reduction projects in order to lower

the ambient SO 2 concentrations in the nonattainment area and bring the area into compl iance

with the revised SO 2 1

- hr NAAQS.

Rayonier Permit

Rayonier received a construction permit on April 12, 2012 from DEP to lower SO 2 maximum

allowable emission rates on all three of its SO 2 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 SO 2 units have in

- stack continuous emission monitoring systems (CEMS) for SO 2 to ensure comp liance with their SO 2 emission limits in accordance with Section 113(a)(1) of the CAA.

Table 4

Rayonier Facility SO 2 Reduction Project Source Changes

Source SO 2 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 SO 2 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.pdf10 RockTenn Permit

The construction permit for RockTenn’s SO 2 reduction project was issued on January 9, 2015

. The project will involve physical and operational changes to the four largest SO 2 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 wi thin the unit. .

• Phase II will be completed no later than Decemb er 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 sy stem, and construction of a non

- condensabl e 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 collect ed 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. U pstream of the introduction of NCGs to the N o. 7 Power Boiler, a packed column scrubber system will be installed to remove total reduced sulfur (TRS)

from the NC G stream before combustion.

This schedule of construction projects at the RockTenn facility is considered to be as expeditiously as practi cable and will allow for attainment of the SO 2 1

- hr NAAQS prior to the attainment date of October 4, 2018. As previously noted, d ata from the reference monitor for the nonattainment area already show that that area is in compliance with the revised SO 2 standard.

For compliance purposes, a mixture of CEMS and stack testing will be required. An SO 2 CEMS is already operation al on the No. 5 Power Boiler. RockTenn is required to install and operate an

SO 2 CEMS on the No. 7 Power Boiler no later than Decemb er 31, 2017. The recovery boilers will demonstrate compliance with SO 2 CEMS data after the air system upgrades. Rock Tenn may elect to establish a relationship between SO 2 emissions and key operating parameters, and request approval of a combination of pe riodic 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 p eriodic testing, in lieu of CEMS , initial compliance based on this method must be demonstrated by January 1, 2018.11 Table 5

RockTenn Facility SO 2 Reduction Project Source Changes

Source SO 2 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 SO 2 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 techno logy [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

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

and wheth er they would advance the [area’ s] attainment date.” See Approval & Promulgation of Air Quality Implementation Plans, 66 FR 586 at 607 (Jan. 3, 2001) ; se e 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

te chnological and economic feasibility.” (44 FR 53762; September 17, 1979.) See Memorandum from Roger Strelow titled, “Guidance for Determining Acceptability of SIP Regulations in Non

Attai nment Areas.” (December 9, 1976 ) ; s ee 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 an d 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 th e only source of SO 2 located in the nonattainment area and, consiste nt with CAA requirements under 42 U.S.C. § 7502(c)(1) , Rayonier is the only source for which a RACM/RACT analysis i s 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 attainm ent demonstration requires an area

- specific analysis that there are no additional economically and technol ogically12 DEP reviewed a variety of measures and technology that co uld be implemented by Rayonier in

order to reduce ambient SO 2 concentrations and comply with the revised SO 2 NAAQS. DEP considered a range of potentially available control technologies to determine whether they we re reasonably available for Rayonier to imp lement , and whether they would advance the area’s

attainment date. DEP specifically considered t hree general approaches to SO 2 emission

reduction :

• More efficient scrubber operation : All three SO 2 sources at the Rayonier facility are already equipped with SO 2 scrubber systems. These scrubbers are the primary method of

SO 2 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 SO 2 NAAQS and can be operated in a more efficient manner.

• R estriction of high

- sulfur fuels : Fuel sulfur content can have a significant effect on SO 2 emiss ions. 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 s tack height : Shorter stacks can subject the plume to the effects of building

downwash. Th is meteorological process can result in a concentrated plume reaching ground level very rapidly. An increased release height can decrease ambient

concentrations of SO 2 by allo wing the plume more time to disperse more efficiently away from turbulent air within the planetary boundary layer.

