Oklahoma Department of Environmental Quality s1

DRAFTOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISIONMEMORANDUM October 11, 2004TO: Dawson Lasseter, P.E., Chief Engineer, Air QualityTHROUGH: Richard Kienlen, P.E., Engr. Mgr. II, New Source Permits SectionTHROUGH: Peer Review, Hal WrightFROM: David Pollard, ROATSUBJECT: Evaluation of Permit Application No. 99-113-TV Fort James Operating Company Muskogee Mill 4901 Chandler Road, Muskogee Section 33 & W1/2 Section 34, T15N, R19EIM Muskogee County, OK Directions: Muskogee Turnpike to Chandler Exit, East to 45th Street, South to Harold Abitz Drive, East into facility.SECTION I. INTRODUCTIONFort James Operating Company (applicant) has submitted an application for a Tier II, Major Source Facility, Operating Permit, with the required fee of $2,000, which was received by the Department of Environmental Quality, Air Quality Division (AQD) on March 5, 1999. The applicant owns and operates the Fort James Operating Company, Muskogee Mill, an existing major manufacturer and converter of sanitary paper products such as tissue, napkins, and paper towels (SIC 2621, paper mills) at the above location. Auxiliary operations include flexographic printing, platemaking, and production polyethylene film wrap for the paper products.The applicant has submitted numerous changes to the application. On September 23, 1999, AQD received corrections for the estimated Volatile Organic Compounds (VOCs) emissions from the five paper machines, the pulp processing system, and solvent cleaning because of corrected emission factors and increased usage of cleaning solvents. On November 9, 1999, AQD received a modification to the application to incorporate the use of VOC-containing enhancement chemicals in the paper machines. On December 1, 2000, AQD received a modification to the TV application to incorporate the use of propane as a secondary fuel for paper machines PM-11, PM-12, and PM-13. Both of these modifications have been incorporated into the TV application as revisions to the application, as stated they would be in the AQD correspondences to the applicant. PERMIT MEMORANDUM 99-113-TV DRAFT 2On November 11, 2001, AQD received corrections to the pollutants associated with pulp and paper production rates to account for a forecasted increase of 19.5% instead of 16.32%, and also to correct the chloroform emission factor for Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15. On July 11, 2002, AQD received revisions to the emissions calculation for PM-11, PM-12, PM-13, PM-14, and PM-15 to account for unspeciated VOC emissions. On October 25, 2002, AQD received a revision to the emissions for PM-11, PM-12, PM-13, PM-14, and PM-15 to account for particulate emissions (not from combustion sources).In addition to the above application revisions/corrections, the AQD also received responses to five Notices of Deficiency (NOD’s). These NOD’s are summarized in chronological order below:1. On February 16, 2001, AQD received a response to an NOD requesting MSDS’s and product usage rates for the pulp and papermaking processes. 2. On November 2, 2001, AQD received a response to an NOD requesting a number of items including plot plans, stack dimensions, stack discharge rates, component function, and clarification of some modeling results along with the National Council For Air And Stream Improvement (NCASI) report. 3. On November 6, 2003, AQD received a response to an NOD requesting burner rating information and a number of clarifications/corrections to emission factors used for the paper machines, boilers, and the Poly Plant. 4. On May 27, 2004, AQD received a response to an NOD requesting additional technical justification for calculated emissions from the pulp processing and paper machines. 5. On September 1, 2004, AQD received a response to an NOD requesting additional information for: the coal preparation plant including equipment identification, emissions calculations, and controls for the crusher; technical justification for emissions from the flexographic polyethylene printer; emissions calculations for the paper machine additives; emissions calculations for the coal pile; emissions calculations for the catalytic incinerator; justification for air dispersion modeling of pollutants emitted from the paper pulping processes, paper machines, flexo-plate making, and flexographic printers; burner identification for the Paper Machine PM-12 drying hood; refinement and completion of a process flow table for the paper pulping process; clarification of monitoring methods used for the catalytic incinerator; identification of equipment components used in the paper pulping processes; identification of equipment components used in the flexographic printing processes; additional emissions calculations and/or justification for toxic air contaminants emitted from boiler B-1, polyethylene extruder, flexographic printers, and paper machine additives; additional justification for calculations of PM emissions from the paper machines; and finally, a review and editing of a draft version of the permit memorandum as it existed at the time the NOD was issued.The AQD also received, on May 16, 2002, an application for an Applicability Determination (AD) dated May 14, 2002, requesting applicability for changes that had occurred in AP-42 emission factors since the initial March 5, 1999, application submittal.The facility began construction in 1975 and has been in operation since 1978 with an extensive permitting history. The facility operates under numerous permits, the first being issued on October PERMIT MEMORANDUM 99-113-TV DRAFT 36, 1975. The facility was issued a PSD permit in 1984 to operate Boiler B-4 and Paper Machine PM-14. The facility was issued another PSD permit in 1997 to operate a polyethylene extruder, a flexographic printing press (for printing on the polyethylene), and a catalytic oxidation incinerator. Following is a chronology of permitting activity for the facility based on events listed in the TEAM database and information contained in the most recent application for a permit.Chronology of Permitting Activity10/06/75 - Permit No. 75-053-C was issued for the pulp and paper mill, including Boilers B-1 & B-2, Yankee Dryers for Paper Machines PM-11 & PM-12, and two 10,000-gallon gasoline storage tanks. 01/09/78 - Permit No. 77-076-C was issued for B-3 and associated equipment. It is generally accepted that the associated equipment consisted of what is known as FP-1, which amounts to six flexographic printers. 03/22/79 - Permit No. 79-021-C was issued for the Yankee Dryer for Paper Machine PM-13. 08/31/79 - Permit No. 75-053-O was issued for the pulp and paper mill. 01/05/81 - Permit No. 80-059-C was issued for dual fuel gas turbine generator. 09/01/81 - Permit No. 81-081-C was issued for DG-1 and DG-2. 09/29/81 - Permit No. 81-066-C was issued for B-4 and PM-14. 10/21/81 - Permit No. PSD-OK-404 M-1 was issued by EPA for B-4 and PM-14. 12/18/81 - Permit No. 79-021-O was issued for the Yankee Dryer for Paper Machine PM-13. 03/31/82 - Permit No. 77-076-O was issued for B-3. 02/09/83 - Permit No. 81-081-O was issued for DG-1 and DG-2. 09/14/83 - Permit No. 83-062-C was issued for 3 polyethylene extruders and 2 flexographic printing presses. 05/07/85 - Permit No. 81-066-O was issued for B-4 and PM-14. 04/22/92 - Permit No. 91-127-C M-1 was issued for PM-15. 06/19/95 - Permit No. 91-127-O was issued for PM-15 and ClO2 Plant. 05/30/97 - Permit No. 97-218-C was issued to install 2 flexographic printers. Only one press, FP-7, was installed. 09/29/97 - Permit No. 83-062-O PSD was issued for one polyethylene extruder, one flexographic printing press (for printing on the polyethylene), and a catalytic oxidation incinerator. 10/15/97- Permit No. 91-127-O M-1 was issued to correct the size of the burners and emissions estimates for PM-15. 03/05/99 - Application for Permit No. 99-113-TV submitted. 03/25/99 - Application for Permit No. 97-218-O withdrawn.SECTION II. PROCESS DESCRIPTIONThe facility is a major manufacturer and converter of sanitary paper products, i.e., they make parent rolls and they also make finished products such as tissue, napkins, and paper towels. Many of these products are printed with decorative inks during the converting process. The main processes involved in papermaking are pulping, de-inking (bleaching out the inks in the recycled paper), paper production, and printing. The company’s basic raw material for wet papermaking is currently recycled wastepaper and a small amount of purchased pulp, which is processed into pulp using a PERMIT MEMORANDUM 99-113-TV DRAFT 4 proprietary process. The facility typically recycles over a thousand tons of wastepaper per day. The applicant has indicated that future products may be made from other sources of fiber. Since this may result in different emissions from the materials or the use of different additives and also the applicability of additional regulations and/or MACT standards, the facility will need to evaluate these issues to determine the needs for submitting a permit application.Pulping and Pulp Processing The derivation, rationale, and technical justification for the emission calculations are presented in the section for emissions. Following is a description of the equipment used in the pulping process. Pulpers - Use mechanical agitation and water to convert wastepaper to a pulp slurry. Stock Blend Tank - Used to blend pulp. Screens - Separate solid contaminants from the pulp slurry. Washers – Separate solid contaminants from the pulp slurry. Stock Presses – Used to dewater the pulp slurry and increase consistency. Mixer – Used to mix the pulp slurry with process water, dilution water, chemicals, etc. Flotation Cell Washers – Remove solid contaminants from the pulp slurry. Cleaners – Remove solid particle contaminants. Bleach Towers – Provide residence time to allow the bleach medium to react with the pulp slurry. Thickeners – Used to increase pulp slurry consistency.The pulping and pulp processing systems process and bleach wastepaper for use in the manufacture of tissue, towel, and napkin paper. This proprietary process uses bleaching agents on most grades of paper. Recycled wastepaper is re-pulped by physical and chemical processes into a pulp slurry to recover usable fiber, blended with various de-inking and bleaching compounds, and processed into paper stock to make the paper products. At the pulpers, recycled wastepaper is blended with hot water while mechanical agitation is used to convert the mixture into pulp slurry. Generally, the incoming slurry is screened to remove debris and impurities. Contaminants are removed in this step, as well. Additional contaminant removal is accomplished by means of processes performed by other equipment described above. Bleaching agents are added to the slurry for the purpose of increasing brightness. The facility uses no chlorine or chlorine dioxide to bleach pulp. Bleached pulp is stored in storage tanks for later use on paper machines to make paper. VOCs and organic pollutants are released during pulp processing as a result of chemical and mechanical processes.The Low Consistency Washers aerate the pulp slurry, which results in bubbles on top of the material. A rotating vacuum arm removes the bubbles from the top of the material and into a separator where liquids and vapors are separated. The vent from the No. 2 flotation unit vacuum system was tested by The National Council for Air and Stream Improvement (NCASI). The vapors are vented to the atmosphere. Two vented bleaching towers were also tested by NCASI. The applicant has indicated that bleaching agents and aids other than those currently used, may be used in PP-1 in the future. The facility will need to evaluate emissions impacts to determine permitting requirements.Paper Production The processed secondary pulp fiber is pumped to the paper machines, PM-11, PM-12, PM-13, PM- 14, and PM-15, where the parent rolls are produced. Much of this paper is converted to finished product at the facility. Water is removed from the incoming pulp stock by a screen. The pulp is PERMIT MEMORANDUM 99-113-TV DRAFT 5 then sprayed onto a belt where a vacuum is pulled from below to remove additional water. Residual moisture is removed from the produced paper as it is dried in the Yankee Dryers by steam and/or fuel-burning hoods. These drying processes result in emissions of VOCs from the pulp and paper. Natural gas is the primary fuel, No. 2 fuel oil a secondary fuel, and propane, as mentioned earlier, was designated in an application submitted on December 1, 2000, as a secondary fuel. PM-11 and PM-12 have after-dryers that use steam from the power plant. Combustion emissions and some additional VOC emissions are generated from the fuel-burning processes. Emissions were measured from building vents and equipment vents for PM-12 and PM-14 by NCASI. Additional emissions from the additives incorporated into the process subsequent to the NCASI testing are estimated by the applicant to be 60% of the VOC content, with 20% retained in wastewater and the other 20% is consumed (i.e., used up or reacts with latex contaminants). These values are based on testing done at other facilities. Following is a description of each paper machine.PM-11 is a 209-inch, wet crepe/dry crepe twin-wire periformer, manufactured by KMW, with a suction forming roll, single-felted press section, two pressure rolls, an 18-foot Yankee dryer equipped with two 24 MMBTUH gas-fired hoods, and five after-dryers. No. 2 fuel oil and propane can be used as backup fuels. The stock system is conventional, utilizing a drum save-all for fiber recovery and an air flotation clarifier for water recycling.PM-12 is a 209-inch, wet crepe twin-wire periformer, manufactured by KMW, with a suction forming roll, single-felted press section, two pressure rolls, an 18-foot Yankee dryer equipped with two 16.5 MMBTUH gas-fired hoods, and fourteen after-dryers. No. 2 fuel oil and propane can be used as backup fuels. The stock system is conventional, utilizing a drum save-all for fiber recovery and an air flotation clarifier for water recycling.PM-13 is a 209-inch, wet crepe/dry crepe S-wrap twin-wire periformer, manufactured by KMW, with a solid forming roll, single-felted press section, two pressure rolls, an 18-foot Yankee dryer equipped with two burners rated at 16.5 MMBTUH gas-fired hoods, and eight after-dryers. No. 2 fuel oil and propane can be used as backup fuels. The stock system is conventional, utilizing a drum save-all for fiber recovery and an air flotation clarifier for water recycling.PM-14 is a 271-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming roll, single-felted press section, two pressure rolls, and an 18-foot Yankee dryer equipped with two 24 MMBTUH gas-fired hoods. No. 2 fuel oil can be used as a backup fuel. The stock system is conventional, utilizing a drum save-all for fiber recovery and an air flotation clarifier for water recycling.PM-15 is a 273-inch, dry crepe twin-wire periformer, manufactured by Beloit, with a solid forming roll, single-felted press section, two pressure rolls, and an 18-foot Yankee dryer equipped with two 25 MMBTUH gas-fired hoods and high temperature hot water. The stock system is conventional, utilizing a disc save-all for fiber recovery and an air flotation clarifier for water recycling. Emissions were measured from Paper Machine Nos. 12 and 14 by NCASI. Emission measurements for Paper Machine No. 12 were taken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum Systems Vent, the After Dryer Vent No. 1, the Yankee Dryer Vent, and the After Dryer Vent No. 2. Emissions measurements for Paper Machine No. 14 were taken at the Fan Pump Silo Vent, the PERMIT MEMORANDUM 99-113-TV DRAFT 6Yankee Wet-Side Dryer, the Yankee Dry-Side Dryer, the Vacuum Systems Vent, and the Wet End Roof Vents.The table below summarizes the equipment used in each system line and the point of entry in the process for additives in the order they are utilized. Items in italics represent chemical additives and items in bold represent emission units that were tested by NCASI.Process Flow – Paper Machines PM-11 PM-12 PM-13 PM-14 PM-15 Wet Strength Wet Strength Wet Strength Wet Strength Resin (Grade Resin (Grade Resin (Grade Resin (Grade Specific) Specific) Specific) Specific) Sheet Texture Sheet Texture (Gra (Grade Specific) de Spec ific) Machine Chest Machine Chest Machine Chest Machine Chest Charge Control Dry Strength Dry Strength (Grade Specific) (Grade Specific) Dyes (Grade Dyes (Grade Dyes (Grade Dyes (Grade Specific) Specific) Specific) Specific Absorbency Absorbency Aid Absorbency Aid Absorbency Aid Aid (Grade (Grade Specific) (Grade Specific) (Grade Specific) Specific) Flow Box Flow Box Flow Box Flow Box Flow Box Biocide Biocide Biocide Biocide Biocide Defoamer Defoamer Defoamer Defoamer Defoamer Silo Silo Silo Silo Silo Wire Wire Passivation Wire Passivation Wire Passivation Wire Passivation Passivation (Normally off) Inner & Outer Inner & Outer Inner & Outer Inner & Outer Inner & Outer Wire Wire Wire Wire Wire Solvent (As Solvent (As Solvent (As Solvent (As Solvent (As Needed) Needed) Needed) Needed) Needed) Felt Cleaner Felt Cleaner Felt Cleaner Felt Cleaner Wires & Felt Wires & Felt Wires & Felt Wires & Felt Wires & Felt Yankee Yankee Coating Yankee Coating Yankee Coating Yankee Coating Coating Yankee Release Yankee Release Yankee Release Yankee Release Yankee Release Yankee Dryer Yankee Dryer Yankee Dryer Yankee Dryer Yankee DryerProcess Flow – Paper Machines (cont’d) PM-11 PM-12 PM-13 PM-14 PM-15 PERMIT MEMORANDUM 99-113-TV DRAFT 7Charge Charge Additive Charge Additive Charge Additive Additive Polymer Polymer Polymer Polymer Krofta (part of Krofta (part of Krofta (part of Krofta (part of Krofta (part of water system) water system) water system) water system) water system) Felt Cleaner Caustic Felt Caustic Felt Caustic Felt Caustic Felt (As Needed) Cleaner (As Cleaner (As Cleaner (As Cleaner (As Needed) Needed) Needed) Needed) Acid Felt Cleaner Acid Felt (As Needed) Cleaner (As Needed) Felt Felt Guardboard Felt Guardboard Guardboard Dye Dye Neutralizer Dye Neutralizer Dye Neutralizer Neutralizer (Grade Specific & (Grade Specific (Grade Specific (Grade part of water & part of water & part of water Specific & part system) system) system) of water system) Chlorine Chlorine Chlorine Chlorine Neutralizer Neutralizer Neutralizer Neutralizer (Grade (Grade Specific & (Grade Specific (Grade Specific Specific & part part of water & part of water & part of water of water system) system) system) system) After Dryers After Dryers After Dryers Slimicide (Batch Use) White Water Tanks (Part of water system) Vacuum Vacuum System Vacuum System Vacuum System Vacuum System System (not (not part of the (not part of the (not part of the (not part of the part of the direct flow of direct flow of direct flow of direct flow of direct flow of paper) paper) paper) paper) paper) Wet End Roof Vents (not in the direct flow of paper) PERMIT MEMORANDUM 99-113-TV DRAFT 8Solvent Cleaning of Paper Machines SC-1 is the designation of emissions generated from solvent cleanup of the paper machine clothing (felts and wires). Cleanup solvent is pumped from tanks or totes to paper machines PM-11, PM-12, PM-13, PM-14, and PM-15 for application on the machine clothing. The purpose of this cleanup is to rid the machine clothing of any contaminants, commonly known as stickies, which may be deposited from the paper stock going to the machines. These contaminants would adversely affect product from the machine by forming small holes or creating inconsistencies in the paper if not cleaned regularly. Additionally, smaller amounts of solvent are used occasionally for cleaning equipment at the pulp processing mill, PP-1.Flexographic Paper Printing Designs are printed on the tissue products by flexographic paper printer systems FP-1 and FP-7. Both systems use water-based inks for printing. At the time of the inspection, it was stated that the inks contain less than 0.03% VOCs by weight content.FP-1 consists of six flexographic printing presses that print paper parent rolls to produce printed parent rolls. These printed parent rolls become paper towel and napkin products.FP-7 is a 101.5-inch, four color, in-line flexographic printing press and re-winder that also prints paper parent rolls to produce printed towel products at the end of the unit.Polyethylene Extruding and Flexographic Printing (polyethylene film) The polyethylene extruder, the plate-making room, and the flexographic printing room are all housed in the Poly Plant Building.Flexo-plate making is conducted in the plate-making room. The plates are produced for use with all of the mill plant’s flexographic printers. VOC-containing solvents are used in the finishing step of plate-making. VOC emissions from a plate washing process are discharged from the building through a horizontal vent. A smaller amount of fugitives leave the room through two door openings into the Poly Plant building. The Poly Plant building has numerous vents, the most prominent being three 5’ x 5’ exhaust vents down the center-line peak of the building roof. These vents have hinged- flap rain caps which result in somewhat of a horizontal discharge. Some of the solvent is recovered and recycled.PO-1 is the designation of the polyethylene extruding plant. The paper products are ultimately wrapped with polyethylene over-wrap and other materials, packaged, and distributed to customers. Plastic over-wrap is produced on-site from the polyethylene and extruding plant. Polyethylene pellets, stored in silos, are pneumatically conveyed to the extruder. The extruder produces a polyethylene tube which is elongated by take-off nip rollers, air cooled, solidified, passed through a corona treater, and wound onto takeoff rolls. Ozone generated in the corona treating process is discharged through a horizontal vent. Once a full roll is produced, it is taken from the takeoff roll, rewound into rolls of unprinted polyethylene film, and stored in the same building until needed for printing.Flexographic printing of the polyethylene film is conducted in the flexographic printing room. The polyethylene rolls are fed into a six-color, central impression flexographic printing press and PERMIT MEMORANDUM 99-113-TV DRAFT 9 dried through the tunnel dryer to produce printed parent rolls of polyethylene film. The finished rolls are stored and transferred to locations within the facility where the product may be needed. Emissions from the plant are solvent and ink VOCs and combustion products from the catalytic oxidation incinerator and the dryer. The applicant has estimated that approximately 70% of the VOCs from the solvent and inks are captured by the recovery hood and discharged into an incinerator, and the remaining 30% of the VOCs leave the room through large openings into the main building and are ultimately discharged through the three main exhaust vents located on the roof. The incinerator temperature is monitored before and after exposure to the catalyst media and recorded daily. The inlet gas temperature shall be continuously monitored by a shutdown switch that will shut down the press should the temperature drop below 550F. To document proper operation, the permittee is required to record the before (Thermocouple T/C 1) and after (Thermocouple T/C 2) catalytic cell temperature daily.Steam and Electricity Co-generation (power plant) The facility has a power plant utilizing four boilers, identified as emission units B-1, B-2, B-3, and B-4, which co-generate most of the electrical and steam needs of the facility. They are fueled by coal and other fossil fuels. The ash residue generated from this operation is landfilled in an approved on-site landfill. Opacity of the boiler emissions is monitored continuously by the use of strip charts. Following is a description of each boiler.B-1 is primarily a natural gas-fired package boiler rated at 310 MMBTUH. It is capable of firing No. 2 fuel oil as a backup fuel. The unit co-generates steam and electricity for use on-site. It shares a common stack with boiler B-2.B-2 is primarily a pulverized coal-fired boiler rated at 440 MMBTUH. It is capable of firing natural gas and No. 2 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses an electrostatic precipitator for particulate control and shares a common stack with boiler B-1.B-3 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse for particulate control and shares a common stack with boiler B-4.B-4 is primarily a pulverized coal-fired boiler rated at 557.11 MMBTUH. It is capable of firing natural gas and No. 6 fuel oil as backup fuels. The unit co-generates steam and electricity for use on-site. It uses a baghouse for particulate control and shares a common stack with boiler B-3.Emergency Backup Power Generators The facility has two emergency backup power generators used only for emergency power in the event of a complete power loss. Otherwise they are operated only for periodic capability tests.DG-1 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM- 93152-11/20, with a diesel-fueled Catepillar engine, Serial # 24Z00499. DG-2 is a 1,200 KW, Marathon Electric, Magna One, Model # 683 FDR8126GG W, Serial # LM- 93152-11/13, with a diesel-fueled Catepillar engine, Serial # 24Z00501. PERMIT MEMORANDUM 99-113-TV DRAFT 10Coal Preparation Plant The coal preparation plant supplies the boilers with pulverized coal fuel. All emission units except the coal pile are subject to the provisions of 40 CFR, Part 60, Subpart Y, “Standards of Performance for Coal Preparation Plants.” More detail on the applicability criteria is found in the NSPS discussion of Section VIII.Coal Storage Coal fuel used in the boilers is stored in an outdoor storage pile prior to processing into pulverized coal. Solid, bituminous and sub-bituminous coal is delivered by railcar and unloaded into a below-grade receiving bin. Some coal is also received by truck and unloaded into the coal pile. A conveyor moves the coal from the receiving bin to a radial stacker. The radial stacker unloads the coal into an aboveground stockpile.Coal Processing and Conveying Equipment Coal fuel used in the boilers is stored in an outdoor storage pile (FS-1) prior to processing into pulverized coal. Solid, bituminous and sub-bituminous