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

• Sulfite Recovery Boiler : The Sulfite Recovery Boiler is the largest S O 2 source at the Rayonier facility. The boiler fires spent liquor for the purposes of producing both combustion gases that contain recoverable SO 2 and heat for steam generation. Flue gases exiting the boiler are routed to an existing multi

- stage wet scru bber. The scrubber serves dual roles of process equipment to recover SO 2 and air pollution control to reduce emissions of particulate matter and SO 2

. 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 SO 2 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 re vised SO 2 standard. DEP has developed a control strategy for RockTenn incorporating a range

of SO 2 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 strate gy by December 31, 2017, more than nine months prior to the CAA attainment

deadline.13 absorber ammonia addition rate can be adjusted. SO 2 is recovered from the cooled flue gases in this final stage by reaction with fresh aqueou s 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. D EP has determined th at 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 SO 2 from this unit without increasing emissions of the fine particulate bypro duct. DEP determined that this was the only reasonable control measure for the recovery boiler as it is run at an optimal

SO 2 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 SO 2 emissions. In addition, the stack height is s ufficient to avoid dow nwash

effects. Rayonier proposed a reduction in their maximum allowable SO 2 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 reas onable

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 SO 2 emissions. DEP considered further restricting the use of No. 6 fuel oil but it was determined that this

would have a limited effect on SO 2 emissions as it is only fired during startup, shutdo wn, and solid fuel feed up sets

. The boiler emitted just 6.3 tons of SO 2 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 em issions in 2013 provide reasonable ass urance that the unit can

meet a reduced SO 2 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 enforce able SO 2 emission limit for this u nit from 420 lb/hr to 180 lb/hr

.

• Vent Gas Scrubber : The Vent Gas Scrubber is in itself SO 2 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 scru bber 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 SO 2 through gas absorption using alkaline scrubbing media. The upper section of the scrubber is d esigned as a direct

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

manage ope rating problems and calculates one

- hour and 24

- hour running averages of the

SO 2 concentration. The stack for this scrubber is on ly 110 feet in height, which is lower than the good engineering practi ce (GEP) height. An increase in the height of this stack would provide for potential ly significant reductions in ground

- level SO 2 concentrations near the facility. This strategy was deemed r easonable 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 SO 2 emissions over a larger area. Rayonier14 proposed to increase this stack from 11 0 feet to 180 feet. In addition, Rayonier proposed

to reduce the maximum allowable SO 2 emission limit from 250 ppm to 100 ppm

.

DEP determined that these measures at its three SO 2 sources constitute RACM/RACT for the

Fernandina Beach SO 2 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 technologi cally and economically feasible. T he reduced SO 2 emissio n limits made possible by these changes will allow for expeditious attainment and maintenance of

the revised SO 2 NAAQS in the nonattainment area. In fact, d ata from the reference monitor for the nonattainment area already show that the area is in complianc e with the revised SO 2 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 nonattainme nt 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 SO 2 emissions would be l ess than 7 tons per year. Although this proposed new facility will not be subject to new source review, DEP has

evaluated the SO 2 emissions increase attributable to this proposed construction project and

determined that the small increase in SO 2 emissions would not interfere with the state’s attainment plan.15 4. Air Quality Modeling Demonstration

4.1 Model Selection and C ontrol 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 SO 2 concentrations in the nonattainment area. Federally enforceable permit emission limits were used as model inputs. The modeling demonstration utilized the most

current versions of th e AERMOD models available at the time the modeling d emonstration was performed. Th e model versions used are listed below in Table 6

.

Table 6

Model Versions Used in the SO 2 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 SO 2

- emitting sources for the Rayonier facility as well as the RockTenn facility, the only significant sources of SO 2 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 SO 2 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 o btained from the construction permits

. Table 7 and Table 8 summarize the source parameters and SO 2 emission rates for all modeled point sources at the Rayonier and

RockTenn facilities.16 Figure 1

. Nassau County, Florida SO 2 Nonattainment Area

Table 7

Fernandina Beach SO 2 Attainment Demonstration

– Modeled SO 2 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 2 4.05 190.88

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. 6 5 21.00

4SDT Point RockTenn No. 4 Smelt Dissolving Tank 13 0. 1 3 1.03

5SDT Point RockTenn No. 5 Smelt Dissolving Tank 14 0. 1 5 1.1817 Table 8

Fernandina Beach SO 2 Attainment Demonstration

– Modeled Source Parameters

Source Coordinates Base Elevation Flowrate Diameter Exit Velocity Temperature Stack Height