coal is primarily delivered by railcar and unloaded into a below-grade receiving bin. A conveyor moves the coal from the receiving bin to a radial stacker. The radial stacker unloads the coal into an aboveground stockpile. Some coal is also received by truck and unloaded directly into the coal pile. A front-end loader is then used to transfer coal from the stockpile to the grizzly feeder. A conveyor transfers the coal from the grizzly feeder to the sizer/crusher for sizing, which also separates debris such as rocks. Except for the outlet chute opening to the conveyor, the sizer/crusher is enclosed and housed in a small building. There are openings on two sides of the building for the ingoing and outgoing conveyors. From the sizer/crusher, a conveyor transfers the sized coal to the coal bunkers ahead of the coal feeders, which in turn feed the pulverizers and subsequently the boilers. The coal feeders and pulverizers are enclosed processes. Dust suppression systems are located at the railcar unloading, the grizzly feeder, and the sizer/crusher.Wastewater Treatment Plant The facility also operates its own wastewater treatment plant consisting of primary and secondary treatment stages. The majority of the solid wastewater residues are landfilled on-site.SECTION III. EQUIPMENTThe following tables list the Emission Units (EUs) at the facility that contribute to a process that generates significant emissions. The tables are categorized by Emission Unit Groups (EUGs), based on the type of emission and/or an applicable rule. The application states that the date of construction is either the approximate date the company commenced construction of the particular process, or the date of the last modification of the process for which the company obtained an air permit under laws existing at that time.EUG 1 – Subpart D Boilers EUG 1 includes boilers that are subject to 40 CFR Part 60, Subpart D, “Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971.” PERMIT MEMORANDUM 99-113-TV DRAFT 11EUG 1 – Subpart D Boilers EU Boiler Manufacturer Boiler Rating Burner Model Construct ID (MMBtu/hr) Date B-1 Zurn Industires, Inc. 310 Keystone 1975 SAOH-MJ-DAR-48 B-2 Babcock & Wilcox Company 440 BW-24089 1975 B-3 Combustion Engineering, Inc. 557.11 VU-40 1978 B-4 Riley Stoker 557.11 RX Turbofurnace 1981EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP EUG 2 includes emission units that have combustion emissions not subject to an NSPS or a NESHAP performance standard.EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP EU ID EU Name Model # Burner Burner Construction Manuf. Rating Date (MMBTUH) PM-11 Paper Machine #11 Kinedizer 27M Maxon 2 x 24 1975 PM-12 Paper Machine #12 Oven-Pak EB6 Maxon 2 x 16.5 1975 Model 400 PM-13 Paper Machine #13 Oven-Pak EB6 Maxon 2 x 16.5 1979 Model 400 PM-14 Paper Machine #14 Combustifume Maxon 2 x 24 1981 PM-15 Paper Machine #15 LV-85 Maxon 2 x 25 1992 PO-1 Printing Press Oven-Pak EB3 Maxon 2.0 1983 Tunnel Dryer PO-1 Catalytic HXC II - 400 2.0 1983 Oxidizing IncineratorEUG 2 – Combustion Sources Not Subject to NSPS or NESHAP (continued) EU EU Name/ Model Power Output Construction Date ID DG-1 Marathon Electric, Magna One 1,200 KW 1982 DG-2 Marathon Electric, Magna One 1,200 KW 1982 PERMIT MEMORANDUM 99-113-TV DRAFT 12EUG 3 – Subpart Y Coal Preparation Plant EUG 3 consists of the Coal Preparation Plant and includes all emission units subject to the provisions of 40 CFR, Part 60, Subpart Y, “Standards of Performance for Coal Preparation Plants,” which include coal processing and conveying equipment (including breakers and crushers) and coal storage systems in coal preparation plants that process more than 200 tons per day. The coal storage pile, which is not subject to this rule, is not included in this EUG.EUG 3 – Subpart Y Coal Preparation Plant EU ID EU Name Manufacturer/Model# Construct Date Railcar Unloading FEECO 1991, est. Radial Stacker FEECO 1991, est. Grizzly Feeder FEECO / Fairfield 1991, est. Coal Sizer/Crusher Gundlach / Model#56-DA-1294 1977, est. Conveyor Fort Howard (Manufactured on-site while Mill 1977, est. was owned by Fort Howard) B-2 Coal Bunkers B&W 1975, est. B-2 Coal Feeders Stock Equipment Co./ Gravimetric Feeder 1975, est. B-2 Pulverizers B&W / EL50 Ball Mill 1975, est. B-3 Coal Bunkers CE 1978, est. B-3 Coal Feeders Stock Equipment Co. / Gravimetric Feeder 1978, est. B-3 Pulverizers CE / Bowl Mill 533ARB 1978, est. B-4 Coal Bunkers Riley 1981, est. B-4 Coal Feeders Merrick / Coalometer 1981, est. B-4 Pulverizers Riley / 556 Hammer Mill 1981, est.EUG 4 – PP-1 Pulp Processing Units (Subpart S Affected/No Applicable Standards) EUG 4, PP-1 Pulp Processing Units, emits VOCs from the bleaching and pulping processes. Some of these units are affected processes under 40 CFR Part 63, Subpart S, “National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry,” but are not subject to any performance standard or other requirements at this time because of the type of bleaching agents currently used in the pulping process. The facility uses secondary wood (recycled paper) fiber and is therefore an affected facility. However, as a result of the processes and bleaching chemicals used in producing the secondary fiber pulp, there are no standards in the subpart that currently apply to the facility. Therefore, this EUG is reserved for any future Subpart S regulated units. Emissions from these units are subject to OAC 252:100-41 and are included with EUG 6. PERMIT MEMORANDUM 99-113-TV DRAFT 13EUG 4 – PP-1 Pulp Processing Units (Subpart S Affected/No Applicable Standards) EU Name Construction Date Pulpers (not system specific) 1977, 1979, 1981, 1983, 1992, est. Unbleached Stock Blend Tanks 1977 & 1983, est. Screens 1977, 1979, 1981, 1983, & 1992, est. Unbleached Washers 1977, est. Flotation Cell Washers 1977, 1979, 1981, 1983, & 1992, est. Unbleached Thickener 1977 & 1992, est. Bleached Washers 1977, 1981, 1983, 1992, est. Storage (not system specific) 1977, 1979, 1981, 1983, 1992 est. Bleach Towers 1977, 1979, 1981, 1983, 1992, est. Thickeners 1979, 1981, 1983, est. Unbleached Stock Presses 1992, est. Mixers 1992, est. Cleaners 1992, est.EUG 5 – Subpart KK Flexographic Printing EUG 5 includes emission units that have flexographic printing presses and auxiliary equipment subject to 40 CFR Part 63, Subpart KK, “National Emission Standards for the Printing and Publishing Industry.”EUG 5 – Subpart KK Flexographic Printing EU EU Name Manufacturer/Model No. Construct ID Date PO-1 Flexographic Polyethylene Printer Paper Converting Machine Company June, 1984 (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724 1983 Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 PO-1 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6726 1997EUG 6 – VOC Sources Subject to OAC 252:100-41 EUG 6 includes emission units that are Subject to OAC 252:100-41. They include units that are part of the paper making process, having VOC, HAP or TAC emissions and not subject to Subpart S (PP-1 Pulp Processing Units are affected but not subject to standards at this time), and units not subject to a NESHAP performance standard.EUG 6 – VOC Sources Subject to OAC 252:100-41 EU ID EU Name Manufacturer/Model/Serial # Construct Date PERMIT MEMORANDUM 99-113-TV DRAFT 14EU ID EU Name Manufacturer/Model/Serial # Construct Date PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning NA 1975 PM-11, PM-12, PM-13, PM-14 PM-15 Solvent Cleaning NA 1992 PO-1 Flexographic Polyethylene Gloucester Engineering, Model #264-001, 1983 Extruder Serial #264-28879-001 Corona Treater Enercon, Model ASO12V-160 June, 1984 Corona Treater Enercon, Model ASO41V-300 June, 1984 w/Decomposer Model 03X-16 Flexo-plate making Anderson-Vreeland June, 1984 PO-1 Flexographic Polyethylene Paper Converting Machine Company June, 1984 Printer (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724 1983 Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6726 1997EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP EUG 7 includes emissions units that have non-combustion, particulate process emissions, not subject to an NSPS or a NESHAP performance standard.EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP EU ID EU Name Manufacturer/Serial # Construct DateFS 1 Coal Pile NA 1975 PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992SECTION IV. EMISSIONS PERMIT MEMORANDUM 99-113-TV DRAFT 15Based on the facility’s 1998 turnaround document, the facility processed approximately 324,460 tons of paper products and 480,090 tons of coal that year. Product usage was 1,787,370 pounds of ink and ink solvent, 72,960 gallons of Paper Machine solvent, and 7,075 tons of bleaching/de-inking additives. The following tables illustrate the calculated potential emissions for each emissions unit identified in the application, as re-grouped into the following Emission Unit Groups.EUG 1 – Subpart D Boilers The applicant submitted the following emissions calculations for the boilers, based on either AP-42 factors, or emissions testing as footnoted. However, some of the Title V permit limits are established by existing permit limits, which were based on modeling to establish compliance with existing air quality standards at the time of permit issuance.Stack tests for Boiler B-2 burning High Btu coal were conducted on January 7, 8, and 9, 2003. Stack tests for Boiler B-2 burning Low Btu coal were conducted on May 16 and 17, 2003. Stack tests for Boiler B-3 burning Powder River Basin coal were conducted on May 20 and 21, 2003. Stack tests for Boiler B-4 burning Powder River Basin coal were conducted on April 15 and 16, 2003. The results of these tests are contained in reports prepared by Western Environmental Services and Testing, Inc., received by AQD on November 6, 2003, with the applicant’s response to an NOD dated June 12, 2003.EUG 1 – Subpart D Boilers EU Boiler Firing Controls Low Fuels ID Rating Configuration NOX (MMBtu/hr) B-1 310 Forced Draft Package None No Gas/Oil B-2 440 Wall Fired Electrostatic Precipitator No Coal/Gas/Oil B-3 557.11 Tilting Tangential Baghouse Filter No Coal/Gas/Oil B-4 557.11 Wall Fired, Opposing Walls Baghouse Filter Yes Coal/Gas/Oil EUG 1 – Subpart D Boilers (continued) COAL NATURAL GAS FUEL OIL B-1 Emissions Emissions Emissions Emissions Emissions Emissions 310 MMBTUH Factor (TPY) Factor (TPY) Factor (TPY) PM NA NA 7.6 lbs (4) 12.38 (1) 0.0033 lbs (5) 38.41 (1) MMCF gal (3) (1) (6) (1) NOX NA NA 0.115 lbs 187.38 0.024 lbs 279.32 MMBTU gal (4) (1) (6) (1) SO2 NA NA 0.6 lbs 0.98 0.0785 lbs 913.61 MMCF gal VOC NA NA 5.5 lbs (4) 8.96 (1) 0.0002 lbs (7) 2.33 (1) MMCF gal CO NA NA 84 lbs (4) 136.87 (1) 0.005 lbs (6) 58.19 (1) MMCF gal HCL NA NA NA NA NA NAH2SO4 NA NA NA NA NA NA HF NA NA NA NA NA NA EUG 1 – Subpart D Boilers (continued) COAL NATURAL GAS FUEL OIL B-2 Emissions Emissions Emissions Emissions Emissions Emissions PERMIT MEMORANDUM 99-113-TV DRAFT 16440 MMBTUH Factor (TPY) Factor (TPY) Factor (TPY) PM (Hi Btu 0.032 lbs (3) 74.00 (1) 7.6 lbs (4), (14) 0.18 (1) 0.0033 lbs (5, 14) 0.55 (1) Coal) (19) MMBtu MMCF gal PM (Lo Btu 0.027 lbs (3) 62.44 (1) Coal) (19) MMBtu (3) (1) (15) (6) (1) NOX (Hi Btu 0.43 lbs 994.44 190 lbs 366.17 0.024 lbs 396.45 Coal) (19) MMBtu MMCF gal (3) (1) NOX (Lo Btu 0.319 lbs 737.73 Coal) (19) MMBtu (3) (1) (4) (1) (6) (1) SO2 (Hi Btu 0.644 lbs 1,489.34 0.6 lbs 1.39 0.0785 lbs 1,296.73 Coal) (19) MMBtu MMCF gal (3) (1) SO2 (Lo Btu 0.267 lbs 617.48 Coal) (19) MMBtu VOC (Hi Btu 0.075 lbs (3) 173.45 (1) 5.5 lbs (1), (4) 12.72 (1) 0.0002 lbs (7) 3.30 (1) Coal) (19) MMBtu MMCF gal VOC (Lo 0.002 lbs (3) 4.63 (1) Btu Coal) MMBtu CO (Hi Btu 0.022 lbs (3) 50.88 (1) 84 lbs (1), (15) 194.26 (1) 0.005 lbs (6) 82.59 (1) Coal) (19) MMBtu MMCF gal CO (Lo Btu 0.004 lbs (3) 9.25 (1) Coal) (19) MMBtu HCL (Hi Btu 0.012 lbs (3) 27.75 (1) NA NA NA NA Coal) (19) MMBtu HCL (Lo Btu 0.003 lbs (3) 6.94 (1) Coal) (19) MMBtu (3) (1) H2SO4 (Hi 0.001 lbs 2.31 NA NA NA NA Btu Coal) (19) MMBtu (3) (1) H2SO4 (Lo 0.017 lbs 39.32 Btu Coal) (19) MMBtu HF (Hi Btu 0.006 lbs (3) 13.88 (1) NA NA NA NA Coal) (19) MMBtu HF (Lo Btu 0.001 lbs (3) 2.31 (1) Coal) (19) MMBtuEUG 1 – Subpart D Boilers (continued) COAL NATURAL GAS FUEL OIL B-3 Emissions Emissions Emissions Emissions Emissions Emissions 557 MMBTUH Factor (TPY) Factor (TPY) Factor (TPY) PERMIT MEMORANDUM 99-113-TV DRAFT 17PM 0.005 lbs (3) 14.64 (1) 7.6 lbs (4), (16) 0.09 (1) 0.0108 lbs (16, 17) 0.84 (1) MMBtu MMCF gal (3) (1) (15) (2) (6) (1) NOX 0.224 lbs 655.78 170 lbs 456.22 0.032 lbs 624.55 MMBtu MMCF gal(3) (1) (4) (1) (6) (2) SO2 0.403 lbs 1,179.82 0.6 lbs 1.76 0.10362 lbs 1,853.85 MMBtu MMCF gal VOC 0.001 lbs (3) 2.93 (1) 5.5 lbs (4) 16.10 (1) 0.00076 lbs (7) 14.83 (1) MMBtu MMCF gal CO 0.003 lbs (3) 8.78 (1) 24 lbs (15) 70.26 (1) 0.005 lbs (6) 97.59 (1) MMBtu MMCF gal HCL 0.03 lbs (3) 87.83 (1) NA NA NA NA MMBtu (3) (1) H2SO4 0.003 lbs 8.78 NA NA NA NA MMBtu HF 0.001 lbs (3) 2.93 (1) NA NA NA NA MMBtu B-4 Emissions Emissions Emissions Emissions Emissions Emissions 557 MMBTUH Factor (TPY) Factor (TPY) Factor (TPY) PM 0.015 lbs (3) 43.91 (1) 7.6 lbs (4), (18) 0.18 (1) 0.0108 lbs (17, 18) 1.68 (1) MMBtu MMCF gal (3) (1) (15) (6) (2) NOX 0.339 lbs 992.45 190 lbs 463.54 0.04 lbs 715.63 MMBtu MMCF gal (3) (1) (4) (1) (6) SO2 0.631 lbs 1,847.31 0.6 lbs 1.76 0.10362 lbs 1,685.32 MMBtu MMCF gal VOC 0.001 lbs (3) 2.93 (1) 5.5 lbs (4) 13.42 0.00076 lbs (7) 14.83 (1) MMBtu MMCF gal CO 0.012 lbs (3) 35.13 (1) 84 lbs (15) 204.93 0.005 lbs (6) 81.32 MMBtu MMCF gal HCL 0.033 lbs (3) 96.61 (1) NA NA NA NA MMBtu (3) (1) H2SO4 0.004lbs 11.71 NA NA NA NA MMBtu HF 0.001 lbs (3) 2.93 (1) NA NA NA NA MMBtu (1) - 20% contingency added (2) - 10% contingency added (3) - Stack tests conducted in June 1980 for Boiler B-1, on January 7, 8, 9, 2003, for B-2 (High Btu coal), May 16 & 17, 2003, for B-2 (Low Btu coal), May 20 & 21, 2003, for B-3, and April 15 & 16, 2003, for B-4 (4) - AP-42, Table 1.4-2 (7/98) (5) - AP-42, Tables 1.3-1, 1.3-2 (9/98) (6) - AP-42, Table 1.3-1 (9/98), S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil (7) - AP-42, Table 1.3-3 (9/98) (14) - 99% efficiency for ESP (15) - AP-42, Table 1.4-1 (7/98) (16) - 99.60% efficiency for Baghouse (17) - AP-42, Tables 1.3-1 and 1.3-2 (9/98), S content of 0.66% (fuel supplier) (18) - 99.20% efficiency for Baghouse (19) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous EUG 1 - PTE SummaryPM NOX SO2 VOC CO HCL H2SO4 HF B-1 38.41 (3) 279.32 (3) 913.61 (3) 8.96 (2) 136.87 (2) NA NA NA B-2 74.00 (1) 994.44 (1) 1,489.34 (1) 173.45(1) 194.26 (2) 27.75 (1) 39.32 (1) 13.88 (1) PERMIT MEMORANDUM 99-113-TV DRAFT 18B-3 14.64 (1) 655.78 (1) 1,853.85 (3) 16.10 (2) 97.59 (3) 87.73 (1) 8.78 (1) 2.93 (1) B-4 43.91 (1) 992.45 (1) 1,847.31 (1) 14.83 (3) 204.93 (2) 96.61 (1) 11.71 (1) 2.93 (1) Total 170.96 2,921.99 6,104.11 213.34 633.65 212.09 59.81 19.74 (1) – Coal fired emissions (2) – Natural gas fired emissions (3) – Fuel oil fired emissionsEUG 2 – Combustion Sources Not Subject to NSPS or NESHAPEU ID Rating Firing Controls Fuels (MMBtu/hr) Configuration PM-11 2 x 24 NA None Gas/Propane PM-12 2 x 16.5 NA None Gas/Propane PM-13 2 x 16.5 NA None Gas/Propane PM-14 2 x 24 NA None Gas/Oil PM-15 2 x 25 NA None Gas/Oil PO-1 Catalytic Oxidizer 2.0 NA None VOCs/GasThe applicant submitted the following emissions calculations for the paper machines, based on AP-42 emissions factors as footnoted, burner ratings, and fuel heating values. However, as noted earlier for the boilers, some of the Title V permit limits are established by existing permit limits, which were based on modeling to establish compliance with existing air quality standards at the time of permit issuance.Emissions calculations for firing the paper machines on LPG, a backup fuel for PM-12, were calculated by the same method. Since the LPG emissions do not exceed the limits set by natural gas and fuel oil, the results of these calculations are not presented. The gas/oil burners were replaced with gas only burners in 1999, 2003, and 2002, respectively. The rating for the PM-12 burner is a correction from the rating of 13.0 MMBTUH submitted in the Title V application.Emissions calculations for the Dryer and Incinerator (from natural gas combustion) were based on AP-42 emissions factors, burner ratings, and fuel heating values. These calculations are shown below as presented on pages 161 and 162 of the Title V application. As described in the memorandum of Permit No. 83-062-O (PSD), issued for the PO-1 Polyethylene Extruder and Printer, “the Tunnel Dryer and TEC Systems Catalytic Oxidation Incinerator, Model No. HXC II - 400 destroys 96.8% (per recent testing) of the collected VOC emissions while consuming on average 9.97 MMCF/year (1,138 ft3/hr) of commercial natural gas. The unit is capable of consuming up to 17.52 MMCF/yr (2,000 ft3/hr) at maximum operation capacity. Criteria pollutant emissions are based on AP-42 (1/95), Tables 1.4-1, 1.4-2, and 1.4-3, using the Commercial Boilers (0.3 - <10 X 106 BTU/hr) emission rates in that, at the maximum operating rates, this unit is capable of delivering 2.0 X 106 BTU/hr. All emissions of criteria pollutants are below de minimis levels from this source.” Note in the VOC calculation that because the Incinerator has 96.8 % VOC destruction efficiency, only 3.2% of the VOCs produced from combustion are not destroyed and therefore emitted.EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP PERMIT MEMORANDUM 99-113-TV DRAFT 19NATURAL GAS FUEL OIL PM-11 Emissions Emissions Emissions Emissions 24 MMBTUH x 2 Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 1.92 (1) 0.0033 lbs (5) 5.95 (1) MMCF gal (15) (1) (6) (1) NOX 100 lbs 25.23 0.02 lbs 36.04 MMCF gal (4) (1) (6) (1) SO2 0.6 lbs 0.15 0.0785 lbs 141.46 MMCF gal VOC 5.5 lbs (4) 1.39 (1) 0.0002 lbs (7) 0.36 (1) MMCF gal CO 84 lbs (4) 21.19 (1) 0.005 lbs (6) 9.01 (1) MMCF gal PM-12 Emissions Emissions Emissions Emissions 16.5 MMBTUH x 2 Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 1.32 (1) 0.0033 lbs (5) 3.22 (1) MMCF gal (15) (1) (6) (1) NOX 100 lbs 17.35 0.02 lbs 24.78 MMCF gal (4) (1) (6) (1) SO2 0.6 lbs 0.10 0.0785 lbs 76.62 MMCF gal VOC 5.5 lbs (4) 0.95 (1) 0.0002 lbs (7) 0.25 (1) MMCF gal CO 84 lbs (4) 14.57 (1) 0.005 lbs (6) 4.88 (1) MMCF gal PM-13 Emissions Emissions Emissions Emissions 16.5 MMBTUH x 2 Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 1.32 (1) 0.0033 lbs (5) 4.34 (1) MMCF gal (15) (1) (2) (6) (1) NOX 100 lbs 17.35 18.40 0.02 lbs 24.78 MMCF gal (4) (1) (6) (1) SO2 0.6 lbs 0.10 0.0785 lbs 103.14 MMCF gal VOC 5.5 lbs (4) 0.95 (1) 0.0002 lbs (7) 0.25 (1) MMCF gal CO 84 lbs (4) 14.57 (1) 0.005 lbs (6) 6.57 (1) MMCF galEUG 2 – Combustion Sources Not Subject to NSPS or NESHAP (cont’d) NATURAL GAS FUEL OIL PM-14 Emissions Emissions Emissions Emissions 24 MMBTUH x 2 Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 1.60 0.0033 lbs (5) 4.96 MMCF gal (15) (2) (6) (1) NOX 100 lbs 23.13 0.02 lbs 36.04 MMCF gal PERMIT MEMORANDUM 99-113-TV DRAFT 20(4) (1) (6) SO2 0.6 lbs 0.15 0.0785 lbs 117.88 MMCF gal VOC 5.5 lbs (4) 1.16 0.0002 lbs (7) 0.36 (1) MMCF gal CO 84 lbs (4) 17.66 0.005 lbs (6) 7.51 MMCF gal PM-15 Emissions Emissions Emissions Emissions 25 MMBTUH x 2 Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 2.00 (1) NA NA MMCF (15) (1) NOX 100 lbs 26.28 NA NA MMCF (4) (1) SO2 0.6 lbs 0.16 NA NA MMCF VOC 5.5 lbs (4) 1.21 NA NA MMCF CO 84 lbs (4) 18.40 NA NA MMCF PO-1 Emissions Emissions Emissions Emissions 2.0 MMBTUH Factor (TPY) Factor (TPY) PM 7.6 lbs (4) 0.07 NA NA MMCF (15) NOX 100 lbs 0.88 NA NA MMCF (4) SO2 0.6 lbs 0.01 NA NA MMCF VOC 5.5 lbs (4) 1.89 NA NA MMCF CO 84 lbs (4) 0.74 NA NA MMCF (1) - 20% contingency added; (2) - 10% contingency added; (4) - AP-42, Table 1.4-2 (7/98); (5) - AP-42, Tables 1.3-1, 1.3-2 (9/98); (6) - AP-42, Table 1.3-1 (9/98); S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil; (7) - AP-42, Table 1.3-3 (9/98); (15) - AP-42, Table 1.4-1 (7/98)EUG 2 - PTE SummaryPM NOX SO2 VOC CO PM-11 5.95 (1) 36.04 (1) 141.46 (1) 1.39 (2) 21.19 (2) PM-12 3.22 (1) 24.78 (1) 76.62 (1) 0.95 (2) 14.57 (2) PM-13 4.34 (1) 24.78 (1) 103.14 (1) 0.95 (2) 14.57 (2) PM-14 4.96 (1) 36.04 (1) 117.88 (1) 1.16 (2) 17.66 (2) PM-15 2.00 (2) 26.28 (2) 0.16 (2) 1.21 (2) 18.40 (2) PO-1 0.07 (2) 0.88 (2) 0.01 (2) 1.89 (2) (3) 0.74 (2) (1) - Fuel oil fired emissions (2) - Natural gas fired emissions (3) – Includes solvent cleaning VOCs not destroyed by catalytic incinerator.EUG 3 – Subpart Y Coal Preparation PlantThe applicant submitted the following methodology for calculating emissions from the coal handling processes. PERMIT MEMORANDUM 99-113-TV DRAFT 21To calculate emissions for operations from railcar unloading to the grizzly feeder, an emission factor from AP-42, 13.2.4 Aggregate Handling and Storage Piles, was used from the Mineral Products Industry category. This factor includes both batch and continuous drop operations, both of which are utilized for this coal preparation plant. It includes dust emissions from several distinct source activities within the storage cycle:1. Loading of aggregate onto storage piles (batch or continuous drop operations). 2. Equipment traffic in storage area. 3. Wind erosion of pile surfaces and ground areas around piles. 4. Load-out of aggregate for shipment or for return to the process stream (batch or continuous drop operations).Emissions from railcar unloading, the radial stacker, and filling the grizzly feeder with the front- end loader were calculated with the use of this emission factor. Inherent to the emission factor derivation and resulting emission calculations for this methodology are coal pile emissions. Since the coal pile, FS-1, is not included in this EUG, this results in a conservatively higher estimate for the emission units that are included in this EUG. However, even though open storage piles are exempt from Subpart Y, there are still applicable permit limitations and controls. Coal pile emissions, FS-1, were calculated and submitted in the original permit application using a different methodology. That methodology is detailed under the applicable discussion of emission calculations for EUG 7 – Non-Combustion PM Sources Not Subject to NSPS, to which the coal pile belongs. The results of the calculations for Subpart Y applicable units are illustrated by the following methodology and summarized in the table below.From AP-42, Section 13.2.4: E (lbs/ton) = k*0.0032 * (U/5)1.3 / (M/2)1.4, where: k = 0.35 for PM10 U = wind speed (15 mph, worst case value from Ranges of Source Conditions) M = moisture content (0.25 %, worst case value from Ranges of Source Conditions)Applying the above factors, E = 0.0859 lbs PM/ton of coal.Coal handling factors for crushing and conveying were taken from “Compilation of Past Practices and Interpretations by EPA Region VIII on Air Quality Review of Surface Mining Operations.” These factors are also consistent with those used in an Oklahoma power plant Title V permit. A factor of 0.2 lbs PM/ton of coal was used for crushing, and a factor of 0.02 lbs PM/ton coal was used both for conveying and the conveying/filling process into the bunkers. No factors were compiled for the coal feeders or the pulverizers. These are closed processes, and are expected to have no visible emissions. However, they are subject to a 20% opacity limit by regulation.Applying the above emission factors to a throughput of 519,362 tons of coal in 2003 yields the following table. PERMIT MEMORANDUM 99-113-TV DRAFT 22EUG 3 – Subpart Y Coal Preparation Plant EU Name Particulate Matter Throughput PM Emissions Emission Factors (TPY) (TPY) (lbs/ton coal) Railcar Unloading Radial Stacker 0.0859 519,362 22.31 Grizzly Feeder Coal Sizer/Crusher 0.2 519,362 51.94 Conveying 0.02 519,362 5.19 Coal Bunkers 0.02 519,362 5.19 Coal Feeders Closed Process Pulverizers No emissionsConcerning the building housing the coal sizer/crusher, there are openings on two sides of the building for the ingoing and outgoing conveyors. Except for the outlet chute opening to the conveyor, the Sizer/Crusher is enclosed. Based on this and visual observation, the applicant feels it is apparent that Sizer/Crusher emissions would not exceed Unloading/Stacker/Feeder emissions. Regardless, an emission calculation for the crusher has been included in the EUG 3 emissions table above. The applicant further believes that the emission rate in the table above for the Sizer/Crusher does not seem practical when compared to the emission rate from the Unloading/Stacker/Feeder category directly above it. The applicant found no other factor by which to calculate Sizer/Crusher emissions and has requested that AQD consider this inconsistency during permit development. The only limit placed in the permit at this time by AQD is opacity.EUG 4 – PP-1 Pulp Processing Units This EUG is reserved for future Subpart S applicable units. HAP/TAC emissions calculations are included in EUG 6 – VOC Sources Subject to OAC 252:100-41EUG 5 – Subpart KK Flexographic PrintingPrinting Presses Emissions of HAPS are limited by Subpart KK to 400 kilograms per month. In addition to restrictions on HAP emissions, these units have a large amount of VOC emissions. Non-HAP TAC emissions are subject to the requirements of OAC 252:100-41. VOC emissions for the printers are illustrated in the discussion of emissions for EUG 6, VOC Sources Subject to OAC 252:100-41, and are not repeated here.EUG 6 – VOC Sources Subject to OAC 252:100-41 Emissions units not subject to a NESHAP and subject to OAC 252:100-41. PERMIT MEMORANDUM 99-113-TV DRAFT 23EUG 6 – VOC Sources Subject to OAC 252:100-41 EU ID EU Name Manufacturer/Model/Serial # Construct Date PP-1 Pulp Processing Units Components listed in EUG 4 1977-1992 PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning NA 1975 PM-11, PM-12, PM-13, PM-14 PM-15 Solvent Cleaning NA 1992 PO-1 Flexographic Polyethylene Gloucester Engineering, Model #264- 1983 Extruder 001, Serial #264-28879-001 Corona Treater Enercon, Model ASO12V-160 June, 1984 Corona Treater Enercon, Model ASO41V-300 June, 1984 w/Decomposer Model 03X-16 Flexo-plate making Anderson-Vreeland June, 1984 Flexographic Polyethylene Paper Converting Machine Company June, 1984 Printer (PCMC), Model No. 6795, 6-color w/vapor collection hood and tunnel dryer FP-1 Flexographic Paper Printers (six) Flexo 21-182 – PCMC/ Model No. 6724 1983 Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6726 1997PP-1 Pulp Processing Units The following discussion was prepared by the applicant and transposed here with minor editing.Emissions were measured from Pulping System by The National Council for Air and Stream Improvement (NCASI) and overall emissions factors developed for each pollutant emitted from the systems. The following discussion of the derivation of emissions was taken from the applicant’s submittal dated May 24, 2004, in response to AQD’s Notice Of Deficiency dated May 10, 2004, with some editorial changes by AQD:Fort James Operating Company’s Muskogee Mill (“FJOC” or “the mill”) was selected by NCASI and the forest products industry leadership to participate in a comprehensive emissions testing program. NCASI is the primary research arm of the pulp and paper industry and worked closely with the United States Environmental Protection Agency (“USEPA”) to develop a sampling program to gather information on emissions of Hazardous Air Pollutants (“HAPs”) that would support the development of Maximum Achievable Control Technology (“MACT”) PERMIT MEMORANDUM 99-113-TV DRAFT 24 standards for, in addition to others, recycled fiber pulping and de-inking mills. As a side note concerning HAPs, each HAP is also an Oklahoma Department of Environmental Quality (ODEQ) Toxic Air Contaminant (TAC).The primary goal of the program was to characterize the emissions of volatile organic HAPs from various processes to determine if these emissions could be related to key process variables. A secondary goal was to obtain emissions data that could be used to prepare Title V operating permit applications and to improve the accuracy of annual release estimates required by SARA 313.Initiated in 1994, the sampling program consisted of two phases. In phase I, approximately 140 process liquid samples were collected from 33 mills. Based on industry experience and working closely with USEPA, NCASI developed a list of nearly 100 HAP compounds that the liquid samples would be analyzed for, with a target detection limit of 1 mg/L. The results from the analysis of these samples and information collected about the process units were then used as a basis for selection of eleven mills at which full-scale studies were conducted. The eleven mills were selected on the three principles below, and FJOC met each of the criteria.1. The selected mills and process units were to be representative of similar facilities in the industry. Since one of the goals of phase I was the identification of compounds that had a reasonable likelihood of being detected in process vent gases, it was necessary to collect samples from mills that used processes and additives that were typical of the industry. 