UTM
x (m) UTM y (m) (ft) (m) (ft 3 /min) (m 3 /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

RTN 7 456,320.64 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

RTN 21 456,547.48 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 provi des a method of calculating an “equivalent” longer

- term emis sion limit where appropriate. 5 T he method involves finding the

“critical emission value”

– the emission rate at which the model would predict ambient SO 2

conc entrations at the level of the one

- hour SO 2 NAAQS

– then adjusting this rate downward so as to achieve a comparable stringency to the modele d one

- hour average emission limit. T he 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 99 th percentile one

- h ou r average emission rate to its 99 th
percentile longer

- term average emission rat e. 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 th e emission limit is in place.” With specific regard to RockTenn ’s

R ecovery Boilers No. 4 and No. 5 , compliance with the new em issions limits will require the

exclusive use of ultra

- lo w sulfur diesel (ULSD)

, with a maximum sulfu r content of 15 parts per million (0.0015 percent)

, as a fuel oil. T he facility is allowed by permit to burn ULSD, and t he

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

and No. 5. 6

T his 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 anal ysis

, consistent with EPA’s

Guidance for 1

- Hour SO 2 Nonattainment Area SIP Submissions, DEP has adjusted both

5 Guidance for 1

- Hour S O 2 N onattainment Area SIP Submissions, Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency , Research Triangle Park, N orth 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 Recove ry Boilers No. 4 and No. 5 will be limi ted 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 provi des a summary of this adjustment calcul ation

.

Table 9

Source Emission Rate Variability Analysis

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

3

- Hr/1

- Hr 1

- Hr Average 3

- Hr Average 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 anal ysis consisted of a continuous five

- year period of hourly surface weather observations and twice

- daily upper air so undings from the

Jacksonville National Weather Service Office at Jacksonvi lle 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 Limits19 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 locat ion being modeled. For this task, DEP used the AERMET preprocessor AERSURFACE. AERSUFACE utilized the 1992 National Land Cover Dataset (NLCD) for Florida to extract

su rface 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 i s 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 (z

o )
Jacksonville International Airport 0.14 0.44 0.058

Fernandina Beach SO 2 Nonattainment Area 0.13 0.21 0.321

4.6 Land Use Classification

Land

- use classification was determined using Auer’s 9 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 fift y percent of the area consists of Auer land

- use in dustrial, 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

- kilo meter radii around each facility. According to the U.S. Census Bureau, the population density of the city of Fernandina Beach was approximately 408 people/km 2 in 2013 which is below the EPA suggested urban threshold of 750 people/km 2

. Based on this analys is, 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.html20 Figure 2

. Nassau County, Florida

– SO 2 Nonattainment Area Land Use

4.7 Terrain Data

Terrain elevations were incorporated into the modeling using AERMAP. For this mo deling 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 region s, 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. T he 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

b oundaries) was used. The grid encompasses the entire nonattainment area, except facility21 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 co mpletely 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 natur al 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 SO 2 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 SO 2 National Ambient Air Quality Standards Designations Modeling T echnical Assistance Document. 11 The d ata 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

SO 2 concentrations at this sit e

– illustrated in Table 12

– only the most recent two years of data were used rather than the recommended three years.

11 S O 2 National Ambient Air Quality Standards Designations Modeling Tech nical Assistance Document. U.S.

E nvironmental Protection Agency, Research Triangle Park, North Ca rolina 27711. http://epa.gov/airquality/sulfurdioxide/pdfs!S02ModelingTAD.pdf22 Table 12

2003

– 2014 Monitored SO 2 Design Values for Monitor ID: 12

- 089

- 0005

- 42401

- 1

Year Ranked 1

- hr Averages Ranked 3

- hr Averages Ranked 24

- hr Averages Annual 99 th Percentile Design

1 st 2 nd 1 st 2 nd 1 st 2 nd 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* 3 6 * 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 illust rated 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 pollu tants 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 99 th 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

back ground 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 Mo dels

.23 Figure 4

. 2012

- 2013 Average Ambient SO 2 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

SO 2 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 SO 2 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 emissi on sources at Rayonier and Rock Tenn. However, a two

- unit emissions cap was develope d for Rock Tenn’s two recovery boilers in order to provide the facility with increased operational flexibility while

si multaneously reducing SO 2 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 e mitted 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 SO 2 Impact in Nonattainment Area (μg/m 3 )

Model Scenario Averaging

Time Max Predicted Impact Background Total Impact SO 2 1

- Hour NAAQS Greater Than NAAQS? Rayonier RockTenn

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 present s the maximum of the25 five

- year average of 99 th 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

. T he area of highest concentration is found adjacent to the southwest

c orner of the Rayonier facility , on Rayonier

- owned property, where emissions from sources at

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

Boiler

, the area of maximum concentration occurs north of Rayonier n ear the RockTenn facility

. 13

In accordance with EPA’s Guidance for 1

- Hour SO 2 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 SO 2 levels in the area

. 14 As shown, the modeling results predict no violations of the revised SO 2 NAAQS within the nonattainment area. For comparison, Figur e 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 SO 2 concentrations of more than 90%.

Figure 6

. Post

- Modification Modeling Maximum Allowable SO 2 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 SO 2 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 attainme nt date.” Guidance for 1

- Hour SO 2 Non attainment 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 SO 2 Nonattainment Area SIP Submissions (April 2014), Appendix A, Section 5. Modeling Domain, p. A

- 7. Maximum Concentration:

193 μg/m 3 P ost

- Modification Allowab l e Emissions RockTenn26 Figure 7

. Pre

- Modification Modeling Maximum Allowable SO 2 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 nonatt ainment or maintenance area. Florida seeks through this SIP submittal approval of the state’s nonattainment area plan for Nassau County, in the form of federally

enforceable air permit conditions addressing SO 2 emissions from two facilities , as detailed

ab ove . EPA’s approval of t his 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 underst ood. EPA has stated that the RFP concept is less applicable to SO 2 , as SO 2 is a localized pollutant with limited sources. 15 D ata from the reference monitor for the Nassau County nonattainment area already show that the area is in compliance with the revised

SO 2 standard. As previously mention ed, Rayonier has completed its SO 2 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 r evised SO 2 standard. By

15 SO 2 Guideline Document. Office of Air Quality Planning and Standards, U.S. Environmental Protection Agency

, Research Triangle Park, North Carolina 27711

. P re

- Modification Potential Emissions RockTenn

Maximum Concentration:
2,962 μg/m 327 impl ementing the control measures specified in this SIP revision as expeditiou sly 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 revis ed

SO 2 NAAQS by the attainment date of October 4, 2018

. I n the “General Preamble for the Imple mentation of Title I of the Cle an Air Act Amendments of 1990,” published on April 16,

1 992 at 57 FR 13498, EPA expressly discussed contingency measures for SO 2

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

attainment re volves 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 SO 2 NAAQS and to un dertake an aggressive follow

- up for compliance and enforcement includ ing 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 register ed SO 2 levels in excess of the standard (75 ppb 1

- hour daily maximu m concentration) for a fourth time during a calendar year prior to the attainment date , or upon notification by DEP that the area has fail ed to
attain the revised SO 2 NAAQS by the attainment date

, Rayonier and Rock Tenn w ill , 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 nonattainmen t area plan. Rayonier and Rock Tenn 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 parameter s of all emissions units for four 10

- day period s up to and including the date s upon which t he reference moni tor registered each of the four exceedance s , together with recommended provisional SO 2 emission control strategies for each affected unit and evidence that these control strategies have been deployed, as appropriate. Upon receipt of these written

system au dit reports, DEP w ill immediately begin a 30

- day evaluation period to dia gnose the

cause of the monitored exceedance. This w ill be followed by a 3 0

- day consult ation 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, w hite liquor scrubber system enhancement, and physical or operational reduction of production capacity, as appropriate

. DEP

woul d 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 SO 2 Nonattainment Area SIP Submiss ions ( April 2014 ), “[F] or S0 2 , 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 1354 7, 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., R FP (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 auth ority 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 tha t a reference monitor for the area has register ed SO 2 levels in excess of the standard (75 ppb 1

- hour daily maximum concentrati on) for a fourth time during a calendar year after the attainment date