2. The facilities chosen were to include processes targeted by USEPA in 1994 for potential MACT III regulations, which included de-inking. 3. For each targeted mill process, major variables possibly affecting emissions were to be considered. Within recovered fiber pulping, de-inked and non-de-inked pulping were included. Within the category of paper production, recovered fiber tissue and towel were included.PHASE I In phase I, the following six process liquid samples were collected for the screening study analysis at the pulp processing facility: Test Area 1 unbleached washer filtrate, bleached washer filtrate, Test Area 2 unbleached washer filtrate, bleached washer filtrate, Paper Machine No. 12’s (PM-12) white water, and Paper Machine No. 14’s (PM-14) white water. The screening liquid sample points can be located on the simplified flow diagram below. PERMIT MEMORANDUM 99-113-TV DRAFT 25Deinking Unbleached Bleached Washers Bleaching Washers PM-12Recovered Fiber Deinking Unbleached Bleached Bleaching Washers Washers PM-14Other Other Deinking Paper Units MachinesLEGENDStock Liquid Sample PointPHASE II Emissions from process vents were measured from the Pulp Processing Test Area 1 by NCASI. Emissions measurements were taken at the Unbleached Disc Thickener Vent, the Unbleached Washers, the Bleached Washers, the Flotation Cell Vacuum System Device Vent No. 2, and the Stock Blend Tank Vent. Test Area 2 were taken at the No. 1 Bleach Tower Vent, the Pressurized Deinking Modules Rejects Vent, the Unbleached Press Vent No. 1, the No. 2 Bleach Tower Vent, and the Thickener Vent.There were generally three stack test results on each source that were averaged according to prescribed calculation protocols (note however that, if for a source, all the runs for a compound gave emission rates below the detection limit, the average emission would be reported as ND (not detected) at the detection limit). The vent gas concentrations were multiplied by the measured vent gas flow rates to determine the source emission rates (lb/hr). The mass emission rates for individual compounds were calculated by using the molecular weights of the specific compound. The calculated emission rates were then normalized by dividing the emission rate by the System production/throughput rate in short tons (T) to obtain the final results (lb/T).Using the distributive property of mathematics, the emission rates for each source can be added together then multiplied by the system production rate yielding the same value as each emission rate being multiplied by the system production rate individually. Using Test Area 1 for example:(#01)x + (#2D)x + (#4B)x + (#05)x + (#06)x = x (#01 + #2D + #4B + #05 + #06) PERMIT MEMORANDUM 99-113-TV DRAFT 26 where x is the system production rate at the time of testing.NCASI generally states in its report that, in some cases, not all of the vents from a process unit were tested. The emissions for untested vents were estimated from similar tested vents. For example, if there were three roof vents, and only one of those vents was tested, and using a production rate of 300 tons per day (TPD) during the testing, then 100 TPD was used in the emission calculation for the one tested vent to account for the emissions from the other two similar vents.The Pulp Processing emissions factors were used to estimate total TAC/HAP emissions for all pulping systems. This is reasonable since all systems use similar processes and raw materials to produce similar products. This approach should provide the best available emissions estimates for any existing system. Each System in Pulp Processing uses the same recovered fiber stock, and virtually the same additives and equipment to produce the same product. That is to say, each system uses a similar raw material and a similar process to produce a similar product. This assumption and methodology is somewhat analogous to using an AP-42 emission factor for a category of gas boilers that are similar in heat input rating, size and design. The primary difference in the Systems lies in the bleaching agent and/or sequence. Emissions factors for the systems were developed by applying the production rate-normalized emission factors from the two areas tested.During the year 2004, the mill has been using the same bleaching agents except that more of one bleaching agent with an additive was used whereas less of another bleaching agent was used. According to the manufacturers of the additive, bleaching emissions would be similar. “Although there are some differences in the mode of chemical attack, the byproducts, such as methanol, acetic acid, and quinone structures, are associated with both bleaching species.” The applicant therefore believes that emissions using the new additive are similar to emissions prior to using the additive.The discussion above summarized how HAP emission factors for two types of bleaching were tested by NCASI. When the emission factors were selected to estimate potential-to-emit (PTE) emissions for the mill’s Title V application, the higher factors were selected and applied to the maximum expected production rates for the pulping system. This method more-than-likely over estimates emissions, but is the most conservative method, and would in essence allow a safety margin to bleach with either type of bleach, yet have the most conservative PTE already estimated. The air modeling for toxics was performed at these conservative emission estimates.The PTE for all the Pulp Processing is estimated in the table below. This is also the table submitted (in its latest revision) for the Title V permit application, and is the applicant’s request for establishing a permit limit.EUG 6 – PP-1 Pulp Processing Emissions Units PERMIT MEMORANDUM 99-113-TV DRAFT 27Emissions Emissions Air Toxic CAS # TPY lbs/hr 1,2-dimethoxyethane 110714 0.05 0.01 Acetaldehyde 75070 12.16 2.78 Biphenyl 92524 20.09 4.59 Chloroform 67663 39.61 9.04 Formaldehyde 50000 0.00 0.00 Limonene 5989275 0.04 0.009 Methanol 67561 33.95 7.75 Methyl ethyl ketone 78933 0.57 0.13 Methylene chloride 74873 0.00 0.00 Naphthalene 91203 0.54 0.12 Phenol 108952 2.04 0.47 Propionaldehyde 123386 0.26 0.06 Toluene 108883 13.86 3.16 Note: Limonene has been added to this table. When the application was originated in 1998, limonene was listed as NE.Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15 The same methodology was used in calculating emission factors for the paper machines, using test data and paper production rates for the two paper machines tested to develop a facility-wide total pollutant emission factor for each pollutant emitted from the five paper machines combined. Paper Machine Nos. 11 and 13 are towel machines that use processes and raw materials to produce products similar to Paper Machine No. 12. Paper Machine Nos. 13 and 15 are Yankee dryer tissue machines that use similar processes and raw materials to produce products similar to Paper Machine No. 14. (Paper Machine No. 13 is referred to as a “swing machine”, i.e., it can produce towel or tissue.)Emissions were measured from Paper Machine Nos. 12 and 14 by NCASI and overall emissions factors developed by NCASI for each pollutant emitted from the systems. Emissions measurements for PM-12 were taken at the Fourdrinier Vent, the Fan Pump Silo Vent, the Vacuum Systems Vent, the After Dryer Vent No. 1, the Yankee Dryer Vent, and the After Dryer Vent No. 2. Emissions measurements for PM-14 were taken at the Fan Pump Silo Vent, the Yankee Wet-Side Dryer, the Yankee Dry-Side Dryer, the Vacuum Systems Vent, and the Wet End Roof Vents.As described earlier, there were generally three stack test results on each source that were averaged, emission rates below the detection limit were be reported as ND. The vent gas concentrations were multiplied by the measured vent gas flow rates to determine the source emission rates (lb/hr). The mass emission rates for individual compounds were calculated by using the molecular weights of the specific compound. The calculated emission rates were then normalized by dividing the emission rate by the paper machine production/throughput rate in short tons (T) to obtain the final results (lb/T). By the same analogy as before, using the same mathematical relationship and assumptions for allocating emissions from untested vents, emission rates for each pollutant were derived. Using PM-12 as an example: PERMIT MEMORANDUM 99-113-TV DRAFT 28(#12)x + (#13)x + (#14)x + (#15)x + (#16)x + (#17)x = x(#12 + #13 + #14 + #15 + #16 + #17) where x is the paper machine production rate at the time of testing.The paper machine emissions factors were used to estimate TAC/HAP emissions not only for PM-12 and PM-14, but also PM-11, PM-13, and PM-15. Each paper machine uses finished stock from Pulp Processing, and virtually the same additives and equipment to produce the same product. That is to say, each paper machine uses a similar raw material and a similar process to produce a similar product. And, according to NCASI Technical Bulletin No. 740, “Factors such as furnish and product type did not significantly affect the paper machine HAP emissions.” Using PM-12 and PM-14 emission factors for the other paper machines is no different for instance, (yet probably better because it is mill-specific data) than using an AP-42 emission factor for a gas boiler that is similar to one that you have.Furthermore, each paper machine is regarded in the paper industry as a tissue machine, and tissue is generally regarded as towel (paper towels) and tissue. Each paper machine uses a Yankee dryer to perform the bulk of the machine’s drying, yet PM-11, PM-12, and PM-13 also use after-dryers to dry the heavier towel sheet.The table above illustrates HAP emission factors for unbleached (PM-12) and bleached (PM-14) tissue products. When the emission factors were selected to estimate potential-to-emit (PTE) emissions for the mill’s Title V application, the higher of the PM-12 or PM-14 factor was selected and applied to the maximum expected production rate for PM-11, PM-12, PM-13, PM- 14, and PM-15. This method more than likely over estimates emissions for each paper machine, but it is the most conservative method, and would in essence allow a given paper machine to produce either bleached or unbleached product, yet have the most conservative PTE already estimated. The air modeling for toxics was performed with these conservative emission estimates.The estimated combined PTE for the five paper machines is illustrated in the table below. In terms of permit limits, the applicant has requested to have one VOC/TAC/HAP limit for the five paper machines combined. Considering a total VOC/TAC/HAP limit established for all five machines combined, it would make no difference how the emissions are distributed among the individual systems. This would allow operational flexibility in shifting production from one system to another, depending on product needs. This is reasonable since all five of these systems use similar processes and raw materials to produce similar products. This approach should provide the best available emissions estimates for Paper Machines PM-11, PM-13, and PM-15.EUG 6 – Emissions From Paper Machines 11, 12, 13, 14, & 15 Emissions Emissions Air Toxic CAS # TPY Lbs/hr 1,2-dimethoxyethane 110714 8.08 1.85 Acetaldehyde 75070 26.40 6.03 Biphenyl 92524 4.04 0.92 PERMIT MEMORANDUM 99-113-TV DRAFT 29Chloroform 67663 0.01 0.00 Formaldehyde 50000 19.13 4.37 Methanol 67561 0.02 0.00 Methyl ethyl ketone 78933 0.30 0.07 Methylene chloride 74873 5.66 1.29 Naphthalene 91203 0.01 0.00 Phenol 108952 0.70 0.16 Propionaldehyde 123386 8.08 1.85 Toluene 108883 26.40 6.03Paper Machine Additives Emissions from Paper Machine Additives are emissions from Paper Machine chemicals that were not in use when the NCASI testing was performed in 1995. The emissions are primarily from paper enhancement chemicals, dyes, etc. VOC emissions are based on VOC concentrations and throughput of each chemical.On November 9, 1999, AQD received a modification to the Title V application to incorporate the use of VOC-containing enhancement chemicals, Paper Machine Additives, as they are now labeled, in the paper machines. As noted above, they were not in use when the NCASI testing was performed in 1995. Also, they were not included in the original Title V application. The emissions are primarily from paper enhancement chemicals such as softness aids, dyes, biocides, etc. At the time of the separate 1999 application, there was only one TAC component whose emission was above its category de minimis, for which the applicant has stated that its ground level concentration was well below its MAAC. The application requested that an emissions limit of 25 TPY VOC, based on a 60% release factor from these Paper Machine Additives, be incorporated into the Title V permit to allow for flexibility and potential growth.The applicant provided additional information in their August 31, 2004 (received September 1) response to an NOD. The applicant included the table below as an example of the emissions produced from use of these chemicals. The applicant has indicated that the facility can maintain compliance with the total VOC limit while maintaining compliance with the MAAC and has requested that AQD not consider the chemical names and current usages to be the same year after year, i.e., to allow for flexibility of using different products. Flexibility is needed to change chemicals and chemical usages dictated by market and customer needs. The table was used to determine 2003 emissions reported on the 2003 Air Emissions Inventory (Turnaround Document) and compared with additives used from 1999 to 2003, would show the need for flexibility. VOC emissions are based on VOC concentrations and throughput of each chemical. A 60% release factor is applied in the same way as demonstrated later for paper machine solvent emissions in SC-1. EUG 6 - 2003 VOC Emissions from Paper Machine Additives VOCs % VOC by weight Release Factor (TPY) biocide 15% 60% 0.57 biocide 74% 60% 1.55 biocide 15% 60% 3.85 biocide 15% 60% 3.42 PERMIT MEMORANDUM 99-113-TV DRAFT 30 softener 8.40% 60% 0.69 softener 4.30% 60% 0.00 softener 11.60% 60% 0.37 red dye 2.70% 60% 0.00 yellow dye 4.00% 60% 0.05 Blue dye 1 4.00% 60% 0.00 Blue dye 2 0.30% 60% 0.00 beige dye 1.70% 60% 0.00 red dye 4.00% 60% 0.00 Blue dye 10.9% 60% 0.07 yellow dye 0.00% 60% 0.00 red dye 0.00% 60% 0.00 dye brightening aid 0.40% 60% 0.00 Blue dye 1.10% 60% 0.05 10.55Again, as mentioned above, there was only one TAC in the additives application in 1999. From the current list in the table above, the TAC emissions are as follows:EUG 6 - 2003 Paper Machine Additives TAC Analysis Wt. % of TAC Above De CAS/Category/TAC TAC Emissions Minimis TPY Biocide 10 0.35 NO 6317-18-6 Cat. B NE Methylene bis (thiocyanate) 60 2.09 NO 111-77-3 Cat. C NE Diethylene glycol monomethyl ether 1 0.03 NO 67-56-1 Cat. C Methanol 0.1 0.00 NO 91-20-3 Cat. B Naphthalene 5 0.17 NO 64742-94-5 Cat. B Aromatic Solvent Biocide 5 4.04 NO 34590-94-8 Cat. C Dipropylene glycol methyl ether yellow dye 10 0.23 NO 57-13-6 Cat. C Urea blue dye 10 0.00 NO 57-13-6 Cat. C Urea blue dye 1.9 0.00 NO NA - fume or dust / copper compounds blue dye 6 0.07 NO 111-42-2 Cat. B Diethanolamine 15 0.00 NO NA - fume or dust / copper compounds Solvent Cleaning of Paper Machines PM-11, PM-12, PM-13, and PM-14 Emissions of VOCs from SC-1, solvent cleaning, are based on usage of a 100% VOC solvent to clean Paper Machine wires. This solvent is applied through spray nozzles located across a boom which stretches across the Paper Machine. Based on research from a similar de-ink facility paper machine, only 60% of the solvent applied to the machine equates to air emissions. According to the research, 20% is consumed in the reaction with the latex buildup on the wire, and 20% ends up in the water loop and eventually in the wastewater treatment plant. The 60% evaporation rate was carried over from Permit No. 91-127-O (M-1), issued for PM-15. The numbers in the tables PERMIT MEMORANDUM 99-113-TV DRAFT 31 below do not reflect permitted numbers for PM-15. Permitted emissions for PM-15 are carried over from Permit No. 91-127-O (M-1). Solvent cleaning emissions for the other machines have not been addressed in previous permits. The applicant has proposed limits in the Title V application based on similar emissions criteria and 1998 material usage projected to future demand.EUG 6 - SC-1 Solvent Cleaning of Paper Machines PM-11, PM-12, PM-13, & PM-14 Pollutant CAS # Emission Throughput TAC HAP Factor (TPY VOCs) Emissions Emissions (lbs/ton) (TPY) (TPY) Stoddard Solvent 8052413 60% 300 43.2 Aromatic Hydrocarbon Mixture > C9 64742945 60% 300 55.3 Aromatic hydrocarbon mixture > C9 64742956 60% 300 52.7 1,2,4-Trimethylbenzene 95636 60% 300 14.4 1,3,5-Trimethylbenzene 108678 60% 300 5.4 Xylene 1330207 60% 300 2.3 2.3 Naphthalene 91203 60% 300 5.8 5.8 Unspeciated VOC 60% 300 Total 179.1 8.1Solvent Cleaning of Paper Machine PM-15 As noted above, emissions for PM-15 are carried over from Permit No. 91-127-O (M-1). Those numbers are 37.57 tons per year, 12-month rolling cumulative.Polyethylene Extruder In estimating emissions from the Poly Plant extruder processes, emission factors from a 1996 article in the Journal of the Air and Waste Management Association (JAWMA) were used for linear low density polyethylene (LLDPE) blown film at a 355 oF melting temperature. The polyethylene (poly) film produced at the Poly Plant is a blown film process using 20 – 22 % LLDPE at a melting temperature of approximately 350 oF. Other emission factors associated with the JAWMA document refer to either high-density blow molding or extrusion coating. Neither of these processes matches the process at the Poly Plant.VOC and TAC/HAP emissions were calculated using the emissions factor developed in the JAWMA study in units of lbs emissions/million pounds poly extruded. These factors were then multiplied by the future potential extrusion rate in pounds/year and converted to tons/year in the following table. In 2002, the Poly Plant produced 5,020,914 pounds of poly, and in 2003, 5,358,174 pounds were produced. The future poly production rate used to calculate a potential- to-emit is estimated at 6.0 MM lbs/yr.EUG 6 – VOC/TAC/HAP/PM Emissions from Polyethylene Extruder CAS # Category Factor Film Mfg’d. Emissions (lbs/MMlb) ( (TPY) M Ml PERMIT MEMORANDUM 99-113-TV DRAFT 32 bs/ yr ) VOC - Extruder ------8.0 6.0 0.024 TAC/HAP’s Ethane 74-84-0 NS 0.02 6.0 0.00006 Ethylene 74-85-1 NS 0.01 6.0 0.00003 Propylene 115-07-1 NS 0.01 6.0 0.00003 Formaldehyde 50-00-0 A 0.09 6.0 0.00027 Acrolein 107-02-8 A 0.02 6.0 0.00006 Acetaldehyde 75-07-0 B 0.03 6.0 0.00009 Propionaldehyde 123-38-6 C 0.02 6.0 0.00006 Acetone 67-64-1 NS 0.08 6.0 0.00024 Methyl ethyl ketone 78-93-3 C 0.02 6.0 0.00006 Formic acid 64-18-6 C 0.17 6.0 0.00051 Acetic acid 64-19-7 C 0.17 6.0 0.00051 Acrylic acid 79-10-7 A 0.02 6.0 0.00006Corona Treaters The Enercon Corona Treater Station, Model ASO12V-160, generates a corona that is used to treat the polyethylene film produced at the Polyethylene Plant. This treatment allows for enhanced ink bonding to the film. Ozone is generated as a result of treating the film in this manner. The ozone from this source is vented to the atmosphere without any controls. Emissions of ozone from this vent line have been calculated to be 0.365 lbs/hr (1.599 TPY) based on manufacturer’s data that the Enercon Corona Treater Station is designed to produce 0.073 lbs/hr of ozone per KvA (kilovolt-ampere) and the maximum input of electricity is 5.0 KvA. There are no emission control devices attached to this system.A second corona treater was installed for use when the primary system is down or when there are special printing needs that call for the film to be re-treated prior to printing. It is installed on the flexographic printer with an ozone decomposer mounted downstream. The decomposer is 95% effective and reduces generated ozone to molecular oxygen. Emissions are exhausted to the atmosphere outside to the south of the building. The corona treater is seldom used and is currently present as a back-up system. The permit allows for simultaneous operation of the two corona treaters.83-062-O (PSD) Stack Source Power Emissions Ozone Input Factor Emissions Lbs/hr TPY 1 Enercon Corona Treater Model ASO12V-160 5 Kva 0.073 0.365 1.599 lbs/Kva PERMIT MEMORANDUM 99-113-TV DRAFT 332 & 3 Enercon Corona Treater Model ASO41V-300 10 Kva 0.073 0.0365 0.1599 with Decomposer Model 03X-16 lbs/KvaPlate Making Emissions for Flexo-Platemaking at the Poly Plant, PO-1, are based on the solvent component concentrations and the fact that the solvents are 100% VOC. Emissions are small because almost all of the used solvent is recycled at the Poly Plant recycle unit.EUG 6 - PO-1: Flexo-plate making Emissions Throughput VOC Emissions HAP Emissions Factor (tons VOC / yr) (TPY) (TPY) 100% VOC 1.83 1.83 0.0PO-1, FP-1, and FP-7 Flexographic Printers PO-1’s Flexographic Polyethylene Printer produces both fugitive and point source VOCs. The drying and collection hood above the Printer has a collection efficiency of only 70% which is consistent with US EPA published guidance “Control of Volatile Organic Emissions from Existing Stationary Sources – Volume VIII: Graphic Arts – Rotogravure and Flexography” (EPA-450/2-78- 033, December 1978). This document is referred to on page 8 of the ODEQ’s permit memorandum for the Poly Plant permit, Permit No. 83-062-O (PSD). Therefore, the remaining 30% are the source of the fugitive emissions from the Printer. The 70% that is collected is directed to a catalytic oxidation incinerator, installed as part of a control system for Permit No. 83-062-O PSD, which also included the polyethylene extruder and the flexographic printing press, where a destruction efficiency of 96.8% has been measured. The remaining 3.2% of the 70% collected accounts for the Printer’s point source emissions.Emission unit FP-1 consists of six flexographic printing presses. Water-base inks are used to print paper machine parent rolls to produce printed parent rolls. These printed parent rolls are then converted to both towel and napkin products. There are no stacks for these processes. At the time of the application, the average VOC concentration of the water based inks ranged from approximately 6% to 8%. A conservative 10% was used to calculate a PTE and allow for flexibility in varying ink VOC concentrations.Emission unit FP-7 is a 101.5”, four-color, in-line flexographic printing press. Water-base inks are used to print paper machine parent rolls to produce printed towel products at the end of this printer/re-winder. There are no stacks for this process. At the time of the application, the average VOC concentration of the water based inks ranged from approximately 6% to 8%. A conservative 10% was used to calculate a PTE and allow for flexibility in varying ink VOC concentrations.EUG 6 – Non-HAP VOC Sources Subject to OAC 252:100-41 Emission Throughput Control VOC HAP Factors (tons VOC /yr) Efficiency Emissions Emissions (TPY) (TPY) PERMIT MEMORANDUM 99-113-TV DRAFT 34PO-1/Flexographic Polyethylene Printer VOCs* Fugitive 30% 197.05 NA 59.12 ** 0.0 VOCs* Point 70% 197.05 96.8% 4.41 0.0 FP-1/Flexographic Paper Printer VOCs 10 % VOC 922.76 Tons No 92.28 0.0 Ink/yr Control FP-7/Flexographic Paper Printer VOCs* 0.45% 25.6 Tons No 0.1152 ** 0.0 (average) Ink /yr Control * Based on 1998 actual emissions. ** Permit limits of 99 TPY and 0.98 TPY for these units from Permit Nos. 83-062-0 (PSD) and 97-218-C are carried over for the Title V emissions