, or upon notification by DEP that a monitored SO 2 violation based on the design value has occurred after the attainment date, Rayonier and

Rock Tenn w ill , without any further action by D EP or the U.S. Environmental Protection Agency, immediately undertake a full system audit of all emissions units subject to control under

this nonattainme nt area plan. Rayonier and Rock Tenn will each independently submit to DEP in writing, within 10 days o f 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

, toge ther with recommended provisional SO 2 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 w ill immediately begin a 30

- day evaluation period to diagnose the cause of the monitored exceedance. This w ill be followed by a 3 0

- day consu ltation 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 liq uor 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 a dditional 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 g rowth 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 SO 2 emissions in the area

. In the event that any new or modified major statio nary sources of SO 2 were proposed for construction, Florida’s

Nonattainment area New Source Revi ew regulations at Section 62

- 212 .500, F.A.C., would apply

to the designated nonattainment area for the 2010 SO 2 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 SO 2 emission limits from the air construction permit s authorizing the SO 2 reduction projects at the Rayonier and RockTenn facilities including o perating limitations and stack height increases, as detailed under the section of this submittal titled “Materials Proposed to be Incorporated into the SIP

. ” As demonst rated above, these measures will provide for

attainment and maintenance of the revised S O 2 NAAQS in the Nassau County nonattainment

area before the attainment date of October 4, 2018

.30 Response to 40 CFR P art 51, A ppendix V, C riteria

Pursuant to 40 CFR Part 51, Appendix V, t he 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 “L etter of S ubmittal, ” 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 th e 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 ad option/issuance date.

This proposed revision to Florida’s SIP consists of specific provisions of two federally enforceable air construction permit s, Permit No. 08900 0 4

- 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 th ese permit s 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 au thority 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 Flor ida 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 forma t, 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. 08900 0 4

- 036

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

- 046

- AC , issued in final f orm to RockTenn31 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 ( S ection 120.525, F.S.) require s DEP to give notice of public meetings, hearings, and workshops by publication in the Florida Administrative Register (F A R ) not less than seven days

before the event. Through publication in the F A R 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 notification s may be found in the “Public Participation ” and “Pre

- Hearing Submittal

to EPA” section s 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 “L etter of S ubmittal. ”

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

Wri tten 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 ( SO 2 ).

(b) Identification of the locations of affected sources including the EPA attainment/nonattainment designation of th e locations and the status of the attainment plan for the affected areas(s).

This SIP revision applies to the SO 2 nonattainment area located in Nassau County , Florida

. The designated nonattainmen t 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, UTM32 zone 17, using the NAD83 datum (the location of the violating ambient monitor) and the radius being 2.4 kilome ters.

The nonattainment area contains within its boundaries one m ajor point source for SO 2 emissions

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

source of SO 2 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 Florid a’s SO 2 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 chan ges 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 ( SO 2 ) 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 t he national primary ambient air quality standards for at least 10 years as required by section 175A of the Act.

See “ Sulfur Dioxide ( SO 2 ) Attainment Demonstration

– Technical Document” section of this

submittal.

(e) Modeling information required to suppor t 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 o ther information relevant to the determination of adequacy of the modeling analysis.

See “ Sulfur Dioxide ( SO 2 ) Attainment Demonstration

– Technical Document ” section of this

submittal. See also CD containing an electronic copy of this document together wit h all SO 2 air quality modeling files.

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

See Rayonier and Rock Tenn Air Construction Permit s ( 0890004

- 036

- AC and 08900 03

- 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 SO 2 emissions limits for each affected unit, specifi ed operating parameters, and specified compliance measures from the Rayonier and Rock Tenn 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 ope rating parameters and compliance measures from the Rayonier and Rock Tenn 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 requi red 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 varianc es 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

o nline 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 a ir 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 sourc es (403.061(13)) ; require permit s 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 th e Clean Air Amendments of 1990.

403.0877 Authority to require engineering certif ication of permit applications.

403.121 Authority to seek judicial and administ rative remedies for violations.

403.131 Authority to seek in junctive relief for violations.

403.141 Authority to find civil liability for violations.

403. 1 61 Authority to assess civil and cri mina l penalties for violations.

403.182 Authority for loc al pollution control programs.

403. 20 1 Authority to grant variances.

403.716 Authority to require training of medic al waste incinerator operators.

403.8052 Authority to establish a Small Business Assista nce Program for small

- business sources of air pollu tant 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 a llow use of general permits (permits

- by

- rul e) for minor sources

.

Other statutory authorities (outside of Chapter 403, F.S.) for Florida’s a ir r esource m an agement 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 version s 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 T ampering 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 Program36 Materials Proposed to be Incorporated into the SIP

DEP is proposing that the following SO 2 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 SO 2 NAAQS in the nonatt ainment area located in Nassau County.

Specified Limits and Conditions from Rayonier P ermit ( Permit No. 08900 0 4

- 036

- AC )

DEP is proposing that the following emission limits and operating parameters from the Rayonier

Permit be incorporated into Florida’s S IP in satisfaction of the Clean Air Act requirements for

attainment and maintenance of the revised SO 2 National Ambient Air Quality Standard (NAAQS) in the nonattainmen t area located in Nassau County.

EU 005

– Vent Gas Scrubber and Direct Contact Condenser

SO 2 Emission Limits : 100 ppm (3

- hour average) SO 2 limit

.

Compliance Monitoring : SO 2 concentrations in the stack is measured continuously using a C E MS.

Emission Reporting : Repor ting Requirements A.5. (Page 8 of 12)

. (NOTE: as

built stack parameter of 180 feet recorded in Rayonier’s Title V Per mit [Permit

No. 0890004

- 042

- AV]

. )

EU 006

– Recovery Boiler

SO 2 Emission Limits : 250 ppmvd (3

- hour average) SO 2 limit

.

Compliance Monitoring : SO 2 concentrations in the stack is measured continuously using a C E MS.

EU 022

– No. 6 Power Boiler

SO 2 Emission Limits : 180 lbs/hour (3

- hour average) SO 2 limit at the stack height

of 190 feet

.

Compliance Monitoring : SO 2 emissions are monitored by a CEMS.

The se 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 provide s on the following pages a facsimile of the Rayonier Permit ( Permit No. 0890004

- 036

- AC) in its entirety.37383940414243444546474849 Specified Limits and Cond itions from RockTenn P ermit ( 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 SO 2 National Ambient Air Quality Standard (NAAQS) in the nonattainmen t area located in Nassau County.

EU 006

– No. 5 Power Boiler

SO 2 Emission Limits : Effective January 31, 2016 through November 30, 2017, SO 2 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 monitori ng system (CEMS), during all periods of operation except when operating as a backup control device firing NCGs. Effective December 1, 2017, SO 2 emissions from the No. 5

Power Boiler shall not exceed 15.0 lb/hour based on a 3

- hour block average as

determine d by data collected from a CEMS during all periods of operation.

Compliance Monitoring : The CEMS shall be measuring and recording in units of the

SO 2 emissions standard by the first effective date f or this new emission standard.

EU 015

– No. 7 Power Boiler

SO 2 Emission Limits : Effective January 31, 2016, SO 2 emissions from the No. 7 Power

Boiler shall not exceed 1225.20 lb SO 2 /hour based on a 3

- hour block average as determined by the current compliance demonstration methods in the Title V air operat ion 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, SO 2 emissions from the No. 7 Power Boiler shall not exceed

1225.20 lb SO 2 /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 SO 2 emissions and exhaust flow for reporting in units of the applicable standard. Emissions shall be monitored and recorded during all periods of boiler operation i ncluding 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 (Sta ndard CEM S Requirements) of the permit. The CEMS shall be installed, certified and recording valid data in units of the SO 2 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 De cember 1, 2017.50 EU 007

– No. 4 Recovery Boiler

EU 011

– No. 5 Recovery Boiler

SO 2 Emission Limits : Effective January 1, 2018, SO 2 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 SO 2 emissions cap: Effective January 1, 2018, combined SO 2 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 c ollected from a c ertified CEMS.