limits.EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAPPaper Machines Paper fibers are released into the atmosphere via the drying, trimming, handling and slitting of the paper sheet. Emissions were calculated using stack test data from a sister mill in Rincon, Georgia. Results from the 2002 stack testing of Rincon’s #19 Paper Machine drying hood indicated 0.465 lb/hr of particulate matter generated, of which, 0.415 lb/hr was not due to burning natural gas. The emission factor was converted to units of lbs PM/ton paper produced and multiplied by a contingency factor of 2.0 to account for particulate matter emissions generated by the wet end of the paper machine.Stack test data (November 2001) from the roof vents in the building above the No. 19 paper machine was also collected at the Rincon Mill and the results of that testing were 0.875 lb/hr of particulate matter generated. This factor was also converted to units of lb PM/ton paper produced. It should be noted that emissions measured from the Rincon, Georgia Plant were reported in units of mass per unit volume. Paper throughput was not reported in the test report. Relating the emissions to throughput as an emission factor is a relationship assumed by the applicant in their estimation of emissions.The two factors were then summed for an overall combined factor. Using this combined emission factor for Muskogee’s paper machines, an estimate of particulate emissions from the processes described above and from the roof vents was calculated based upon estimated paper production used in Title V potential-to-emit calculations in the original application, resulting in total emissions as illustrated in the table below.Control Efficiency PM Emissions (TPY) PM-11 None 9.31 PERMIT MEMORANDUM 99-113-TV DRAFT 35PM-12 None 13.03 PM-13 None 11.17 PM-14 None 11.17 PM-15 None 10.29 Total 54.97FS-1 Emissions - Title V application As stated in Appendix E of the original application, emission unit FS-1 is known as fuel storage. As briefly discussed above for EUG 3 – Subpart Y Coal Preparation Plant, even though open storage piles are exempt from Subpart Y, there are still applicable permit limitations. Coal pile emissions, FS-1, were calculated and submitted in the original permit application. Solid fuels that will be used in the boilers are stored in outdoor storage piles at the mill site. FS-1 pertains to the particulate emissions resulting from pile building, wind erosion, and pile breakdown. Based on information from a 1984 report by the Electric Power Research Institute, CS 3455, the following calculation was used to determine emissions from the coal pile:E = 1.9(S/1.5)[(365-P)/235)](f/15)Where:E = emission factor (Kg per hectare per day) S = silt content of aggregate (%) P = number of days with > 0.25 mm of precipitate per year. f = percentage of time that the unobstructed wind speeds exceeds 5.4 m/s at the mean pile height.For Muskogee:S = 2.2 (AP-42 table 11.2, 3.1) P = 90 (AP-42 figure 11.2,1-1) f = 39 from the 1988 Windrose for Tulsa, OK (1 knot = .5 m/s)As a result, for every hectare of coal stored, the following was used to determine the coal dust emissions.Kg/hectare-day = 1.9(2.2/1.5)[(365-90)/235](39/15) = 8.5 The approximate square footage of the coal pile is 350,000 ft2.Converting coal pile square footage to hectares = 350,000 ft2 (0.00000929 hectare/ft2) = 3.2515 hectaresSubstituting 8.5/hectare-day (3.2515 hectares) = 27.63775 kg/dayConsequently, 27.63775 kg/day (365 days/yr)(1,000 g/kg)(1 lb/454 g) ton/2,000 lbs = 11.11 tons/yr. PERMIT MEMORANDUM 99-113-TV DRAFT 36EU ID Emissions Factor Throughput Control PM Emissions (kg/hectare-day) (hectares) Efficiency (TPY) FS-1 8.5 3.2515 None 11.11As mentioned above in the discussion of emissions for EUG 3 – Subpart Y Coal Preparation Plant, coal pile emissions were included in the calculation of emissions using AP-42, Section 13.2.4 above.Polyethylene Extruder In estimating PM emissions from the Poly Plant resin handling processes, calculation of emissions from resin storage and handling is based on an emission factor from AP-42, Table 6.6.2-1 (rev. 9/91, reformatted 1/95), Fifth Edition, for storage of dimethyl terephthalate in Poly (ethylene terephthalate) resin production processes. Using an emission factor of 0.017% and a resin usage rate of 6.0 MM lbs/yr yields PM emissions of 0.51 TPY or 0.12 lbs/hr. There is no poly recycling operation at the Poly Plant, since all scrap is sold. A small amount of trim is re-melted and returned directly to the die.CAS # Category Emission Polyethylene Emissions Factors Film (TPY) (lbs/MMlbs) (MMlbs/yr) PM – Resin Storage & 0.017 6.0 0.51 Handling PM - Extruder ------2.4 6.0 0.0072Hazardous Air Pollutants (HAPs) and Toxic Air Contaminants (TACs) The Toxic Air Contaminants (TACs) and Section 112(a) Hazardous Air Pollutants (HAPs) that are emitted from the processes were discussed in previous sections of this memorandum. Because of the length and details, those numbers are not repeated here, but may be repeated in the discussion of air dispersion modeling, where appropriate. PERMIT MEMORANDUM 99-113-TV DRAFT 37SECTION V. AIR DISPERSION MODELINGOverview – Modeling Sources Air dispersion modeling has been performed in stages over the permitting life of the facility. Although some of the more recent models were performed to demonstrate compliance with Subchapter 41, most modeling, especially the early ones, were to demonstrate compliance with other ambient standards. Two PSD permits and evaluations have been issued during the life of this plant.Since there are no PSD or NAAQS issues to be evaluated with the issuance of this permit and most of the historical modeling analyses were apparently accepted for the proposed work as evidenced by issuance of the permits, those models are not re-evaluated for this permit memorandum. Additionally, most of those modeling methods would likely be obsolete, thus contributing no value to this evaluation. Only the most recent modeling analyses, submitted with the Title V permit application, are addressed. The discussions below summarize the results of the modeling, categorized by emissions unit(s) and permit number.Evaluations of compliance with the Maximum Acceptable Ambient Concentration (MAAC) for Toxic Air Contaminants (TACs) were performed by the applicant’s consultant, Roberts/Schornick & Associates, Inc. (RSA). The RSA initial report, dated February 11, 1999, and a subsequent re-evaluation report dated March 2, 1999, (both reports included as Appendix H of the applicant’s Title V application) focus on seventeen TACs that, when emitted at hypothetical maximum levels, would exceed the annual de minimis threshold(s). These pollutants are emitted from the coal-fired boilers (B-1, B-2, B-3, and B-4), the solvent cleaning of the paper machines (SC-1), the pulp processing (PP-1), and the paper machines (PM-11, PM- 12, PM-13, PM-14, and PM-15). Ten of these TACs are emitted from the paper machines, eleven from the pulping process, seven from the solvent cleaning process, and three from the boilers. Of the ten emitted from the paper machines, three are also emitted from the solvent cleaning process. Of the eleven emitted from the pulping process, four are also emitted from the solvent cleaning process.RSA utilized several modeling runs for the full evaluation of these contaminants. For initial screening of pollutants emitted from the paper pulping and paper machines, RSA adopted results from a Screen3 model performed by the applicant in 1997. For pollutants emitted from the solvent cleaning process, RSA adopted results of an EPA ISCST2 model and a Screen model performed by Bowman Environmental Engineering (Bowman) in 1992. Both of these early models were done for applications to install an additional paper machine. ISCST3 models were performed by RSA for the final evaluations of chloroform emitted from the pulping and paper machines, model run dated January 1999, and for hydrochloric acid, sulfuric acid and hydrogen fluoride emitted from the boilers, model run dated February 1999. Chloroform, which had failed the 1997 Screen3 screen model, was demonstrated to be in compliance by the results of the 1999 ISCST3 model. The 1999 ISCST3 model run was adopted again as an analysis tool to evaluate compliance with the MAAC for an anticipated overall paper production increase of 16.32%. Hydrochloric acid, sulfuric acid and hydrogen fluoride were also demonstrated to be in compliance. Paper Pulping Processes And Paper Machines PERMIT MEMORANDUM 99-113-TV DRAFT 38The paper pulping processes and paper machines share a list of common pollutants that are generated in the bleaching processes and carried through the systems to the paper machines. The RSA report dated February 11, 1999, identifies seven TACs that, when emitted at hypothetical maximum levels from these processes, would exceed the de minimis threshold(s). RSA evaluated the total combined rates of these pollutants emitted from all five pulping processes and from the five paper machines emitted simultaneously during full operation. Emission rates in lbs/ton of production were taken from the November 15, 1996, NCASI draft report which was finalized in July 1997 with some slight differences and converted to lbs/hr based on the maximum annual production tonnage divided by 8,760 hrs/yr; therefore, they are the same in reduced form as those discussed in the emissions section of this memorandum.For the initial air dispersion screening analysis, RSA adopted the results of an existing Screen3 model run that was performed by the applicant in 1997 for an evaluation to install another paper machine that was never installed. This model used a unit emission rate of 1.0 lb/hr to obtain a groundlevel concentration (GLC) that could in turn be used as a multiplier with the individual emissions rate for each pollutant to calculate the GLCs, using the assumption that GLCs calculated by the model are linearly proportional to emission rates. The results of the first evaluation concluded that six of the seven pollutants considered would be below their respective MAAC, but chloroform would have a GLC of 132.9 μg/m3, which is above its MAAC of 97 μg/m3.Additional refined modeling was performed for this evaluation by RSA for chloroform using the EPA ISCST3 air dispersion model. Again the assumption of linearly proportionality between GLCs and emissions rates was utilized to derive a multiplier used to calculate the GLCs at varying emissions rates.Pulping System For the pulping system, there were 5 emissions points tested by NCASI for each of the two test areas. According to NCASI, the points tested represented total emissions for the areas tested. From this the applicant, in performing the 1997 Screen3 modeling, concluded that the total combined emissions of a particular pollutant from all emissions units could be modeled as if occurring from five functional areas for each test area, i.e. emitting from five combined representative stacks. With this assumption, chloroform emissions measurements taken from Test Area 1 were used to derive a representative distribution of emissions discharged through the five- stack scenario, for input in the applicant’s 1997 Screen3 model. Using the chloroform emissions factors taken from the NCASI report for Test Area 1, the applicant calculated the distribution of the chloroform emissions occurring from each of the five emissions points as a percentage of the total.An annual chloroform PTE of 35.39 ton/yr was calculated for the pulping system by multiplying the maximum annual production tonnage in ton/year by the NCASI Test Area 1 emissions factor in units of lb/ton of product. This factor is the greater of the emission factors obtained from the two areas tested by NCASI. The Test Area 2 chloroform emission factor was the lowest of the two. The maximum hourly emissions rate of 8.081 lbs/hr was calculated from the annual PTE based on 8,760 hr/yr. As noted earlier, the GLC calculated at these emissions rates exceeded the MAAC test for chloroform when using the 1997 Screen3 model run. The January 1999, ISCST3 model was executed to obtain a more refined GLC for chloroform. PERMIT MEMORANDUM 99-113-TV DRAFT 39The applicant states that the hourly maximum rate of 8.081 lbs/hr was then allocated to the five functional areas using the percentage distribution described in the preceding paragraph and that these five hourly maximum emission rates were modeled as five representative functional stacks using the ISCST3 model to obtain a GLC for chloroform. However, a review of the January 1999 ISCST3 model run input shows that the emission rates input for the five functional areas were 0.10181 for the Flotation Cells, 0.52944 for the Unbleached Press, 0.33604 for the Bleach Tower 1, 0.010206 for the Bleach Tower 2, and 0.040697 for the Unbleached Thickener, all in units of grams/sec. Either way, the numbers equate to the same rate in units of lbs/hr, thus the same resulting GLCs. When summed, these values yield a total emissions rate of 1.018 g/sec. Converted to units of lbs/hr, 1.018 g/sec equates to a total emissions rate of 8.081 lbs/hr for chloroform.The table that follows illustrates the results of the emission rate calculations. These values were assumed to be representative of the distribution of emissions of chloroform from the functional areas that include the entire pulping system. The Test Area 1 chloroform emission factor was prorated using the distribution method for the five functional areas, and applied to each functional area.Functional Area % Emissions From Assumed PTE (g/sec)/ (as noted on model run) Functional Area (lbs/hr) (% total - gr/sec) Flotation Cells (1) 0.10 (0.1036) 0.10/0.808 Unbleached Press (2) 0.52 (0.5181) 0.52/4.202 Bleach Tower 1 (3) 0.33 (0.3339) 0.33/2.667 Bleach Tower 2 (4) 0.01 (0.0069) 0.01/0.081 Unbleached Thickener (5) 0.04 (0.0374) 0.04/0.323 Totals 1.00 1.00/8.081 (1) PP-Functional Stack #1 (2) PP-Functional Stack #2 (3) PP-Functional Stack #3 (4) PP-Functional Stack #4 (5) PP-Functional Stack #5Paper Machines For the paper machines, a similar analogy was applied. Instead of a total combined emissions estimate for the five paper machines, RSA started with estimated individual maximum emissions rates for each of the five paper machines. The calculations were based on a maximum chloroform factor of 0.0161 lbs/ton obtained from the draft 1996 NCASI report for Paper Machine PM-14. This is slightly higher than the 0.015 lbs/ton factor published in the final 1997 NCASI report. Emissions calculations for PM-11 and PM-12, which are housed in the same area of the complex, were combined.There are four functional areas each for paper machines PM-13, PM-14, and PM-15, and four functional areas for PM-11 and PM-12 combined, which are housed in the same area of the complex, for a total of 16 functional areas emitting through 16 representative stacks. Input parameters for January 1999 ISCST3 model surmises that the four functional areas would be the PERMIT MEMORANDUM 99-113-TV DRAFT 40FPS - fan pump silo, YWE – Yankee dryer wet end, VS – vacuum system, and WER – wet end roof vents. These correspond to source vents tested by NCASI. Using the four functional area chloroform emissions factors taken from the NCASI report dated November 15, 1996, for PM- 14, the highest of the two machines tested, the applicant calculated the distribution of emissions representing the functional areas. The table below illustrates the results of these calculations. These emissions rates were used as input into the ISCST3 model to obtain a GLC for chloroform.Functional NCASI % PM-11 & 12 PM-13 PM-14 PM-15 PM-11 Thru 15 Area Emission Emissions PTE PTE PTE PTE PTE Factor (lbs/hr) (1) (lbs/hr) (1) (lbs/hr) (1) (lbs/hr) (1) (lbs/hr) (1) (lbs/ton) Fan Pump 0.0006 4% 0.0139 0.0073 0.0068 0.0074 0.0354 Silo (2) Yankee 0.0000 0% 0.0000 0.0000 0.0000 0.0000 0.0000 Wet End (3) Vacuum 0.0015 9% 0.0312 0.0164 0.0153 0.0167 0.0796 System (4) Wet End 0.0140 87% 0.3018 0.1586 0.1483 0.1612 0.7699 Roof (5) Functional 0.0161 100% 0.3469 0.1823 0.1704 0.1853 0.8849 Area Total (1) Pre-1999 PTE increase. (2) PM-Functional Stack #1 (3) PM-Functional Stack #2 (4) PM-Functional Stack #3 (5) PM-Functional Stack #4Additional ISCST3 Model Input The ISCST3 model was executed using five years of historical meteorological data (1986-88 and 1990-91 Tulsa surface air data combined with Oklahoma City and Norman upper air data). Input data in the ISCST3 model was based on functional areas, rather than attempting to input every stack. Stack temperature, velocity and diameter for each functional area was taken from the 1997 Screen3 modeling. Three exceptions are noted: flotation cells (functional area stack PP- Stack #1) temperature was modeled at 68 ºF instead of 107 ºF; unbleached press (functional area stack PP-Stack #2) was modeled at 68 ºF rather than 81 ºF; and wet end roof (functional area stack PM-Stack #4) was modeled at 0.1 ft/sec rather than 42.5 ft/sec. These differences are all conservative. Including the two boiler stacks, there are a total of 23 stacks input into the ISCST3 model. There are five stacks representing the five paper pulping functional areas and 16 stacks representing the five paper machines functional areas (as described above, four functional areas each for paper machines PM-13, PM-14 and PM-15, and four functional areas for paper machines PM-11 and PM-12 combined). It is noted that grouping the paper machine functional areas into four representative functional areas is the same concept that was used to group the pulp processing functional areas into five representative functional areas. Stack height was assumed to be roof height plus 4 feet for all paper pulping and paper machine stacks. The RSA report states that no stack was modeled at greater than GEP. Additional assumptions include inputting all roof vents/stacks as horizontal vents with a velocity of 0.1 ft/sec and locating all stacks at the approximate centerline of their respective building. The report states that the first two of these assumptions, i.e., stack height and horizontal orientation, are conservative and should yield higher ambient GLCs, and that the location of the PERMIT MEMORANDUM 99-113-TV DRAFT 41 stacks on the centerlines of the buildings is inconsequential. Locations and dimensions of large buildings, large tanks, the coal pile, and the cooling towers were also input in the model. Buildings having multiple tiers were assumed to have the height of the tallest tier. Four receptor grids covering an area of 5.1 km in the east-west direction and 4.3 km in the north-south direction were placed around the facility, with the facility located in the approximate center. Discrete receptors were placed at the fenceline and between the fenceline and the grids at distances of 100 meters. Terrain elevations were imported from the USGS data files. Building downwash was included in the ISCST3 model with direction-specific downwash and GEP stack heights calculated by the EPA BPIP. The ISCST3 model was executed five times, i.e., once for each year of meteorological data input. The overall highest GLC was 43 μg/m3, which occurred at a receptor located along the south fenceline at its approximate midpoint. The results of this evaluation are discussed in the RSA report dated February 11, 1999, included as Appendix H of the Title V application.ISCST3 Model Results Utilizing the resulting GLC for chloroform as the unit multiplier as in the previous analogies, RSA checked the GLCs for the other six pollutants. The following table illustrates the results of these calculations.μ/m3 Ethanol Chloroform Acetaldehyde Biphenyl Methanol Phenol Toluene 24-hr GLC 33.7 43.0 * 76.0 67.5 207.2 26.1 64.0 MAAC 33,800 97 3,600 126 38,000 384 37,668 * Used as the unit multiplier to calculate GLCs for each pollutant at its respective emission rate.Subsequent Production Increase Analysis A subsequent evaluation of air quality impacts was performed by RSA in response to a request from the applicant to account for increases in PTE resulting from anticipated increases in production. The emissions rates were increased by 16.32% for all operations to account for projected increases in production. The increase in emissions rates did not result in any new exceedance of the de minimis threshold(s) for TACs other than the seven identified in the previous analyses. The TACs emitted from these processes are illustrated in the table below, with the seven TACs of concern identified in bold typeset, as taken from the RSA report dated March 2, 1999. This increases the estimated chloroform emission rate used in the model to 9.40 lbs/hr. Recall from the discussion of emissions calculations that based on the maximum paper stock production rate of 565,787 TPY, the estimated chloroform PTE is 9.04 lbs/hr. PERMIT MEMORANDUM 99-113-TV DRAFT 42VOC/HAP/TAC Emissions Air Toxic PM PP PM + PP PM PP PM + PP Cat. Above Emissions Emissions Emissions Emiss. Emissions Emissions De (TPY) (TPY) (TPY) (lbs/hr) (lbs/hr) (lbs/hr) Minimis 1,2,4-trimethylbenzene 0.268865 0.2893658 0.558231 0.061385 0.0660652 0.12744996 C NO 1,1,1-trichlorethane 0.044811 0.1293912 0.174202 0.010231 0.0295414 0.03977216 C NO 1,2-dimethoxyethane 0 0.0499921 0.049992 0 0.0114137 0.01141371 C NO 1,1,2,2-tetrachloroethane 0 0.0028231 0.002823 0 0.0006445 0.00064454 A NO 1,3,5-trimethylbenzene 0.061615 0.087045 0.14866 0.014067 0.0198733 0.03394061 C NO 1,4-dichlorobenzene 0 0.0031172 0.003117 0 0.0007117 0.00071168 B NO 1-butanol 0.109226 1.8114769 1.920703 0.024938 0.4135792 0.43851673 C NO 1-butene 0.023246 0.1732078 0.196453 0.005307 0.0395452 0.04485237 NS NO 1-pentene 0 0.054109 0.054109 0 0.0123537 0.01235366 NS NO 2,2,4-trimethylpentane 0 0.0391114 0.039111 0 0.0089296 0.00892955 B NO 2,3-dimethylpentane 0 0.0064696 0.00647 0 0.0014771 0.00147707 C NO 2,3-dimethylbutane 0 0.0147035 0.014704 0 0.003357 0.00335697 NS NO 2-hexanone 0 0.0576379 0.057638 0 0.0131593 0.01315934 C NO 2-methyl heptane 0.154037 0.302893 0.45693 0.035168 0.0691537 0.10432199 NA NO 2-nitropropane 0.015124 0.0179383 0.033062 0.003453 0.0040955 0.0075484 A NO 3-methyl heptane 0.120429 0.257018 0.377447 0.027495 0.0586799 0.08617514 B NO 3-methyl hexane 0 0.0279367 0.027937 0 0.0063783 0.00637825 C NO Acetaldehyde 7.337775 12.93912 20.277 1.675291 2.9541371 4.62943 B YES Acetone 0.252061 2.3113974 2.563458 0.057548 0.5277163 0.58526447 NS NO Acetonitrile 1.316318 0.2676045 1.583923 0.300529 0.0610969 0.36162623 C NO Acetophenone 0.159639 1.061596 1.221235 0.036447 0.2423735 0.27882069 C NO Acrolein 0.109226 0.141154 0.25038 0.024938 0.0322269 0.05716449 A NO alpha-methyl styrene 0.030807 0.0326419 0.063449 0.007034 0.0074525 0.01448615 C NO alpha-pinene 0 0.0019997 0.002 0 0.0004565 0.00045655 C NO Benzene 0.014283 0.0385233 0.052807 0.003261 0.0087953 0.01205633 A NO Benzonitrile 0.014564 0.0094103 0.023974 0.003325 0.0021485 0.00547347 C NO beta-pinene 0.025766 0.394055 0.419821 0.005883 0.0899669 0.0958496 C NO PERMIT MEMORANDUM 99-113-TV DRAFT 43VOC/HAP/TAC Emissions (Continued) Air Toxic PM PP PM + PP PM PP PM + PP Cat. Above Emissions Emissions Emissions Emiss. Emissions Emissions De (TPY) (TPY) (TPY) (lbs/hr) (lbs/hr) (lbs/hr) Minimis Biphenyl 27.39062 20.879035 48.27 6.253567 4.766903 11.0205 C YES Bromo dichloromethane 0.021285 0.2293753 0.25066 0.00486 0.0523688 0.05722842 C NO carbon disulfide 0 0.0067636 0.006764 0 0.0015442 0.00154421 B NO carbon tetrachloride 0 0.0108806 0.010881 0 0.0024842 0.00248416 A NO Chloro difluoromethane 0.064416 0.0183206 0.082736 0.014707 0.0041828 0.01888954 NS NO Chloroethane 0 0.0138213 0.013821 0 0.0031556 0.00315556 B NO Chloroform 4.509091 41.169929 45.679 1.029473 9.3995271 10.429 A YES Chloromethane 0 0.0323478 0.032348 0 0.0073853 0.00738534 A NO Cumene 0.010643 0.0426403 0.053283 0.00243 0.0097352 0.01216504 C NO Cyclohexane 0.010643 1.6820857 1.692728 0.00243 0.3840378 0.38646763 NS NO Cyclohexanone 0.011763 0.0820458 0.093809 0.002686 0.0187319 0.0214175 C NO Dibromo chloromethane 0 0.0182324 0.018232 0 0.0041626 0.00416265 NA NO Dichloro difluoromethane 0.023526 0.0070577 0.030583 0.005371 0.0016113 0.00698251 NS NO ethanol (ethyl alcohol) 3.360813 17.850105 21.211 0.767309 4.0753664 4.84268 B YES Ether 0.134433 0.3617072 0.49614 0.030692 0.0825816 0.11327391 C NO Ethylbenzene 0.036409 0.2843666 0.320775 0.008313 0.0649239 0.07323639 C NO Formaldehyde 0.009774 0.0038229 0.013597 0.002232 0.0008728 0.0031044 A NO Heptane 0.010363 0.0382292 0.048592 0.002366 0.0087281 0.011094 NS NO Isobutene 0.039209 0 0.039209 0.008952 0 0.00895194 NS NO Isopentane 0.044811 0.1814418 0.226253 0.010231 0.0414251 0.05165584 NS NO isopropyl alcohol 0.04201 0.6646003 0.70661 0.009591 0.1517352 0.16132658 C NO Limonene 0 0.0411699 0.04117 0 0.0093995 0.00939953 NA NO Methanol 19.94082 35.28851 55.229 4.552699 8.0567375 12.6094 C YES methyl ethyl ketone 0.056014 0.6175489 0.673562 0.012788 0.1409929 0.15378139 C NO methyl isobut'ketone 0 0.27378 0.27378 0 0.0625069 0.06250686 C NO methyl methacrylate 0 0.0411699 0.04117 0 0.0093995 0.00939953 B NO methylcyclohexane 0 0.019938 0.019938 0 0.0045521 0.00455206 C NO methylene chloride 0.316477 0.0207908 0.337267 0.072255 0.0047468 0.07700168 A NO m,p-xylene 0.151237 1.0380703 1.189307 0.034529 0.2370024 0.27153126 C NO Naphthalene 0 0.5587347 0.558735 0 0.127565 0.12756501 B NO Nitrobenzene 0.026046 0.0438166 0.069863 0.005947 0.0100038 0.01595043 B NO Nonane 0.033608 0.1214513 0.155059 0.007673 0.0277286 0.03540169 C NO n-butane 0.024926 0.0001706 0.025097 0.005691 3.894E-05 0.00572981 NS NO n-propylbenzene 0.015404 0.0094103 0.024814 0.003517 0.0021485 0.0056653 NS NO Octane 0.159639 0.3646479 0.524287 0.036447 0.083253 0.11970013 C NO o-xylene 0.058814 0.3881736 0.446988 0.013428 0.0886241 0.10205202 C NO Pentane 0.015124 0.0361707 0.051294 0.003453 0.0082582 0.01171105 C NOVOC/HAP/TAC Emissions (Continued) PERMIT MEMORANDUM 99-113-TV DRAFT 44Air Toxic PM PP PM + PP PM PP PM + PP Cat. Above Emissions Emissions Emissions Emiss. Emissions Emissions De (TPY) (TPY) (TPY) (lbs/hr) (lbs/hr) (lbs/hr) Minimis Phenol 5.881422 2.1290734 8.0105 1.342791 0.4860898 1.82888 B YES propionaldehyde 0.007562 0.0067636 0.014325 0.001726 0.0015442 0.00327065 C NO Propylene 0.210051 0.1073359 0.317387 0.047957 0.0245059 0.07246271 NS NO Styrene 0 0.2264346 0.226435 0 0.0516974 0.0516974 B NO tetrachloroethane 0 0.0029407 0.002941 0 0.0006714 0.00067139 NA NO Toluene 0.733777 14.615325 15.349 0.167529 3.3368321 3.50436121 C YES trans-2-butene 0.025766 0.1940868 0.219853 0.005883 0.0443121 0.05019476 NA NO Total 73.43429 160.24406 233.6784 16.76582 36.585402 53.3512221 PM – Paper Machines Emissions PP – Paper Pulping EmissionsRather than run another ISCST3 model, the same assumptions as for the first two analyses were used, i.e., increases in modeled GLCs are linearly proportional to increases in emission rates. Using this methodology, the GLCs obtained from the previous ISCST3 model were increased by 16.32% to obtain new GLCs for the seven pollutants of concern. This resulted in marginal increases in the calculated GLCs. The GLC for chloroform, the pollutant that failed the initial Screen3 model was 50 μ/m3, still well below the MAAC. Therefore the ISCST3 modeling demonstrates that emissions of chloroform, the primary pollutant of concern, would be in compliance with the MAAC while operating the affected processes at maximum production capacity. The results of this evaluation are discussed in the RSA report dated March 2, found in Appendix H of the Title V application. The following table illustrates the results of these calculations.