Compliance Monitoring : Unless otherwise approved by the Division of Air Resource Management, compliance with the SO 2 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 SO 2 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 includin g 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 (Sta ndard CEMS Requi rements) of the permit. If the permittee elects the combined SO 2 emissions cap, compliance must be demonstrated with CEMS data. The CEMS shall be measuring and recording valid data in units of the SO 2 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 Boiler s 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 an d emissions limits for the Rock Tenn facility, which Florida is requesting that EPA approve for incorporation in to Florida’s SIP, are new

conditions and limits. In Florida’s existing SIP, Power Boiler 5 has an SO 2 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 ru le 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

- 04 6

- AC) in its entirety.5152535455565758596061 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 th e 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 hear ing. 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 publ ic 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 co mments , request a public hearing, and participate in a public hearing , if requested, on the proposed SIP revision was advertised in the Florida Administrative Register (FA R ) at least 30 days prior to the scheduled date of the hearing

. Information regarding

t he 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

noti ce is included in this section. No hearing was requeste d, 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 require d 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

announc ing 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 FA R 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 Resourc e 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 informati on 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

h earing date and provided with copies of the material s 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 contr ol 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 hear ing 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 revisio n was noticed in accordance with th e 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 proc edures for public hearings. [...]

Not applicable.63 Notice of Opportunity to Submit Comments and Participate in Public Hearing6465 Requests for District s/Locals to Provide Assistance to Public66 Public Comments on SIP Notice

During the public comment period, Rock Tenn CP, LLC (Rock Tenn) 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 emissio ns calculations for Recovery Boilers No. 4 and No. 5. RockTenn further indicated that in order to meet the new

enforceable SO 2 emission limit at these units, the units would combust ultra low sulfur diesel (ULSD), a fuel allowed under the facility’s exist ing 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 a n u pdated data set from RockTenn.67 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 SO 2 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 ne w appendix

created in respon se to an EPA comment

. ) The revised data corrected for an incorrect emission

factor used by RockTenn for determining SO 2 emissions from fuel oil use in Recovery Boilers

No. 4 and No. 5.

RockTenn also communicated that the dev elopment 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 B oilers 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 e ffective 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 i nto the SIP” section of this SIP submittal.

DEP notes that EPA ’s “ Guidance for 1

- Hour SO 2 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 s hould 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 th e use of ULSD fuel oil

. DEP subs tituted 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,

t he 1

- hour to 3

- hour adjustment changed (from the pre

- hearing draft) fro m 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. F or Recovery Boiler No. 5

, there was no change in the adjustment factor

.68 P re

- Hearing S ubmittal to EPA

Pre

- H earing Submittal Letter6970 Materials Enclosed with Pre

- Hearing Submittal

• Notice of P roposed SIP R evision . See “ Notice of Opportunity to Submit Comments and Participate in Public Hearing ” section of this submittal

.

• Rayonier A ir C onstruction P ermit ( Permit No. 08900 0 4

- 036

- AC)

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

.

• RockTenn A ir C onstruction P ermit ( Permit No 0890003

- 046

- AC)

. S ee “Materials Proposed to be Incorporated into the SIP” sec tion of this submittal

.

• A ir Q uality M odeling F iles . T hese 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.71 EPA Comments on Pre

- Hearing Submittal7273 DEP Response to EPA Com m ents

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 Comment s

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 fract ion of population in the area. Tables 3a. and 3b. have been updated with the revised values.

DEP has also added a new A ppendix 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 en titled “Materials Proposed to be Incorporated into the SIP.” Florida is expressly requesting that EPA consider for incorporation and approval into the SIP new SO 2 emissions limits for each affected unit, specified operating parameters, and the compliance m easures 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 up on annu al reporting requirements. O nroad mobil e emissions were determined using MOVES2014. DEP utilized the NEI only to account for the very small additional SO 2 emissions within the nonattainment area. Given the small nonattainment area addressed in this SIP, DEP

believes that NEI data for the area source cate gory 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 additio nal emissions from other sources would not significantly alter this accuracy, and current

– the 2011 inventory rep resents 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 ca tegories 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 mob ile categories. Point sources we re directly accounted for using emissions data reported to the DEP for yea r 2011. Onroad mobile sources we re estimated using the MOVES2014 emissions processor. Area and nonroad mobile data we re deri ved74 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 MOVES20 14 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 estimat ed 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 adjust ed compliance averaging time and incorporated related

discussion into the text of the attainment demonstration

.