μ/m3 Ethanol Chloroform Acetaldehyde Biphenyl Methanol Phenol Toluene 24-hr GLC 39.2 50.0 * 88.4 78.5 241.0 30.4 74.4 MAAC 33,800 97 3,600 126 38,000 384 37,668 * Used as the unit multiplier to calculate GLCs for each pollutant at its respective emission rate.Boilers B-2, B-3, and B-4 There are two emission stacks serving the four boilers, a common stack #1 for B-1 and B-2, and a common stack #3 for B-3 and B-4. Stack #2 has been out-of-service since original construction after it settled. Boiler B-1 is fired with natural gas while boilers B-2, B-3 and B-4 are coal-fired. The facility identified three TACs; hydrochloric acid, sulfuric acid, and hydrogen fluoride, based on emission calculations from the coal fired boilers, that are emitted above de minimis levels. Screen3 modeling was not used for evaluation of GLCs from boiler emissions. The same ISCST3 model used for the Paper Pulping Processes and Paper Machines was used for the boiler stacks with the changes discussed herein. As indicated in the discussion for modeling of the Paper Pulping Processes and Paper Machines, a total of 23 stacks were input into the ISCST3 model, including the two boiler stacks. Boiler stack parameters, as provided by the applicant, were input. Direction-specific downwash data and GEP stack heights were calculated by BPIP. Because of the higher stack height of 260 feet, a larger receptor area was used. The four grids were extended to cover an area of 8.2 km in the east-west direction and 8.4 km in the north-south direction. Terrain elevations for the Braggs, Oklahoma, quadrangle were added. As before, assuming that increases in modeled GLCs as calculated by the ISCST3 model are linearly proportional to increases in emissions rates, a unit total emission rate of 1.0 lb/hr was modeled to PERMIT MEMORANDUM 99-113-TV DRAFT 45 obtain a groundlevel concentration (GLC) and used as a multiplier with the individual emission rate for each TAC to calculate the GLCs. The following table illustrates the emission rates from the boilers that were used in the evaluation.Boiler ID Stack Hydrochloric Acid Sulfuric Acid Hydrofluoric Acid ID (lbs/hr) (lbs/hr) (lbs/hr) B-1 1 Fueled by Natural Gas Fueled by Natural Gas Fueled by Natural Gas B-2 1 24.71 7.268 1.848 B-3 3 31.28 9.200 2.339 B-4 3 31.28 9.200 2.339 Totals 87.27 25.668 6.527 Stack No. 1 28.31 28.31 28.31 % of EmissionsTotals Summary 87.270 25.668 6.527As illustrated by the table, the emissions from Stack No.1 for each TAC are consistently 28.31% of the total emissions. This is because the emissions calculations are based on AP-42 factors, which are the same for each boiler. Therefore, Stack No. 1 was modeled at 0.2831 lbs/hr and Stack No. 3 was modeled at 0.7169 lbs/hr, for the total resulting unit emissions rate of 1.0 lb/hr. Because the updated emission factors incorporated from recent stack testing resulted in overall lower totals for each pollutant, this modeling is still adequate. The following table illustrates the resulting GLCs calculated using the total emission rates from the boilers and using the multiplier GLCs obtained from a total unit emissions rate of 1.0 lb/hr as presented in Tables 7 and 8 of the RSA report dated February 11, 1999, except that the table below includes the calculated GLCs.Pollutants CAT Maximum Multiplier MAAC Maximum Emissions (  g/m 3) GLC (lbs/hr) (lbs/hr) (g/m3) (g/m3)HCl C 87.270 0.07457 700 6.51H2SO4 A 25.668 0.07457 10 1.91 HF B 6.527 0.07457 50 0.49Results of recent stack testing performed in late 2003 conclude that most of these TACs, as emitted from the individual boilers, are emitted at lower levels while few were emitted at higher levels, resulting in lower overall total combined emissions rates than those used in the modeling analysis. Therefore, the 1999 modeling analysis is good for the newly requested emissions rates.SC-1 Solvent Cleaning GLCs for the solvent cleaning of the paper machines were calculated using the unit multiplier methodology based on the results of EPA ISCST2 and Screen air dispersion modeling contained in the 1992 Bowman report. Meteorological data acquired from the USEPA SCRAM bulletin board for the year 1988 (Tulsa surface data and Oklahoma City mixing height data) were used in the model. Model runs were executed for flat terrain using ISCST2 and for complex terrain using the PERMIT MEMORANDUM 99-113-TV DRAFT 46Valley option in Screen with building downwash. Emissions rates and stack parameters for thirteen stacks were provided to Bowman by the applicant. Maximum hourly emission rates for each TAC were based on a maximum solvent usage rate of 215 gallons, expended during one hour of cleaning and the maximum content by weight of each TAC in the solvent, assuming 60% of the solvent evaporates, 20% is retained in wastewater, and the remaining 20% is consumed (i.e., used up or reacts with latex contaminants). The evaporation efficiency, wastewater retention and reaction percentages are based on testing done at other facilities. Although there is no discussion of justification for the allocation of the emission rates through each stack, based on Table 3 in the Bowman report, it is likely they could have been prorated from the maximum hourly rates based on the fan/air discharge rates from the vents. The calculated emission rates and GLCs for these pollutants are illustrated in Table 3 of the Bowman report.Whereas the Bowman report analyzed a solvent having four TACs, RSA needed to perform the same analysis for a solvent that now contained seven TACs. As with the other modeling analyses, RSA utilized the assumption that increases in modeled GLCs as calculated by the model are linearly proportional to increases in emission rates, such that the results of the modeling can be used to derive a multiplier to calculate the individual GLCs for each pollutant. The maximum GLC occurring from solvent cleaning was taken from the Bowman report to be 108 μg/m3 at an emission rate of 38.26 g/sec. Using these two values to develop the multiplier of 2.82 μg-sec/g-m3, RSA calculated the resulting GLCs for each of seven TACs emitted from the cleaning solvent. The GLCs for all seven of these pollutants were well below the MAAC. These values are illustrated with the MAAC for each pollutant in the RSA report found in Appendix H of the Title V application.The solvent currently used at the facility has only four TACs, but not the same composition as the original solvent analyzed by Bowman. Using the same analogy as for the analyses of the previous two solvents, the results illustrated in the table below are obtained. It should be noted that the rates illustrated in this analysis are 24-hour averages, based on the projected annual emissions. The 2.82 μg-sec/g-m3 converts to 0.356 μg-hr/lb-m3. As demonstrated, the GLCs for these TACs are also well below the MAAC.SC-1 Solvent Cleaning Of Paper Machines PM-11, PM-12, PM-13, and PM-14 CAS # CAT Average Multiplier MAAC Maximum Emissions (  g/m 3) GLC (lbs/hr) (lbs/hr) (g/m3) (g/m3) Pollutant Stoddard Solvent 8052413 C 20.55 2.82 35,000 7 Aromatic Hydrocarbon B 17.47 2.82 7,000 6 Mixture > C9 64742945 1,2,4-Trimethylbenzene 95636 C 0.51 2.82 12,301 0.2 Naphthalene 91203 B 1.54 2.82 1,000 0.5 PERMIT MEMORANDUM 99-113-TV DRAFT 47SECTION VI. INSIGNIFICANT ACTIVITIESBoiler Ash Handling Following is an evaluation performed by the applicant based on some research of two coal-fired power plants. One was permitted in Colorado, and the other in Kentucky.Both permits used AP-42 to estimate particulate matter emissions from boiler ash handling operations. One permitting agency adapted AP-42 for clay and fly ash sintering at Chapter 11.8. The other agency adapted AP-42 for cement batching at Chapter 11.12. Fly ash sintering factors are uncontrolled, where as cement batching offers controlled and uncontrolled emission factors. The boiler ash silos are equipped with baghouses that control emissions with a 99.9% efficiency. The applicant believes that cement exhibits very similar physical characteristics as boiler ash and therefore used the cement batching factors for the following emission estimate of silo emissions.Ash generation was estimated using 600,000 TPY of coal at 8.5% ash. The applicant used this as a worse case ash content for all high Btu coal. However, it should be noted that the permit contains conditions limiting ash content to lower values. Both fly ash and bottom ash are pneumatically conveyed to elevated silos equipped with identical baghouses. The ash is then loaded into enclosed trucks and disposed in the mill’s permitted on-site landfill cells. According to Table 11.12-2, total PM emissions from Cement supplement unloading to elevated storage silo (pneumatic) are 0.0089 lbs PM/ton controlled and 3.14 lbs/ton uncontrolled. Estimating a maximum potential ash generation of approximately 51,000 TPY, potential PM emissions would equate to 454 lbs/year.For truck loading, dumping and pile erosion, Chapter 13.2.4 Aggregate Handling and Storage Piles, was used.From Section 13.2.4:E (lbs/ton) = k*0.0032 * (U/5)1.3 / (M/2)1.4,Where: k = 0.35 for PM10, U = wind speed (15 mph, worst case value from Ranges of Source Conditions), and M = moisture content (0.25 %, worst case value from Ranges of Source Conditions)Applying the above factors, E = 0.0859 lbs PM/ton of ash.At 51,000 TPY of ash, PM emissions would equal 4,381 lbs/year from truck loading, dumping, and pile erosion. This yields a total of 4,835 lbs/year of PM emissions for all of ash handling.Converting Trim Vent Following is an evaluation performed by the applicant based on emissions information obtained from a sister facility in Green Bay Wisconsin. PERMIT MEMORANDUM 99-113-TV DRAFT 48At the subject facility, scrap paper from the converting operations, called “trim” or “broke,” is conveyed to the converting broke pulper to be mixed with water for reuse in the papermaking process. Much of the broke is transported in carts and dumpsters to a pulper or removed pneumatically from the point of generation and dumped on an overhead conveyor to a pulper. Some of the broke, however, is conveyed pneumatically all the way to the top of a pulper where airborne particulate is removed from the air stream, and the air stream is cleaned by a baghouse before discharge to the atmosphere. This operational scenario describes the Converting operations at the subject facility as well as Converting operations at a sister tissue facility located in Green Bay, WI.The Green Bay facility had stack testing performed on three stacks from their trim collection system. Those stack emissions totaled 7.22 lbs/hr (31.6 TPY), uncontrolled. The trim collection system at the subject facility is equipped with baghouses having collection efficiency ratings of 99.9% prior to discharge to the atmosphere. At 7.22 lbs/hr and 99.9% collection efficiency, annual emissions would equate to 63.2 lbs/year.Printed Napkins Printed napkins are a group of eight (8) letterpress printing presses in our Converting area. These presses are not subject to the printing and publishing MACT, Subpart KK. They were not included in the Title V application because as a group their emissions are below 5 TPY VOC. Collectively, VOC emissions have increased to near 5 TPY. Individually, however, emissions are still well below this threshold.The insignificant activities identified and justified in the application are duplicated below. Records must be available to confirm the insignificance of the activities. Appropriate recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr heat input (commercial natural gas). The applicant operates several space heaters at the facility. 2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. There is one aboveground 10,000-gallon gasoline tank existing at the facility. The facility used only 9,500 gallons from this tank during the year 2003. This tank is equipped with submerged fill pipe. 3. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. There are several aboveground diesel tanks at the facility including a 100,000-gallon No. 2 diesel tank used to fuel a locomotive and some heavy equipment. 4. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. There are several diesel and solvent tanks at the facility. 5. Additions or upgrades of instrumentation or control systems that result in emissions increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1). PERMIT MEMORANDUM 99-113-TV DRAFT 496. Cold degreasing operations utilizing solvents that are denser than air. There are numerous activities under this category. 7. Site restoration and/or bioremediation activities of < 5 years expected duration. There are no activities under this category at the facility at this time. 8. Hydrocarbon contaminated soil aeration pads utilized for soils excavated at the facility only. There are no activities under this category at the facility at this time. 9. Emissions from the operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics (OAC 252:100-41-43) and HAPs (§112(b) of CAAA90). The facility currently operates groundwater monitoring wells that are required by the facility’s solid waste landfill permits. There are no groundwater remediation wells at the facility at this time. 10. * Non-commercial water washing operations (less than 2,250 barrels/year) and drum crushing operations of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material. 11. Hazardous waste and hazardous materials drum staging areas. There are numerous activities under this category. 12. Sanitary sewage collection and treatment facilities other than incinerators and Publicly Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also included (i.e., lift station). All of the facility’s sanitary sewage is collected by two lift stations and discharged to the local POTW. 13. Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation. 14. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. There are numerous activities under this category. 15. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. There are numerous activities under this category. 16. * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant (see instructions). a. Boiler Ash Handling b. Converting Trim Vent c. Printed Napkins 17. Vacuum cleaning systems used exclusively for industrial, commercial, or residential housekeeping purposes, except those systems used to collect particulate matter subject to 252:100 and hazardous and/or toxic air contaminants PERMIT MEMORANDUM 99-113-TV DRAFT 50SECTION VII. OKLAHOMA AIR POLLUTION CONTROL RULESOAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements.OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these standards. In addition, modeled emissions from the proposed facility demonstrate that the facility would not have a significant impact on air quality.OAC 252:100-4 (New Source Performance Standards) [Applicable] Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These requirements are covered in the “Federal Regulations” section.OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories were submitted and fees paid for previous years as required.OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I or whose actual calendar year emissions do not exceed the following limits. 5 TPY of any one criteria pollutant  2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule  0.6 TPY of any one Category A toxic substance  1.2 TPY of any one Category B toxic substance  6.0 TPY of any one Category C toxic substanceEmission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from existing permits, the permit application, or developed from the applicable requirement. PERMIT MEMORANDUM 99-113-TV DRAFT 51OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.OAC 252:100-13 (Prohibition of Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.OAC 252:100-19 (Particulate Matter (PM)) [Applicable] Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Appendix C specifies PM emission limitations for all equipment at this facility. Fuel-burning equipment is defined in OAC 252:100-1 as “combustion devices used to convert fuel or wastes to usable heat or power.” Boilers B-1, B-2, B-3, and B-4, Paper Machine Drying Hoods PM-11, PM-12, PM-13, PM-14, and PM-15, the PO-1 Tunnel Dryer (Flexographic Polyethylene Printer), and the PO-1 Catalytic Incinerator are subject to the requirements of this subchapter. AP-42 (7/98) Table 1.4-1 lists natural gas Total Particulate Matter (TPM) emissions to be 7.6 lbs/million scf or about 0.0076 lbs/MMBTU, which is in compliance. AP-42 (9/98) Tables 1.3-1 and 1.3-2 lists TPM emissions factors for #6 fuel oil. Not all emissions units listed are permitted to combust #6 fuel oil, however, this will also represent a highly conservative estimate for those that are limited to #2 fuel oil. Converting these factors to units of lbs/MMBtu yields the values illustrated in the tables below, which are in compliance with the allowable. Compliance with the applicable standard while burning coal was verified by stack testing. The following table illustrates compliance for all combustions units burning any of the permitted fuels. It should be noted that the emissions factors are uncontrolled factors, i.e., they do not take into account emissions controls. EMISSION COAL NAT GAS FUEL OIL APP “C” UNIT Emission Emission Emission Allowable Factor Factor Factor Boiler B-1 NA 0.0076 0.07 (3) 0.27 310 MMBTUH Boiler B-2 Hi Btu Coal 0.032 (1), (2) 0.0076 0.07 (3) 0.24 440 MMBTUH Lo Btu Coal 0.027 (1), (2) 0.0076 0.07 (3) 0.24 Boiler B-3 0.005 (1), (2) 0.0076 0.07 (3) 0.23 557 MMBTUH Boiler B-4 0.015 (1), (2) 0.0076 0.07 (3) 0.23 557 MMBTUH (1) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous (2) - Stack tests, conducted on January 7, 8, 9, 2003 for B-2, May 20 & 21, 2003 for B-3, and April 15 & 16, 2003 for B-4 (3) - Heating value for No. 2 Fuel Oil = 0.14 MMBtu/gal, Heating value for No. 6 Fuel Oil = 0.15 MMBtu/gal PERMIT MEMORANDUM 99-113-TV DRAFT 52EMISSION UNIT NATURAL GAS FUEL OIL APP “C” Emissions Factor Emissions Factor AllowablePaper Machine PM-11 0.0076 0.07 0.41 (24 MMBTUH x 2) Paper Machine PM-12 0.0076 0.07 0.45 (16.5 MMBTUH x 2) Paper Machine PM-13 0.0076 0.07 0.45 (16.5 MMBTUH x 2) Paper Machine PM-14 0.0076 0.07 0.41 (24 MMBTUH x 2) Paper Machine PM-15 0.0076 0.07 0.41 (25 MMBTUH x 2) PO-1 Catalytic Incinerator 0.0076 0.07 0.60 (2.0 MMBTUH)Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units and emission points in an industrial process based on process weight rate, as specified in Appendix G. The following table illustrates the calculated hourly rates of PM emissios. All emission points are in compliance with the Subchapter 19 limits.Paper Machines EMISSION UNIT Emissions Limit (lbs/hr) (lbs/hr) PM-11 2.1 19.7 PM-12 3.0 24.7 PM-13 2.6 22.3 PM-14 2.6 22.3 PM-15 2.3 21.1 Coal Preparation Plant (TPY Coal) Railcar Unloading, Radial Stacker, Grizzly Feeder 519,362 5.09 46.2 Coal Sizer/Crusher 519,362 11.86 46.2 Conveying 519,362 1.18 46.2 Coal Bunkers 519,362 1.18 46.2 Coal Feeders, Pulverizers Closed Process, No emissions FS-1 Coal Pile Emissions included with aboveOAC 252:100-25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except for short-term occurrences that consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. Boilers B-1, B-2, B-3, and B-4 are not subject to Subchapter 25 since they are subject to an opacity limitation in NSPS Subpart D. Other combustion units are units fired with natural gas and are therefore not likely to exceed this standard. Equipment subject to Subpart Y at the Coal Preparation plant is also not subject to Subchapter 25 since they are subject to an opacity limitation. PERMIT MEMORANDUM 99-113-TV DRAFT 53OAC 252:100-29 (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originated in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate this requirement; therefore it is not necessary to require specific precautions to be taken.OAC 252:100-31 (Sulfur Compounds) [Applicable] Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1, 1972). The limits, based on heat input, are 0.2 lbs/MMBTU for gaseous fuels, 0.8 lbs/MMBTU for liquid fuels, and 1.2 lbs/MMBTU for solid fuels. The averaging time for the emission limits is 3 hours unless a solid fuel sampling and analysis method is used to determine emission compliance. In that case the averaging time is 24 hours. Testing was done for emissions from coal combustion which demonstrated emissions from this fuel were well within the limits. Specific conditions in the permit limiting fuel sulfur content for the various fuels will ensure compliance with the limits when these fuels are used. The table below illustrates compliance based on the emissions calculations illustrated in the permit memorandum. It should be noted that the values for natural gas combustion are based on AP-42 emission factors.EMISSION UNIT NAT GAS FUEL OIL COAL Emission Factor Emission Factor Emission Factor B-1 0.0006 lbs (2) 0.69 lbs (3) NA 310 MMBTUH MMBtu MMBtu B-2 Hi Btu Coal (1) 0.0006 lbs (2) 0.69 lbs (3) 0.644 lbs (4) 440 MMBTUH MMBtu MMBtu MMBtu Lo Btu Coal (1) NA NA 0.267 lbs (4) MMBtu B-3 0.0006 lbs (2) 0.69 lbs (3) 0.403 lbs (4) 557 MMBTUH MMBtu MMBtu MMBtu B-4 0.0006 lbs (2) 0.69 lbs (3) 0.631 lbs (4) 557 MMBTUH MMBtu MMBtu MMBtu PM-11 0.0006 lbs (2) 0.69 lbs (3) NA (24 MMBTUH x 2) MMBtu MMBtu PM-12 0.0006 lbs (2) 0.69 lbs (3) NA (16.5 MMBTUH x 2) MMBtu MMBtu PM-13 0.0006 lbs (2) 0.69 lbs (3) NA (16.5 MMBTUH x 2) MMBtu MMBtu PM-14 0.0006 lbs (2) 0.69 lbs (3) NA (24 MMBTUH x 2) MMBtu MMBtu PM-15 0.0006 lbs (2) NA NA (25 MMBTUH x 2) MMBtu (1) - Lo Btu coal is sub-bituminous, Hi Btu is bituminous (2) - AP-42, Table 1.4-2 (7/98) 3 (3) - AP-42, Table 1.3-1 (9/98), SO2 = 157S lbs/10 gal, S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil Heating value for No. 2 Fuel Oil = 0.14 MMBtu/gal, Heating value for No. 6 Fuel Oil = 0.15 MMBtu/gal (4) - Stack tests, conducted on January 7, 8, 9, 2003 for B-2, May 20 & 21, 2003 for B-3, and April 15 & 16, 2003 for B-4 PERMIT MEMORANDUM 99-113-TV DRAFT 54OAC 252:100-33 (Nitrogen Oxides) [Not Applicable] This subchapter limits new gas-fired, liquid-fired, and solid fossil fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20, 0.30, and 0.70 respectively, lbs of NOx per MMBTU, three-hour average. Only boilers B-1, B-2, B-3, and B-4 exceed the 50 MMBTUH threshold and are subject to these standards. The table below illustrates compliance based on the emission calculations illustrated in the permit memorandum.EMISSION UNIT COAL NATURAL GAS FUEL OIL Emissions Emissions Factor Emissions Factor Factor B-1 NA 0.138 lbs (1) 0.21 lbs (1), (4) 310 MMBTUH MMBtu MMBtu (6) (1), (3) (5) (1), (4) B-2 NOX (Hi Btu Coal) 0.52 lbs 0.19 lbs 0.21 lbs 440 MMBTUH MMBtu MMBtu MMBtu (6) (1), (3) NOX (Lo Btu Coal) 0.38 lbs NA NA MMBtu B-3 0.27 lbs (1), (3) 0.187 lbs (2), (5) 0.26 lbs (1), (4) 557 MMBTUH MMBtu MMBtu MMBtu B-4 0.41 lbs (1), (3) 0.19 lbs (5) 0.29 lbs (2), (4) 557 MMBTUH MMBtu MMBtu MMBtu (1) -20% contingency added (2) -10% contingency added (3) -Stack tests, conducted January 7-9, 2003, for B-2, May 20-21, 2003, for B-3, and April 15-16, 2003, for B-4 (4) -AP-42, Table 1.3-1 (9/98), S = 0.5 for No. 2 Fuel Oil, S = 0.66 for No. 6 Fuel Oil (5) -AP-42, Table 1.4-1 (7/98) (6) -Lo Btu coal is sub-bituminous, Hi Btu is bituminousOAC 252:100-35 (Carbon Monoxide) [Not Applicable] None of the following affected processes are located at this facility: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic reforming unit.OAC 252:100-37 (Volatile Organic Compounds) [Part 7 Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The two underground 10,000-gallon gasoline tanks installed under Permit No. 75-053-C no longer remain. One aboveground 10,000-gallon gasoline tank is existing at the facility. This tank is equipped with a submerged fill pipe. Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt. Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete combustion. All fuel-burning equipment at this facility including the boilers, paper machine drying hoods, PO-1 tunnel dryer, and catalytic oxidizer are designed to provide essentially complete combustion of organic materials. PERMIT MEMORANDUM 99-113-TV DRAFT 55OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants) [Applicable] Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on July 1, 2003, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, GGGG, HHHH, JJJJ, NNNN, OOOO, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted by reference as they exist on July 1, 2003. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section. Part 5 is a state-only requirement governing toxic air contaminants. New sources (constructed after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform a BACT analysis, and if necessary, install BACT. All sources are required to demonstrate that emissions of any toxic air contaminant that exceed the de minimis level do not cause or contribute to a violation of the maximum acceptable ambient concentration (MAAC). As demonstrated in the Modeling Section above, no pollutants have ground level concentrations that exceed their respective MAACs.OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.The following Oklahoma Air Pollution Control Rules are not applicable to this facility:OAC 252:100-7 Permits for Minor Facilities not in source category OAC 252:100-11 Alternative Emissions Reduction not requested PERMIT MEMORANDUM 99-113-TV DRAFT 56OAC 252:100-15 Mobile Sources not in source category OAC 252:100-17 Incinerators not type of emission unit OAC 252:100-23 Cotton Gins not type of emission unit OAC 252:100-24 Grain Elevators not in source category OAC 252:100-35 Carbon Monoxide not in source category OAC 252:100-39 Nonattainment Areas not in area category OAC 252:100-47 Landfills not in source categorySECTION VIII. FEDERAL REGULATIONSPSD, 40 CFR Part 52 [Not Applicable to this Permit] PSD does not apply to this permit since there are no proposed emission increases. Future emission increases must be evaluated against the threshold levels of CO - 100 TPY, NOX - 40 TPY, SO2 - 40 TPY, VOC - 40 TPY, PM - 25 TPY, PM10 - 15 TPY, and Lead – 0.6 TPY.NSPS, 40 CFR Part 60 [Subparts D and Y Applicable] Subpart D – Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971 (§§60.40-60.46), affects each fossil-fuel- fired steam generating unit more than 73 megawatts heat input rate (250 million Btu per hour). Boilers B-1, B-2, B-3, and B-4 are all rated above this threshold and are therefore affected facilities. § 60.42, § 60.43, & §60.44 – contain standards for particulate matter, sulfur dioxide, and nitrogen oxides. The standard for particulate matter is 0.10 lbs/MMBtu from fossil fuel or fossil fuel and wood residue with no greater than 20% opacity except for one six-minute period per hour of not more than 27% opacity. The standard for SO2 is 0.8 lbs/MMBtu from liquid fossil fuels and 1.2 lbs/MMBtu from solid fossil fuels. The standard for NOX is 0.2 lbs/MMBtu from gaseous fossil fuel, 0.30 lbs/MMBtu from liquid fossil fuels, and 0.7 lbs/MMBtu from solid fossil fuels. Boiler B-1 is not permitted to burn coal. All four boilers are permitted to burn fuel oils and natural gas. Initial compliance testing for coal combustion was performed for Boilers B-2, B-3, and B-4. Initial compliance testing for B-1 was performed in June 1980. §60.45 - Contains requirements for calibration, maintenance, and operation of continuous monitoring systems for measuring the opacity of emissions, sulfur dioxide emissions, nitrogen oxides emissions, and either oxygen or carbon dioxide except as provided in paragraph §60.45(b). For a fossil fuel-fired steam generator that does not use a flue gas desulfurization device, a continuous monitoring system for measuring sulfur dioxide emissions is not required if the owner or operator monitors sulfur dioxide emissions by fuel sampling and analysis. If the owner or operator demonstrates during the performance test that emissions of nitrogen oxides are less than 70 percent of the applicable standards in §60.44, a continuous monitoring system for measuring nitrogen oxides emissions is not required. If an owner or operator does not install any continuous monitoring systems for sulfur oxides and nitrogen oxides, a continuous monitoring system for measuring either oxygen or carbon dioxide is not required. Based on the results of the initial testing, the facility is required to continuously monitor opacity. Subpart Da - Standards of Performance for Electric Utility Steam Generating Units for Which Construction is Commenced After September 18, 1978 (§§60.40a - 60.49a), affects each electric utility steam generating unit that is capable of combusting more than 73 megawatts (250 million PERMIT MEMORANDUM 99-113-TV DRAFT 57Btu/hour) heat input of fossil fuel (either alone or in combination with any other fuel) and For which construction or modification is commenced after September 18, 1978. Electric utility steam generating unit means any steam electric generating unit that is constructed for the purpose of supplying more than one-third of its potential electric output capacity and more than 25 MW electrical output to any utility power distribution system for sale. Any steam supplied to a steam distribution system for the purpose of providing steam to a steam-electric generator that would produce electrical energy for sale is also considered in determining the electrical energy output capacity of the affected facility. Boilers B-3 and B-4 were constructed in 1978 and 1981, respectively, but do not meet the definition of electric utility steam generating unit. The boilers are therefore not subject to the requirements of this subpart. Subpart Db - Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (§§60.40b - 60.49b), affects each steam generating unit that commences construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit of greater than 29 MW (100 million Btu/hr). Construction of the boilers commenced prior to the effective date and have not been modified or reconstructed and are therefore not subject to the requirements of this subpart. Subpart Dc - Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (§§60.40c - 60.48c), affects each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 MW (100 MMBtu/hr) or less, but greater than or equal to 2.9 MW (10 MMBtu/hr). The boilers were constructed prior to the effective date and are rated at greater than 100 MMBtu/hr. The boilers are therefore not subject to the requirements of this subpart. Subpart Y - “Standards of Performance for Coal Preparation Plants,” are applicable to any of the following affected facilities that commenced construction or modification after October 24, 1974, in coal preparation plants which process more than 181 Mg (200 tons) per day: Thermal dryers, pneumatic coal-cleaning equipment (air tables), coal processing and conveying equipment (including breakers and crushers), coal storage systems, and coal transfer and loading systems. Coal preparation plant means any facility (excluding underground mining operations) which prepares coal by one or more of the following processes: breaking, crushing, screening, wet or dry cleaning, and thermal drying. The coal preparation plant does not have thermal dryers, pneumatic coal-cleaning equipment, or coal transfer and loading systems. All other facilities in the coal preparation plant, except the coal pile, are subject to this rule. Coal storage system means any facility used to store coal except for open storage piles. Therefore, all processes involved in the coal storage operation are subject to this rule except the coal pile.Coal processing and conveying equipment means any machinery used to reduce the size of coal or to separate coal from refuse, and the equipment used to convey coal to or remove coal and refuse from the machinery. This includes, but is not limited to, breakers, crushers, screens, and conveyor belts. Therefore, all processes described here are subject to this rule. PERMIT MEMORANDUM 99-113-TV DRAFT 58NESHAP, 40 CFR Part 61 [Potentially Subpart M Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for small amounts of mercury from the boilers which are covered by NSPS Subpart D and will become subject to NESHAP Subpart DDDDD. Subpart M – The facility may be subject to certain regulations pertaining to the construction, demolition, and disposal of asbestos-containing materials.NESHAP, 40 CFR Part 63 [Subpart KK Applicable] Subpart S – National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry, affects both new and existing processes that produce pulp, paper, or paperboard located at a major source that use: (1) Kraft, soda, or semi-chemical pulping processes using wood; or (2) Mechanical pulping processes using wood; or (3) Any process using secondary or non-wood fibers. Equipment listed in § 63.444(a) are required to be enclosed and vented into a closed-vent system and routed to a control device. Fort James uses secondary wood (recycled paper) fiber and is an affected facility. However, as a result of the processes and bleaching chemicals used in producing the secondary fiber pulp, the facility is not subject to any of the standards in the subpart. Subpart KK - National Emission Standards for the Printing and Publishing Industry, apply to each new and existing facility that is a major source of hazardous air pollutants (HAP), as defined in 40 CFR 63.2, at which publication rotogravure, product and packaging rotogravure, or wide-web flexographic printing presses are operated and area sources as outlined in §63.820(a) (2). For product and packaging, affected sources include all of the product and packaging rotogravure or wide-web flexographic printing presses at a facility plus any other equipment at that facility which the owner or operator chooses to include in accordance with paragraph §63.821(a)(3) of this section, except proof presses, and any product and packaging rotogravure or wide-web flexographic press which is used primarily for coating, laminating, or other operations which the owner or operator chooses to exclude under certain provisions listed in this section. The owner or operator of product and packaging rotogravure, or wide-web flexographic printing presses may also elect to include in that affected source stand-alone coating equipment subject to certain provisions listed in this section. The following lists the affected sources:EU EU Name Manufacturer/Model No. Construct ID Date PO-1 Flexographic Polyethylene Printer Paper Converting Machine Company June, 1984 (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer FP-1 Flexographic Paper Printer Flexo 21-182 – PCMC/ Model No. 6724 1983 Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 PERMIT MEMORANDUM 99-113-TV DRAFT 59Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 PO-1 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6726 1997Each product and packaging rotogravure or wide-web flexographic printing affected source at a facility that is a major source of HAP, as defined in 40 CFR 63.2, that applies no more than 400 kg per month, for every month, of organic HAP on product and packaging rotogravure or wide- web flexographic printing presses, on and after the applicable compliance date as specified in §63.826 of this subpart is subject only to the recordkeeping requirements of §63.829(e) and reporting requirements of §63.830(b)(1) of this subpart. The owner or operator is required to maintain records of the total volume and organic HAP content of each material applied on product and packaging rotogravure or wide-web flexographic printing presses during each month for five years, and upon request, submit them to the Administrator.Subpart DDDDD – National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters, was published in the Federal Register on September 13, 2004. This rule will affect all existing, new, or reconstructed industrial boilers, institutional and commercial boilers, and process heaters located at a major source of HAPs, including arsenic, cadmium, chromium, hydrogen chloride (HCl), hydrogen fluoride (HF), lead, manganese, mercury, nickel, and various organic HAPs. The definition of affected source in §63.7490 has been revised to be: (1) the collection of all existing industrial, commercial, or institutional boilers or process heaters within a subcategory located at a major source; and/or (2) each new or reconstructed industrial, commercial, or institutional boiler or process heater located at a major source. Excluded from the rule are combustion units that are subject to another standard under Part 63 or covered by other standards listed in rule. Requirements for affected units will include emissions limits and work practice standards, performance tests or fuel analyses, monitoring and initial notifications. In the final rule, process heater means an enclosed device using controlled flame, that is not a boiler, and the unit’s primary purpose is to transfer heat indirectly to a process material (liquid, gas, or solid) or to heat a transfer material for use in a process unit, instead of generating steam. Process heaters are devices in which the combustion gases do not directly come into contact with process materials. Process heaters do not include units used for comfort heat or space heat, food preparation for on-site consumption, or autoclaves. Boiler means an enclosed device using controlled flame combustion and having the primary purpose of recovering thermal energy in the form of steam or hot water. All four boilers will be subject to this rule. Based on the definition of process heater, it appears that the paper machines drying hoods and the PO-1 tunnel dryer will not be affected units. PERMIT MEMORANDUM 99-113-TV DRAFT 60Testing was conducted on January 7-9, 2003, for B-2, May 20-21, 2003, for B-3, and April 15- 16, 2003, for B-4, to demonstrate initial compliance with the recently promulgated Subpart DDDDD MACT. All emissions rates were in compliance with this section for coal combustion.CAM, 40 CFR Part 64 [Not Applicable] This part applies to any pollutant-specific emission unit at a major source that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses “large emissions units,” or any application that addresses “large emissions units” as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of the following criteria. It is subject to an emission limit or standard for an applicable regulated air pollutant  It uses a control device to achieve compliance with the applicable emission limit or standard  It has potential emissions, prior to the control device, of the applicable regulated air pollutant of 100 TPYBoilers B-2, B-3, and B-4 use control devices to achieve compliance with the particulate matter standards of NSPS Subpart D and OAC 252:100-19. Potential pre-control emissions from these units equal or exceed major source levels (100 TPY of a regulated pollutant or 10/25 TPY of a HAP), but they are not large emissions units since post-control emissions do not equal or exceed 100 TPY. They will be subject to CAM upon renewal of the Title V permit.Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] The emissions units subject to this determination do not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: www.epa.gov/ceppo.Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart F Applicable] These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A applies to any person that produces, transforms, destroys, imports or exports a controlled substance or imports or exports a controlled product. It identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phase- out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. PERMIT MEMORANDUM 99-113-TV DRAFT 61A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, 2030. The facility does not conduct any of the affected processes and is therefore not subject to this rule. Subpart F applies to any person servicing, maintaining, or repairing appliances. This subpart also applies to persons disposing of appliances, including small appliances and motor vehicle air conditioners. In addition, this subpart applies to refrigerant reclaimers, technician certifying programs, appliance owners and operators, manufacturers of appliances, manufacturers of recycling and recovery equipment, approved recycling and recovery equipment testing organizations, persons selling class I or class II refrigerants or offering class I or class II refrigerants for sale, and persons purchasing class I or class II refrigerants. The purpose of this subpart is to reduce emissions of class I and class II refrigerants and their substitutes to the lowest achievable level by maximizing the recapture and recycling of such refrigerants during the service, maintenance, repair, and disposal of appliances and restricting the sale of refrigerants consisting in whole or in part of a class I and class II ODS in accordance with Title VI of the Clean Air Act. The facility performs maintenance that involves recycling and recovery of refrigerants. Standards Conditions included in the permit address required work practices to be used during the maintenance, service, repair, or disposal of appliances, leak repair requirements, standards for recycling and recovery equipment, technician certification, and record-keeping requirements. Additional applicable requirements are found in the rule.SECTION IX. COMPLIANCETesting Testing of the boilers for initial compliance with 40 CFR 60 Subpart D was performed for each fuel fired. Additional testing in anticipation of 40 CFR 60 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters, was conducted on January 7-9, April 15-16, May 16-17, 20-21, 2003. Details of this testing are contained in the discussion of emissions in this memorandum.Inspection The facility was inspected on January 24, 2001, by David Pollard of AQD, accompanied by Stephen Landers, an employee of the Georgia-Pacific – Fort James Operating Muskogee facility. The facility appeared to have been constructed and operated as presented in the application.Tier Classification and Public ReviewThis application has been classified as Tier II based on the request for an operating permit for a major source for which a Title V operating permit is required. The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the land.The applicant published a “Notice of Filing a Tier II Application” in the Muskogee Daily Phoenix & Times-Democrat, a daily newspaper in the City of Muskogee, Muskogee County, on March 3, 1999. The notice stated that the application was available for public review at the PERMIT MEMORANDUM 99-113-TV DRAFT 62Muskogee County Health Department, 530 S. 34th St., Muskogee, Oklahoma. It also gave the address of the DEQ Air Quality Division office in Oklahoma City.This facility is not located within 50 miles of the border of Oklahoma and any other state. No comments were received from the public. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page at http://www.deq.state.ok.us.Fee PaidOn March 5, 1999, an initial Title V permit application fee of $2,000 was received. On November 9, 1999, a check in the amount of $1,000 submitted with an application to incorporate the use of VOC-containing enhancement chemicals in the paper machines was received. On December 1, 2000, a check in the amount of $1,500 submitted with a request to incorporate the use of propane as a secondary fuel for paper machines PM-11, PM-12, and PM-13 was received. The two requested changes have been incorporated as revisions to the Title V application at a fee of $500 each.Total fees due for the Title V permit and the two requested modifications are $3,000. The applicant will be refunded the excess fees of $1,500.SECTION X. SUMMARYThis facility was constructed as described in the application. There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance of the Title V operating permit is recommended contingent on public and EPA review. PART 70 PERMITAIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON STREET, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA 73101-1677Issuance Date: Permit Number: 99-113-TVFORT JAMES OPERATING COMPANY, having complied with the requirements of the law, is hereby granted permission to operate the Muskogee Paper Mill located at 4901 Chandler Road, Muskogee, Okalhoma, Muskogee County, having the legal description of Section 33 & W/2 Section 34, T15N, R19EIM subject to the following conditions, attached:[X] Standard Conditions dated October 15, 2003 [X] Specific ConditionsThis permit shall expire five K years from the issuance date, except as Authorized under Section VIII of the Standard Conditions.______Director, Air Quality Division DRAFTPERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONSGeorgia Pacific Company Permit No. 99-113-TV Fort James Operating CompanyThe permittee is authorized to operate in conformity with the specifications submitted in the application for an operating permit on March 5, 1999, and the additional information submitted on September 23 and November 9, 1999; December 1, 2000; February 16, November 2, and November 11, 2001; May 16, June 3, and July 11, 2002; November 6, 2003; May 27, September 1, and September 23, 2004. The Evaluation Memorandum dated October 11, 2004, explains the derivation of applicable permit requirements and the estimates of emissions, however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein.1. Points of emission and emissions limitations. [Permit No. PSD-OK-404], [OAC 252:100-8-6(a)(1)]Where two emission limits with different bases are given for a single emission point and pollutant, the source shall not exceed either limit at any time.EUG 1 – Subpart D Boilers EU ID Manufacturer & Rating Fuels Controls Construct Serial Number (MMBtu/hr) Date B-1 Zurn 310 Gas/Oil None 1975 B-2 Babcock & 440 Coal/Gas/Oil Electrostatic 1975 Wilson Precipitator B-3 Combustion 557.11 Coal/Gas/Oil Baghouse 1978 Engineering Filter B-4 Riley 557.11 Coal/Oil/Gas Baghouse 1981 FilterPermit No. 99-113-TVCO HCL H2SO4 HF (TPY) (TPY) (TPY) (TPY) B-1 136.87 NA NA NA B-2 194.26 27.75 39.32 13.88 B-3 97.59 87.73 8.78 2.93 B-4 204.93 96.61 11.71 2.93 SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 2All Boilers – 40 CFR 60 Subpart D, OAC 252: 100-25, 31, & 33 StandardsOpacity PM SO2 NOX (lbs/MMBTU) (lbs/MMBTU) (lbs/MMBTU) Coal 20/27 0.10 1.2 0.70 Fuel Oil 20/27 0.10 0.80 0.30 Natural Gas 20/27 0.10 0.2 0.20 Fuel Mixtures 20/27 0.10 OAC 252:100-31 40 CFR 63, Subpart DA. Boilers B-1, B-2, B-3, B-4. [OAC 252: 100-4], [40 CFR, 60, Subpart D] The facility is subject to Subpart D, Standards of Performance for Fossil-Fuel-Fired Steam Generators for Which Construction is Commenced After August 17, 1971. The permittee shall comply with all applicable requirements including standards, emission and fuel monitoring, test methods and procedures.B. Boilers B-1, B-2, B-3, B-4. [40 CFR, 63, Subpart DDDDD] The facility shall comply with any applicable requirements including, but not limited to standards, emission and fuel monitoring, test methods and procedures, and recordkeeping and reporting.C. Additional limitations for Boilers B-1, B-2, B-3, and B-4. [Permit Nos. 81-066-C&O, PSD-OK-404, 75-053-C&O, and 77-076-C&O]Compliance with the emissions limits specified in the following table shall be demonstrated by the initial testing requirements of 40 CFR Part 60 Subpart D, upon the first firing of each fuel. These requirements have been met for firing coal.Permit No. PSD-OK-404Fuel NOX CO SO2 PM VOC Opacity B-4 Coal (lb/hr) 389.98 32.37 688.53 55.71 9.71 10% Coal (lb/MMBtu) 0.7 0.06 1.2 0.10 0.017 Oil (lb/hr) 167.1 18.8 409.2 37.7 3.8 10% Oil (lb/MMBtu) 0.3 0.034 0.734 0.068 0.007 Gas (lb/hr) 111.4 46.8* 0.4 2.8 3.1* No Visible Gas (lb/MMBtu) 0.2 0.084* 0.001 0.005 0.0055* Emissions * Updated from AP-42 , Tables 1.4-1 and 1.4-2, Rev. 7/98 SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 3EUG 2 – Combustion Sources Not Subject to NSPS or NESHAP EU ID Manufacturer & Serial Burners Fuels EU Burner Number (MMBtu/hr) Construct Replace PM-11 Kinedizer 27M 2 - 24 (48) Gas/Oil/ 1975 1999 Propane PM-12 Oven-Pak EB6 Model 400 2 - 16.5 (33) Gas/Oil/ 1975 2003 Propane PM-13 Oven-Pak EB6 Model 400 2 - 16.5 (33) Gas/Oil/ 1979 2002 Propane PM-14 Combustifume 2 - 24 (48) Oil/Gas 1981 1981 PM-15 LV-85 2 - 25 (50) Gas 1992 1992 PO-1 Oven-Pak EB3 2.0 Gas 1984 NA PO-1 Catalytic Incinerator 2.0 Gas 1984 NA Power Output DG-1 Marathon Electric, Magna One, 1,200 KW Diesel 1982 NA Model# 683 FDR8126GG W, Serial # LM-93152-11/20 w/ Catepillar engine, Serial# 24Z00499 DG-2 Marathon Electric, Magna One, 1,200 KW Diesel 1982 NA Model# 683 FDR8126GG W, Serial # LM-93152-11/13 w/ Catepillar engine, Serial# 24Z00501Permit No. 99-113-TVNOX CO PM-11 36.04 21.19 PM-12 24.78 14.57 PM-13 24.78 14.57 PM-14 36.04 17.66 PM-15 26.28 18.40 PO-1 0.88 0.74All Paper Machines – OAC 252: 100-25, 31, & 33 StandardsOpacity PM SO2 NOX (lbs/MMBTU) (lbs/MMBTU) (lbs/MMBTU) Fuel Oil 20/60 0.10 0.80 0.30 Natural Gas 20/60 0.10 0.2 0.20D. Additional limitations for Paper Machine PM-14. [Permit No. PSD-OK-404] Compliance with the emissions limits specified in the following table shall be demonstrated by the initial testing requirements of 40 CFR Part 60 Subpart D, upon the first firing of fuel oil. Permit No. PSD-OK-404 SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 4PM-14 Fuel NOX CO SO2 PM VOC Opacity 48 MMBTUH Oil (lb/hr) 14.4 1.7 18.9* 1.2* 0.4 No Visible Oil (lb/MMBtu) 0.3 0.036* 0.393* 0.024* 0.008 Emissions Gas (lb/hr) 5.8 4.03* 0.1 0.36* 0.26* No Visible Gas (lb/MMBtu) 0.12 0.084* 0.002 0.0076* 0.0055* Emissions * Updated from AP-42 , Tables 1.4-1 and 1.4-2, Rev. 7/98EUG 3 – Subpart Y Coal Preparation Plant EU Name Manufacturer/Model# Construct Date Railcar Unloading FEECO 1991, est. Radial Stacker FEECO 1991, est. Grizzly Feeder FEECO / Fairfield 1991, est. Coal Sizer/Crusher Gundlach / Model#56-DA-1294 1977, est. Conveyor Manufactured on-site by Fort Howard 1977, est. B-2 Coal Bunkers B&W 1975, est. B-2 Coal Feeders Stock Equipment Co./ Gravimetric Feeder 1975, est. B-2 Pulverizers B&W / EL50 Ball Mill 1975, est. B-3 Coal Bunkers CE 1978, est. B-3 Coal Feeders Stock Equipment Co. / Gravimetric Feeder 1978, est. B-3 Pulverizers CE / Bowl Mill 533ARB 1978, est. B-4 Coal Bunkers Riley 1981, est. B-4 Coal Feeders Merrick / Coalometer 1981, est. B-4 Pulverizers Riley / 556 Hammer Mill 1981, est.40 CFR 60 Subpart Y & OAC 252:100-25 Opacity Standards EU Name Opacity Limit Basis For Limit Railcar Unloading 20% Subpart Y, OAC 252:100-25 Radial Stacker 20% Subpart Y, OAC 252:100-25 Grizzly Feeder 20% Subpart Y, OAC 252:100-25 Coal Sizer/Crusher 20% Subpart Y, OAC 252:100-25 Conveying 20% Subpart Y, OAC 252:100-25 Coal Bunkers 20% Subpart Y, OAC 252:100-25 Coal Feeders 20% Subpart Y, OAC 252:100-25 Pulverizers 20% Subpart Y, OAC 252:100-25E. Subpart Y Coal Preparation Plant. [OAC 252:100-4], [40 CFR 60 Subpart Y] i. The facility is subject to 40 CFR 60, Subpart Y, Standards of Performance for Coal Preparation Plants. The permittee shall comply with all applicable requirements including standards, monitoring and test methods. ii. Throughput of coal fuel shall not exceed 519,362 TPY, 12-month rolling cumulative. EUG 4 – PP-1 Pulp Processing Units (Subpart S Affected/No Applicable Standards) EU Name Construct Date Pulpers (not system specific) 1977, 1979, 1981, 1983, 1992, est. Unbleached Stock Blend Tanks 1977 & 1983, est. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 5Screens 1977, 1979, 1981, 1983, & 1992, est. Unbleached Washers 1977, est. Flotation Cell Washers 1977, 1979, 1981, 1983, & 1992, est. Unbleached Thickener 1977 & 1992, est. Bleached Washers 1977, 1981, 1983, 1992, est. Storage (not system specific) 1977, 1979, 1981, 1983, 1992 est.Bleach Towers 1977, 1979, 1981, 1983, 1992, est. Thickeners 1979, 1981, 1983, est. Unbleached Stock Presses 1992, est. Mixers 1992, est. Cleaners 1992, est.G. PP-1 Pulp Processing Units (Subpart S Affected/No Applicable Standards) i. Pollutants authorized from this EUG are listed in EUG 6. These units are affected facilities under 40 CFR, Part 63, Subpart S, National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry. No standards in the subpart currently apply to the facility. ii. The permittee shall not conduct kraft, soda, sulfite, or semi-chemical pulping processes using wood. iii. The facility shall not use chlorine or chlorine dioxide to bleach pulp. The use of these bleaching agents shall make the facility subject to the standards of 40 CFR, Part 63, Subpart S and require submittal of an application for a permit modification. iv. The facility is subject to the emissions limitations and standards of OAC 252:100-41, as specified in EUG 6 of this permit.EUG 5 – 40 CFR 63 Subpart KK Flexographic Printing EU ID EU Name Manufacturer/Model No. Construct Date PO-1 Flexographic Paper Converting Machine Company 1984 Polyethylene Printer (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer FP-1 Flexographic Paper Flexo 21-182 – PCMC/ Model No. 6724 1983 Printer Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 FP-7 Flexographic Paper Flexo #7 – PCMC/Model No. 6726 1997 Printer H. All presses, Subpart KK Flexographic Printing. [40 CFR 63 Subpart KK] i. EUG 5 is subject to Subpart KK - National Emission Standards for the Printing and Publishing Industry. The permittee shall comply with all applicable requirements. ii. The application of organic HAP on product and packaging rotogravure or wide-web flexographic printing presses is limited to no more than 400 kg per month, for every month. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 6 iii.EUG 5 is subject only to the recordkeeping requirements of §63.829(e) and reporting requirements of §63.830(b)(1) of this subpart. The owner or operator is required to maintain records of the total volume and organic HAP content of each material applied on product and packaging rotogravure or wide-web flexographic printing presses during each month for five years, and upon request, submit them to the Administrator.EUG 6 – VOC Sources Subject to OAC 252:100-41 EU ID EU Name Manufacturer/Model# Construct Date PP-1 Pulp Processing Units All components listed in EUG 4 1977-1992 PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 Paper Machine Additives NA SC-1 Solvent Cleaning PM-11, NA 1975 PM-12, PM-13, PM-14 PM-15 Solvent Cleaning NA 1992 PO-1 Flexographic Polyethylene Gloucester Engineering, Model #264-001, 1983 Extruder Serial #264-28879-001 Corona Treater Enercon, Model ASO12V-160 June, 1984 Corona Treater Enercon, Model ASO41V-300 June, 1984 w/Decomposer Model 03X-16 Flexo-plate making Anderson-Vreeland June, 1984 Flexographic Polyethylene Paper Converting Machine Company June, 1984 Printer (PCMC), Model No. 6795, 6-color w/ vapor collection hood and tunnel dryer FP-1 Flexographic Paper Printers Flexo 21-182 – PCMC/ Model No. 6724 1983 (six) Flexo 31-001 – Fort Howard 1980 Flexo 31-002 – Fort Howard 1980 Flexo 31-003 – Fort Howard 1980 Flexo 31-005 – PCMC/Model No. 6992 1990 Flexo 31-008 – PCMC/Model No. 7416 1993 FP-7 Flexographic Paper Printer Flexo #7 – PCMC/Model No. 6726 1997Permit No. 99-113-TV - based on MAAC Limitations of Select Pollutants PP-1 Paper Pulping Air Toxic CAS # Emissions, TPY 1,2-dimethoxyethane 110714 0.05 Acetaldehyde 75070 12.16 Biphenyl 92524 20.09 Chloroform 67663 39.61 SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 7Limonene 5989275 0.04 Methanol 67561 33.95 methyl ethyl ketone 78933 0.57 Naphthalene 91203 0.54 Phenol 108952 2.04 Propionaldehyde 123386 0.26 Toluene 108883 13.86 Permit No. 99-113-TV - based on MAAC Limitations of Select Pollutants Paper Machines Air Toxic CAS # Emissions, TPYAcetaldehyde 75070 8.08 Biphenyl 92524 26.40 Chloroform 67663 4.04 Formaldehyde 50000 0.01 Methanol 67561 19.13 Methyl ethyl ketone 78933 0.02 methylene chloride 74873 0.30 Phenol 108952 5.66 Propionaldehyde 123386 0.01 Toluene 108883 0.70Permit Nos. 99-113-TV & 91-127-O (M-1) Emission Unit Emission Factor VOC (lbs/lb VOC content) Emissions (TPY) Paper Machine Additives 60% 25.0 SC-1: Solvent Cleaning PM-11, PM-12, PM-13, PM-14 60% 179.1 Solvent Cleaning PM-15 60% 37.57Permit No. 83-062-O (PSD) Source Power Emission Ozone Input Factor Emissions Lbs/hr TPY Enercon Corona Treater Model ASO12V-160 5 Kva 0.073 0.365 1.599 lbs/Kva Enercon Corona Treater Model ASO41V-300 10 Kva 0.073 0.0365 0.1599 with Decomposer Model 03X-16 lbs/Kva SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 8Non-HAP VOCs: Permit Nos. 99-113-TV, 97-218-C & 83-062-O (PSD) Emissions Unit Emission Control Emissions Factor Efficiency (TPY) PO-1 Flexographic Printer Uncontrolled 30% NA 99.0 * Controlled 70% 96.8% *** 7.4 FP-1/Flexographic Paper No Control 92.28 Printer (six printers) FP-7/Flexographic Paper No Control 0.98 ** Printer * Permit 83-062-O (PSD), Combined with PO-1 Platemaking emissions. ** Permit 97-218-C, Combined with FP-1 emissions. *** Catalytic IncineratorI. Non-HAP VOC emissions are subject to the requirements of OAC 252:200-41. [OAC 252:100-41] i. Any Toxic Air Contaminant emitted at levels exceeding the de minimis threshold established by OAC 252:100-41 shall be in compliance with the Maximum Acceptable Ambient Concentration established by OAC 252:100-41. ii. In the event an exceedance of a Toxic Air Contaminant de minimis threshold occurs, the permittee shall submit modeling performed to demonstrate compliance with the MAAC. iii.Any event of a release which results in excess emissions shall be reported in accordance with the requirements of OAC 252:100-9 (Excess Emissions Reporting Requirements). iv. The facility shall maintain written documentation to show compliance with all current Federal, State and Local Regulations, Rules, and Codes, including modeling where compliance with a MAAC may be in question. v. Emissions of any new Category A Toxic Air Contaminant above the de minimis level will require a Best Available Control Technology review and submittal of an application for a permit modification.J. PP-1 Paper Pulping and Paper Machines PM-11, PM-12, PM-13, PM-14, and PM- 15. i. The HAP/TAC pollutants listed above are authorized in emissions from the pulp processing units and paper machines. ii. Emissions from the pulping systems shall be based on total combined finished pulp stock and the emissions factors developed in for the permit application, based on a 12-month rolling cumulative. iii. Emissions from the paper machines shall be based on total combined annual throughput of finished paper and the emissions factors developed for the permit application. Total throughput of finished paper stock per paper machine is limited to the maximum capcities submitted in the permit application. iv. The permittee shall not cause or allow the emission of any toxic air contaminant in such concentration as to cause or contribute to a violation of the MAAC. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 9K. Paper Machine Additives and Solvent Cleaning of PM-11, PM-12, PM-13, PM-14. i. Emissions from Paper Machine Additives are emissions from VOC-containing paper enhancement chemicals including dyes, softness aids, and biocides. Emissions of VOCs from the use of paper machine additives shall not exceed 25 TPY, 12-month rolling cumulative. ii. Emissions of VOCs from solvent cleaning of Paper Machines PM-11, PM-12, PM- 13, and PM-14 shall not exceed 179.1 TPY, 12-month rolling cumulative. iii.Emissions shall be calculated based on the total VOC content of each additive or cleaner material used and a 60% release factor.L. Limitations for Solvent Cleaning of Paper Machine Paper PM-15. [Permit No. 91-127-O (M-1)] i. The usage of wire and felt cleaning solvents on Paper Machine 15 shall be limited to 340 pounds per day based on a monthly rolling average. The cleaning solvent shall not exceed 3.22 pounds per gallon (ppg) 1,2,4-trimethylbenzene, 7.0 ppg xylene, 7.0 ppg naphthalene, nor 6.44 ppg cumene. The allowable portion of all other volatile organic components of cleaning solvents shall be calculated by the following formula:Allowable Portion (ppg) = (MAAC / 26,553 g/m3) * (7.0 ppg /0.6) where “MAAC” means Maximum Acceptable Ambient Concentration ii. VOC emissions from the solvent used to clean the wires and felts on the No. 15 paper machine shall not exceed 37.57 tons per year based on a 12-month rolling cumulative. The permittee shall maintain a daily and monthly record of solvent used on No. 15 Paper Machine. The records shall include the number of gallons of each solvent used, the density of the solvent in lbs/gal (ppg), and the weight fraction of VOCs in the solvent (expressed as a percentage). The permittee shall use these records to calculate the total average monthly VOC emissions, in accordance with the following formula:E = G x D x F x 0.6Where: E = total pounds VOC emitted from solvent use on PM 15 during a calendar month G = gallons solvent used on paper machine No. 15 during month D = paper machine solvent density in lbs/gal (ppg) F = weight fraction of VOCs in paper machine solvent 0.6 = fraction of VOCs being emitted from solvent use on paper machineM.PO-1 Polyethylene Extruder SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 10Emissions of VOCs from the polyethylene extruder shall be limited to 0.024 TPY, based on a 12-month rolling cumulative. Raw material used in the polyethylene extruder shall not exceed an annual throughput of 6,000,000 pounds per year, 12-month rolling cumulative.N. Printers PO-1, FP-1, and FP-7. Total emissions of VOCs from each of the printer systems is limited to the amounts specified in the above table as allowed by Permit Nos. 97-218-C & 83-062-O (PSD) for FP-7 and PO-1 and supplemented by this permit for FP-7. i. Emissions calculations shall be based on mass balance, considering the VOC content of the inks. Emissions from the PO-1 Flexographic Printer shall be prorated into uncontrolled and controlled using factors of 30% and 70%, respectively. ii. The Enercon, Model ASO41V-300 shall only be operated with a properly functioning Model 03X-16, Decomposer. iii.The corona treaters may be replaced with equipment having equal or lesser emissions and not subject to an NSPS, NESHAP, or MACT.O. Additional limitations for the Press P-7. [Permit No. 97-218-C] i. Total VOC emissions from ink usage on press FP-7 shall not exceed a cumulative of 0.98 tons per year based on a 12-month rolling cumulative period. VOC emissions from ink usage on press P-7 shall not exceed 1.17 lbs/hr. Compliance with the 1.17 lbs/hr limitation shall be demonstrated by dividing the total VOC emissions form P-7 for each calendar month by the total number of hours the equipment was used in that month.P. Additional limitations for the PO-1 Flexographic Printing Press and Platemaking. [Permit No. 83-062-O (PSD)] i. The permittee is authorized to use both corona treaters at the same time. ii. Total VOC emissions from ink and solvent usage (combined with the PO-1 Flexo- platemaking from EUG 6) shall not exceed 8.25 tons per month based on a 12-month rolling average, nor shall VOC emissions exceed 99 TPY based on the previous 12 months usage of ink and solvent. iii.Usage of the following VOC materials and emissions is authorized in platemaking.Permit No. 83-062-O (PSD) Product Product Usage VOC Content VOC Emissions (lbs/yr) (Wt. %) (TPY) Petroleum Solvent 2,456.5 100 1.2283 Aliphatic Alcohol 2,456.5 100 1.2283 n-Propyl Acetate 441.0 100 0.2205EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP EU ID EU Name Manufacturer/Serial # Construct Date SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 11FS-1 Coal Pile NA 1975 PM-11 Paper Machine #11 KMW 1975 PM-12 Paper Machine #12 KMW 1975 PM-13 Paper Machine #13 KMW 1979 PM-14 Paper Machine #14 Beloit 1981 PM-15 Paper Machine #15 Beloit 1992 PO-1 Polyethylene ExtruderEU ID Emissions Throughput Control PM Emissions Factor (hectares) Efficiency (TPY) (kg/hectare-day) FS-1 8.5 3.2515 None 11.11Permit No. 99-113-TV Control PM Emissions Efficiency (TPY) PM-11 None 9.31 PM-12 None 13.03 PM-13 None 11.17 PM-14 None 11.17 PM-15 None 10.29Permit No. 99-113-TV – Polyethylene Extruder Factor Polyethylene Emissions (lbs/MMlb) Throughput (TPY) (MMlbs/yr) PM – Resin Storage & Handling 0.017 6.0 0.51 PM – Extruder 2.4 6.0 0.0072Q. FS-1 Coal Pile. Coal fuel storage shall not exceed a total combined surface area of 3.2515 hectares, 12- month rolling cumulative monthly average (12-month rolling cumulative divided by 12).R. Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15. Total combined annual throughput of finished paper stock shall not exceed the amount in tons per year submitted in the permit application, based on a 12-month rolling cumulative basis.Permit No. 99-113-TV – Polyethylene Extruder Factor Polyethylene Emissions (lbs/MMlb) Throughput (TPY) (MMlbs/yr) SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 12PM – Resin Storage & Handling 0.017 6.0 0.51 PM – Extruder 2.4 6.0 0.0072S. PO-1 Polyethylene Extruder Raw material used in the polyethylene extruder shall not exceed an annual throughput of 6,000,000 pounds per year, 12-month rolling cumulative.2. Initial Testing requirements. [OAC 252:100-8-6(a)(1)], [OAC 252:100-43] a. Boilers B-1, B-2, B-3, and B-4. [40 CFR 60 Subpart D] i. The boilers are subject to §60.46, test methods and procedures, when firing a fuel not previously tested for initial compliance and evaluation of monitoring. ii. In conducting the performance tests required in §60.8, the owner or operator shall use as reference methods and procedures the test methods in appendix A of this part or other methods and procedures as specified in this section, except as provided in §60.8(b). Acceptable alternative methods and procedures are given in paragraph (d) of §60.46. b. Additional requirements for Boiler B-4 and Paper machine PM-14. [Permit No. PSD-OK-404] i. Upon the first firing of fuel oil, compliance with the emission limitations shall be determined by the permittee using test methods and procedures as set out in 40 CFR Part 60 Appendix A: Method 7, Determination of Nitrogen Dioxide Emissions from Stationary Sources; Method 10, Determination of Carbon Monoxide Emissions from Stationary Sources; Method 6, Determination of Sulfur Dioxide Emissions from Stationary Sources; Method 5, Determination of Particulate Emissions from Stationary Sources; Method 25, Determination of Total Gaseous Nonmethane Organic Emissions as Carbon; and Method 9, Visual Determination of the Opacity of Emissions from Stationary Sources. ii. During the initial performance test for Paper Machine PM-14, carbon monoxide, particulate matter, and volatile organic compound testing will not be required while firing oil. iii. During the initial performance test for Boiler B-4, sulfur dioxide, particulate matter, and volatile organic compound testing will not be required by the permitting authority while firing natural gas. iv. Permittee shall be exempt from initial performance testing while firing oil until such time that the emission points actually begin firing this fuel. v. The permittee shall conduct the required performance testing within 60 days from the time Paper Machine PM-14 and/or Boiler B-4 have been fired with oil for a period not exceeding 96 cumulative hours in conformance with the Specific and General Conditions of this permit. The permittee shall be allowed an additional mechanical checkout period not exceeding 16 hours in length. vi. Should any combustion equipment modifications be made such as different type burners, combustion air relocation, fuel conversion, tube removal or addition, etc., then emission correlations as described in the attachment to Permit No. PSD-OK- 404 titled “Use Of Flue Gas Oxygen Meter As BACT For Combustion Controls,” and/or 40 CFR 60 Subpart D, or more recently published and accurate EPA methodology shall be conducted within 60 days of attaining full operation after SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 13 such modification. Results of all emission determinations shall be sent to AQD within 45 days after completion of the test. c. Additional requirements for Boiler B-4 and Paper machine PM-14. [General Conditions, Permit No. PSD-OK-404] i. The permittee shall notify the permitting authority in writing of the actual start-up of the permitted source within 30 days of such action and the estimated date of demonstration of compliance as required in the specific conditions. ii. Each emission point for which an emission test method is established in this permit shall be tested in order to determine compliance with the emission limitations contained herein within sixty (60) days of achieving the maximum production rate, but in no event later than 180 days after initial start-up of the permitted source. The permittee shall provide (1) sampling ports adequate for test methods applicable to such facility, (2) safe sampling platforms, (3) safe access to sampling platforms, and (4) utilities for sampling and testing equipment.3. Monitoring Requirements. [OAC 252:100-43], [OAC 252:100-4], [40 CFR 60 Subpart D], [Permit Nos. 75-053-C&O, 77-076-C&O, 79-021-C&O, 81-066-C&O, 81-081-C&O, 83-062-O (PSD), PSD-OK-404, and 91-127-O (M-1)]Fuel Standards. Fuel standards to ensure continued compliance with the applicable permit limit are taken from the applicable permit and/or the permit application as submitted by the applicant to meet compliance with applicable air quality standards at the time of permit issuance. a. All equipment. i. When fired on natural gas, equipment shall be fired with only commercial natural gas having a sulfur content no greater than 159 ppmv. b. Boilers B-1, B-2, B-3, and B-4. i. Boiler B-1 shall be fired with only natural gas or No. 2 fuel oil. ii. When firing coal, Boilers B-2, B-3, and B-4 shall be fired on low sulfur, class III sub- bituminous coal, group “B” and “C” coals as classified by ASTM-STD D-388, having a sulfur content no greater than 0.33% by weight and an ash content no greater than 4.76% by weight. (1) Boiler B-4 may also be fired on Oklahoma low sulfur coal having a fuel sulfur content no greater than 0.55% by weight and an ash content no greater than 13.0% by weight. iii. When firing oil: (1)Boilers B-1 and B-2 shall be fired on No. 2 fuel oil having a fuel sulfur content no greater than 0.5% by weight and an ash content no greater than 0.01% by weight. (2)Boiler B-3 shall be fired on No.2 or No. 6 fuel oils having a fuel sulfur content no greater than 0.71% by weight and an ash content no greater than 0.024% by weight. (3)Boiler B-4 shall be fired on No.2 or No. 6 fuel oils having a fuel sulfur content no greater than 0.66% by weight and an ash content no greater than 0.024% by weight. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 14 c. Paper Machines PM-11, PM-12, PM-13, PM-14, and PM-15. i. When firing oil: (1)Paper Machines PM-11, PM-12, and PM-13 shall be fired on No.2 fuel oil having a fuel sulfur content no greater than 0.3% by weight, an ash content no greater than 0.01% by weight, and an API gravity not less than 32º. (2)Paper Machine PM-14 shall be fired on distillate fuel oil having a fuel sulfur content no greater than 0.35% by weight or an ash content no greater than 0.025% by weight. ii. Paper Machine PM-15 paper machine shall only burn commercial-grade natural gas. iii. The use of propane as backup fuel is authorized for Paper Machines PM-11, PM- 12, and PM-13. d. PO-1 Catalytic Oxidation Incinerator and Flexographic Printing Press Tunnel Dryer. [Permit No. 83-062-O (PSD)] i. The tunnel dryer and catalytic oxidation incinerator shall be fueled only with commercial pipeline-grade natural gas. ii. The catalytic oxidation incinerator inlet gas temperature shall be continuously monitored by a shutdown switch that will shut down the press should the temperature drop below 550F. To document its proper operation, the permittee shall record the before (Thermocouple T/C 1) and after (Thermocouple T/C 2) catalytic cell temperature daily. The catalyst shall be evaluated at least annually to ensure it is within the manufacturer’s specifications. e. Emergency Generator units DG-1 and DG-2. i. Emergency Generator units DG-1 and DG-2 shall be fired on No.2 fuel oil having a fuel sulfur content no greater than 0.35% by weight.Fuel Sampling & Analyses a. All boilers, B-1, B-2, B-3, & B-4, & Paper Machines, PM-11, PM-12, PM-13, PM-14. i. Coal shall be continuously sampled as it is crushed at the mine to provide a gross sample representative of the fuel consumed during a boiler operating day. ii. Fuel oil shall be sampled for each load delivered. iii. Fuel oil and coal shall be analyzed for percent sulfur content and gross calorific value using the most recent ASTM methods for sample preparation, sulfur analysis, and gross calorific value determination. Coal shall be analyzed on a dry basis using the most recent ASTM method for moisture analysis. iv. The fuel supplier’s certification of these analyses may be accepted by AQD.Continuous Opacity Monitoring. a. Boilers B-1, B-2, B-3, and B-4. [40 CFR 60 Subpart D] SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 15 i. The permittee is required to have installed, and to maintain and operate a continuous opacity monitoring system as required by §60.45, for Boilers B-2, B-3, and B-4, for the firing of coal. Boiler B-1 fires natural gas and was not required to install opacity monitoring. ii. Monitoring requirements for all boilers, B-1, B-2, B-3, and B-4, will have to be re- evaluated for monitoring requirements in accordance with of §60.45, when using the alternate fuels authorized by Specific Condition No. 1. b. Additional requirements for Boiler B-3. [Permit No. 77-076-C] i. The permittee shall operate and maintain continuous recording opacity monitoring equipment for Boiler B-3 while firing coal or oil. The monitoring shall comply with the specifications of 40 CFR, Part 60, Appendix B, Performance Specification 1 – Performance Specifications and Specification Test Procedures for Transmissometer Systems for Continuous Measurement of the Opacity of Stack Emissions. The continuous monitoring data may, at the discretion of the permitting authority, be used to determine violations of the conditions of this permit. c. Boiler B-4 and Paper machine PM-14. [EPA Letters dated April 9 and May 7, 1987] [Specific and General Conditions, Permit No. PSD-OK-404] i. The permittee shall operate and maintain the continuous recording opacity monitoring equipment for Boiler B-4 while firing coal or oil. The monitoring shall comply with the specifications of 40 CFR, Part 60, Appendix B, Performance Specification 1 – Performance Specifications and Specification Test Procedures for Transmissometer Systems for Continuous Measurement of the Opacity of Stack Emissions. The continuous monitoring data may, at the discretion of the permitting authority, be used to determine violations of the conditions of this permit. ii. The permittee shall conduct EPA Method 9 opacity readings on emissions from Paper Machine PM-14 at a frequency of no less than once daily when firing fuel oil. iii. Continuous monitoring data may, at the discretion of the permitting authority, be used to determine violations of the conditions of this permit. If opacity readings on emissions from Boiler B-4 exceed 10%, testing for VOC emissions may be required. iv. The permittee shall install, operate, and maintain a continuous recording flue gas oxygen monitor on Boiler B-4 to continuously monitor a representative sample of the flue gas in accordance with the attachment to Permit No. PSD-OK-404 titled “Use of Flue Gas Oxygen Meter as BACT for Combustion Controls.” The permittee shall be exempt from this requirement if initial nitrogen oxide performance testing demonstrates less than 70% of the applicable nitrogen oxide standard in accordance with 40 CFR Part 60.45 (b)(3) and (4). v. Fuel oil fired in Paper Machine PM-14 and the coal or fuel oil fired in Boiler B-4 shall be sampled and analyzed by the permittee for sulfur and ash content. The frequency of sampling and analysis shall be as specified in 40 CFR Part 60.45, Emission and Fuel Monitoring. These data may be used, at the discretion of the permitting authority, to determine violations of the emission limitations. Records SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 16 of the test results of each sample shall be made available for inspection by the permitting authority for at least five years. vi. The opacity limits of Specific Condition No. 1 shall apply at all times. vii. The emission of any pollutant more frequently or at a level in excess of that authorized by this permit shall constitute a violation of the terms and conditions of this permit. d. Coal Preparation Plant. [OAC 252:100-25-3 & 43], [40 CFR 60 Subpart Y] i. The requirements of this condition shall not apply to the FS-1 Coal Pile. ii. The permittee shall conduct Method 9 visual observations of emissions from each affected facility or emissions point at least once per week except as authorized below. In no case shall the observation period be less than six minutes in duration. If visible emissions are observed for six minutes in duration for any observation period and such emissions are not the result of a malfunction, then the permittee shall conduct, for the identified points, within 24 hours, a visual observation of emissions, in accordance with 40 CFR Part 60, Appendix A, Method 9. (1)When four consecutive weekly Method 9 observations show no visible emissions, or no emissions of a shade or density greater than twenty percent (20%) equivalent opacity, respectively, the frequency may be reduced to monthly Method 9 visual observations, as above. Upon any showing of non-compliance, the observation frequency shall revert to weekly. (2)If a Method 9 observation exceeds 20% opacity, the permittee shall conduct at least two additional Method 9 observations within the next 24-hours. (3)If more than one six-minute Method 9 observation exceeds 20% opacity in any consecutive 60 minutes; or more than three six-minute Method 9 observations in any consecutive 24 hours exceeds 20% opacity; or if any six-minute Method 9 observation exceeds 60% opacity; the owner or operator shall comply with the provisions for excess emissions during start-up, shutdown, and malfunction of air pollution control equipment. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 17 e. FS-1 Coal Pile. [OAC 252:100-25-3 & 43] The permittee shall conduct Method 22 visual observations of emissions from each coal storage pile at least once per week. In no case shall the observation period be less than six minutes in duration or until visible emissions are observed. If visible emissions are observed for any observation point, then the permittee shall conduct, for the identified points, within 24 hours, a six-minute visual observation of emissions, in accordance with 40 CFR Part 60, Appendix A, Method 9. When discharge points are located inside a building, the VE observations may be done on the building ventilation discharges or other significant discharge points.Equipment Standards. [OAC 252:100-43] a. Baghouses - Boilers B-3 and B-4. i. The pressure across the baghouse filters shall be recorded daily. ii. A visual inspection of each pollution control device shall be performed at a frequency recommended by the manufacturers but no less than weekly. iii. The pollution control devices shall be maintained and operated as recommended by the manufacturers to maintain the required efficiency, including the recommended pressure drop across the filter. iv. The filter(s) shall be replaced on a frequency recommended by the manufacturer, or sooner if necessary. v. The capture system and the housing for the filters shall be constructed and maintained such that no bypass of unfiltered emissions occurs. vi. A complete preventive maintenance inspection of the pollution control device shall be performed semi-annually, or at intervals recommended by the manufacturer, whichever occurs more frequently. vii. In the event of any malfunction of pollution control equipment which results in an exceedance of any permit limit, the permittee shall immediately shut down the affected emissions unit(s) and perform any repairs necessary to restore the performance of the pollution control equipment to the permitted standard(s), prior to returning the emissions units back to production. b. Electrostatic Precipitator (ESP) - Boiler B-2 i. The ESP shall be operated, maintained, and monitored in accordance with the manufacturer’s recommendations, including all operating parameters, to ensure that the system is achieving an overall control efficiency of no less than 99% for emission of PM10. ii. At a minimum, monitoring parameters shall include: (1)Opacity and visible emissions (2)Shifts in resistivity/electrical data across the entire system (3)Changes in electrical data for a single field (4)Rapper conditions (5)Air infiltration4. Hours of Operation. [OAC 252:100-8-6(a)(1)] SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 18 i. The facility is authorized to operate 24-hours per day, every day of the year. ii. Emergency Generator units DG-1 and DG-2 are limited to 1,440 hours total combined operating hours, 12-month rolling cumulative. (1)The generators shall be equipped with meters to measure hours of operation. (2)An operating log shall be maintained to assure compliance with the limit on operating hours.5. Emission Controls. [OAC 252:100-8-6(a)(1)], [OAC 252:100-37] a. All boilers, B-1, B-2, B-3, and B-4. i. The boilers shall be equipped with air-to-fuel controls that limit the heat input ratings to the ratings specified in Specific Condition No. 1. The controls shall be designed, installed, and operated to control the boilers and burners at optimum combustion efficiency. ii. The burners may be replaced upon prior approval of the Air Quality Division provided that it can be demonstrated that the replacement burners are at least as efficient as the previous one(s) in service. The boilers may also be equipped with additional burners upon prior approval of the Air Quality Division, provided the authorized heat input ratings are not exceeded. iii.The air pollution control devices may be modified or replaced, upon prior approval of the Air Quality Division, provided that it can be demonstrated that the replacement equipment is at least as efficient as the previous pollution control device. b. Boilers B-2, B-3, and B-4. [Permit Nos. 75-053-C&O, 77-076-C&O, 81-066-C&O, & PSD-OK-404] i. Emissions from Boiler B-2 shall pass through an Electrostatic Precipitator having 99% removal efficiency for PM10 emissions prior to discharge to the atmosphere. ii. Emissions from Boiler B-3 shall pass through a baghouse having 99.6% removal efficiency for PM10 emissions prior to discharge to the atmosphere. iii.BACT for Boiler B-4 shall consist of the use of low NOX burners and a fabric filter collection system which is capable of maintaining an efficiency of no less than 99.2% for PM10, and the use of low sulfur content coal when fired by coal. Boiler design, efficient equipment operation, and the use of combustion controls shall be utilized to ensure minimization of CO and NOX and to ensure that emissions do not exceed standards. c. Boilers B-1 and B-2. [Permit No. 75-053-C&O] The furnace shall incorporate design features to limit nitrogen oxides to permitted levels. d. Boiler B-3. [Permit No. 77-076-C&O] Boiler design and the use of combustion controls shall be utilized to ensure minimization of NOX and to ensure that emissions do not exceed standards. e. Paper Machine PM-14. Permit Nos. PSD-OK-404 & 81-066-C&O BACT for Paper Machine PM-14 shall consist of the use of low NOX burners and natural gas for the primary fuel and the use of 0.35% sulfur distillate fuel oil as the secondary fuel to limit emissions of SO2 and particulate matter. All other pollutants shall be minimized by proper operation of the unit. f. PO-1 Polyethylene Extruder, Plate Making, and Flexographic Printing Press SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 19[Permit No. 83-062-O (PSD)] i. The tunnel dryer and catalytic oxidation incinerator shall be fueled only with commercial pipeline-grade natural gas. ii. The destruction efficiency of air pollution control equipment shall be maintained by this or alternative systems at no less than 96.8%. The catalytic oxidation incinerator inlet gas temperature shall be continuously monitored by a shutdown switch that will shut down the press should the temperature drop below 550F. To document its proper operation, the permittee shall record the before (Thermocouple T/C 1) and after (Thermocouple T/C 2) catalytic cell temperature daily. The catalyst shall be evaluated at least annually to ensure it is within the manufacturer’s specifications. g. Subpart Y Coal Preparation Plant and FS-1 Coal Pile. [Permit No. 75-053-C&O] Reasonable control procedures shall be taken to minimize the effect of wind-blown particulate matter from the coal unloading facilities and storage piles. i. Compaction, and moisture spray control shall be used for the coal storage piles. ii. Enclosed facilities shall be used for rail car unloading and transfer equipment.6. Reporting Requirements. [OAC 252:100-8-6(a)(3)(B)], [OAC 252:100-43] In addition to any applicable reporting requirements contained in Subparts D and Y Part 60, Subpart M Part 61, Subpart KK Part 63, and OAC 252:100, the permittee is subject to the following reporting requirements incorporated from existing permits. a. Boiler B-4 and Paper Machine PM-14. [General Conditions, Permit No. PSD-OK-404] i. The permittee shall notify the permitting authority in writing of the actual start-up of the permitted [fuel] source within 30 days of such action and the estimated date of demonstration of compliance as required in the specific conditions. ii. The permittee shall notify the permitting authority of the scheduled date of compliance testing at least thirty (30) days in advance of such test. Compliance test results shall be submitted to the permitting authority within forty-five (45) days after the complete testing using the attached format guide titled “Performance Test Report Format.” iii. If, for any reason, the permittee does not comply with or will not be able to comply with the emission limitations specified in this permit, the permittee shall provide the permitting authority with the following information in writing within five (5) days of such conditions: (1)Description of noncomplying emission(s); (2)cause of noncompliance; (3)anticipated time the noncompliance is expected to continue or, if corrected, the duration of the period of noncompliance; (4)steps taken by the permittee to reduce and eliminate the noncomplying emission; and (5)steps taken by the permittee to prevent recurrence of the noncomplying emission. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 20Failure to provide the above information when appropriate shall constitute a violation of the terms and conditions of this permit. Submittal of this report does not constitute a waiver of the emission limitations contained within this permit. iv. Any change in the information submitted in the application regarding facility emissions or changes in the quantity or quality of materials processed that will result in new or increased emissions must be reported to the permitting authority. If appropriate, modifications to the permit may then be made by the permitting authority to reflect any necessary changes in the permit conditions. In no case are any new or increased emissions allowed that will cause violation of the emission limitations specified herein. v. In the event of any change in control or ownership of the source described in this permit, the permittee shall notify the succeeding owner of the existence of this permit by letter and forward a copy of such letter to the permitting authority. b. PO-1 Polyethylene Extruder, Plate Making, and Flexographic Printing Press [Permit No. 83-062-O (PSD)] i. If additional hazardous and toxic air pollutants are emitted from the polyethylene extruder, flexographic platemaking or printing operation, or other related operation, the permittee shall notify Air Quality.7. Each emission unit (EU) listed in EUG 4, PP-1 Pulp Processing Units, shall be clearly labeled with the EU number on the unit in a conspicuous location that can be easily accessed for inspection, considering safety and ease of inspection. For EUG 3, Subpart Y Coal Preparation Plant, only a site drawing which identifies all EUs is required to be maintained at the facility.8. Recordkeeping. The permittee shall maintain records of operations as listed below. These records shall be maintained on-site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:100-8-6(a)(3)(B)] All EUGs a. A material safety data sheet (MSDS) or certified product data sheet which documents the volatile organic solvent content expressed in pounds per gallon of VOC less water and exempt solvents, percentages of water by weight, solids percent by weight, solvent density, and percentage of exempt solvents by weight (if any), of each raw material, including printing inks, cleaning solvents, paper machine additives, and bleaching agents and additives. b. Initial compliance testing of the fuel sulfur content for natural gas and whenever the gas supplier is changed will be used to ensure compliance with this limitation. The supplier’s certification may be accepted by AQD. EUGs 1, 2, and 3 c. Records of fuel analyses, pollution control monitoring/inspection/maintenance, and continuous and Method 9 opacity monitoring required by Specific Condition No. 3 (frequencies for fuel sampling and analyses as required by Specific Condition No. 3). d. Information necessary to document size, ratings or capacities of equipment where specified in Specific Condition No. 1. EUGs 6 and 7 SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 21 e. Dry finished paper stock throughput (12-month rolling cumulative): i. combined cumulative, all pulp processing, Systems 1 through 5. ii. combined cumulative, all paper machines, PM-11 through PM-15. iii. for each paper machine. EUG 5 & 6 f. Records required by 40 CFR 63, Subpart KK. g. Demonstration of compliance for HAP/VOC limitations by the appropriate method specified. h. Usage of VOC-containing raw materials and calculations of VOC emissions based on the authorized emission factors and methodologies (12-month rolling cumulative) for each of the following groups of sources: i. FP-1, all six printers combined total. ii. FP-7. iii. PO-1 Flexographic Printer and Platemaking, combined total. iv. SC-1 solvent cleaning, Paper Machines PM-11 through PM-14. v. Solvent cleaning, Paper Machine PM-15. (1)Daily usage (2)Record of content of 1,2,4-trimethylbenzene, xylene, naphthalene, and cumene, in units of pounds per gallon. (3)The allowable portion of all other volatile organic components contained in cleaning solvents as calculated by authorized methodology, in units of pounds per gallon. (4) Raw material usage and VOC emissions from the solvent used to clean the wires and felts. The records shall include the number of gallons of each solvent used, the density of the solvent in lbs/gal (ppg), and the weight fraction of VOCs in the solvent (expressed as a percentage). The permittee shall use these records to calculate the total average monthly VOC emissions, in accordance with the authorized. EUG 7 i. Dry finished paper stock throughput (12-month rolling cumulative), combined cumulative, all paper machines, PM-11 through PM-15. j. Boiler B-4 and Paper machine PM-14. [Permit No. 81-066-C&O] A file shall be maintained on-site containing all measurements including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks and adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR Part 60. This information shall be recorded in a permanent form suitable for inspection and shall be retained for at least five years following the date of such measurements, maintenance, reports and records.9. The following records shall be maintained on-site to verify Insignificant Activities. No recordkeeping is required for those operations which qualify as Trivial Activities. [OAC 252:100-8-6 (a)(3)(B)] SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 22 a For fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day: daily throughput, averaged over a 30- day period. b. For fluid storage tanks with a capacity of 10,000 gallons or less and a true vapor pressure less than 1.0 psia: Records of capacity of the tanks and contents. c. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor pressure less than 1.5 psia: Records of capacity of the tanks and contents. d. For non-commercial water washing operations (less than 2,250 barrels/year) and drum crushing operations of empty barrels less than or equal to 55 gallons with less than three percent by volume of residual material: Any appropriate manifests/records required by the applicable regulatory authorities that document volumes of waste disposal/shipping/storage. e. For activities that have the potential to emit less than 5 TPY (actual) of any criteria pollutant: The type of activity and the amount of emissions from that activity (annual).10. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements that have been determined to be inapplicable to this facility. [OAC 252:100-8-6(d)(2)] a. OAC 252:100-7 Permits for Minor Facilities b. OAC 252:100-11 Alternative Emissions Reduction c. OAC 252:100-15 Mobile Sources d. OAC 252:100-17 Incinerators e. OAC 252:100-23 Cotton Gins f. OAC 252:100-24 Particulate Emissions From Grain, Feed, or Seed Operations g. OAC 252:100-35 Carbon Monoxide h. OAC 252:100-39 Nonattainment Areas i. 40 CFR Part 72 Acid Rain11. The permittee shall certify compliance with the terms and conditions of this permit. The certification of compliance shall be submitted no later than 30 days after each anniversary of the issuance date of this permit, to the Air Quality Division of DEQ, with a copy to the US EPA, Region 6. The certification shall include a monthly summary of the information required by Specific Condition No. 11 of this permit for the past year. [OAC 252:100-8-6(c)(5)(A), (C) & (D)]12. AQD reserves the right to require stack testing for any emission unit.COMPLIANCE SCHEDULE SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 231. Within 90 days of issuance of this permit, the permittee shall submit a plan to complete the testing requirements of §60.46, Test methods and procedures for all boilers firing natural gas. This requirement shall not apply for gas used only in igniters. Based on the results of the testing, the permittee shall install monitoring equipment and conduct monitoring as required by §60.45(a)(3).2. Within 90 days of issuance of this permit, the permittee shall submit the name of the manufacturer, model number if available, throughput capacity and/or size of the screens, cleaners, pulpers, mixers, and storage as well as any corrected ratings for those process units listed in the permit for EUG 4.3. Within 90 days of issuance of this permit, the permittee shall submit the site drawing required for EUG 3 and have completed the labeling required for EUG 4.4. Within 90 days of issuance of this permit, the permittee shall submit emissions calculations for emissions resulting from the incineration/oxidation of VOCs treated by catalytic incinerator. SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 24PERFORMANCE TEST REPORT FORMAT [Permit No. PSD-OK-404, General Conditions]All test reports shall include the following information:I. INTRODUCTION - background information pertinent to the test, including: (a)Company Name and address (b)Name and signature of company official responsible for submitting report. (c)Testing organization name and address (d)Name and signature of test organization official responsible for preparing report. (e)Test dates (f) Names and titles of persons who participated in the test. (g)Schematic drawings of the process being tested showing emission points, sampling sites, and stack cross section with sampling points labeled and dimensions indicated. (h)Description of the process being sampled.II. SUMMARY (a)A summary of emission rates found, compared with applicable performance standards. (b)Isokinetic sampling rates achieved if applicable. (c)The designed, normal maximum and actual operating level of the process during tests. (Describe how such operating level was determined.) (d)Describe air pollution control equipment associated with process being tested. Also describe operating parameters of such air pollution control equipment at the time of tests.III. PROCEDURE - Briefly describe the procedures used and the operation of the sampling equipment. Explain in detail any deviation from EPA Reference procedures.IV. ANALYTICAL TECHNIQUE - Briefly describe all analytical techniques and equipment used to determine the emissions from the source.V. CHAIN OF CUSTODY - Briefly describe a listing of the chain of custody of the test samples.VI. TEST DATA AND CALCULATIONS - Attach all data collected and calculations performed for the test, including: (a)all field data collected on raw data sheets. (b)a log of process operations at time of tests. (c)Laboratory data, including blanks, tare weights, and results of analysis. (d)all emission calculations.VII. APPENDIX SPECIFIC CONDITIONS NO. 99-113-TV DRAFT 25(a)All calibration worksheets of sampling equipment. (b)Brief resume/qualifications of persons conducting tests and preparing reports. (c)Complete description of applicable continuous monitoring system, including manufacturer, model number, serial number and monitoring scheme. TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT STANDARD CONDITIONS (October 15, 2003)SECTION I. DUTY TO COMPLYA. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial of an application to renew this permit. All applicable requirements (excluding state-only requirements) are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act. This permit is valid for operations only at the specific location listed. [OAC 252:100-8-1.3 and 8-6 (a)(7)(A) and (b)(1)]D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. [OAC 252:100-8-6 (a)(7)(B)]SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMSA. Any exceedance resulting from emergency conditions and/or posing an imminent and substantial danger to public health, safety, or the environment shall be reported in accordance with Section XIV. [OAC 252:100-8-6 (a)(3)(C)(iii)]B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. [OAC 252:100-8-6 (a)(3)(C)(iv)]C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Every written report submitted under this section shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (iv)] TITLE V STANDARD CONDITIONS October 15, 2003 2SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTINGA. The permittee shall keep records as specified in this permit. These records, including monitoring data and necessary support information, shall be retained on-site or at a nearby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel upon request. Support information includes all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, the permit may specify that records may be maintained in computerized form. [OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions as existing at the time of sampling or measurement. [OAC 252:100-8-6 (a)(3)(B)(i)]C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. [OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions. [OAC 252:100-8-6 (a)(3)(C)(iii)]E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or Oklahoma Clean Air Act.F. Submission of quarterly or semi-annual reports required by any applicable requirement that are duplicative of the reporting required in the previous paragraph will satisfy the reporting requirements of the previous paragraph if noted on the submitted report.G. Every report submitted under this section shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iv)] TITLE V STANDARD CONDITIONS October 15, 2003 3H. Any owner or operator subject to the provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by the subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least two years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (d)]J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. The progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8-6 (c)(4)]K. All testing must be conducted by methods approved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. The permittee may request the use of alternative test methods or analysis procedures. The AQD shall approve or disapprove the request within 60 days. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. [OAC 252:100-8-6 (a)(3)(A)(iv) and OAC 252:100-43]L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]SECTION IV. COMPLIANCE CERTIFICATIONSA. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since the issuance of this permit. The compliance certification shall also include such other facts as the permitting authority may require to determine the compliance status of the source. [OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]B. The certification shall describe the operating permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reporting period; and a statement that the facility will continue to comply with all applicable requirements. [OAC 252:100-8-6 (c)(5)(C)(i)-(iv)] TITLE V STANDARD CONDITIONS October 15, 2003 4C. Any document required to be submitted in accordance with this permit shall be certified as being true, accurate, and complete by a responsible official. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. [OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)]D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions units or stationary sources that are not in compliance with all applicable requirements. This schedule shall include a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance with any applicable requirements for which the emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or administrative order to which the emissions unit or stationary source is subject. Any such schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based. Except that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8-6 (c)(3)]SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE PERMIT TERMThe permittee shall comply with any additional requirements that become effective during the permit term and that are applicable to the facility. Compliance with all new requirements shall be certified in the next annual certification. [OAC 252:100-8-6 (c)(6)]SECTION VI. PERMIT SHIELDA. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC 252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6 (d)(1)]B. Those requirements that are applicable are listed in the Standard Conditions and the Specific Conditions of this permit. Those requirements that the applicant requested be determined as not applicable are listed in the Evaluation Memorandum and are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENTThe permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD. [OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)] TITLE V STANDARD CONDITIONS October 15, 2003 5SECTION VIII. TERM OF PERMITA. Unless specified otherwise, the term of an operating permit shall be five years from the date of issuance. [OAC 252:100-8-6 (a)(2)(A)]B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been submitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1 (d)(1)]C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]D. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]SECTION IX. SEVERABILITYThe provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby. [OAC 252:100-8-6 (a)(6)]SECTION X. PROPERTY RIGHTSA. This permit does not convey any property rights of any sort, or any exclusive privilege. [OAC 252:100-8-6 (a)(7)(D)]B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6 (c)(6)]SECTION XI. DUTY TO PROVIDE INFORMATIONA. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty (60) days of the request unless the DEQ specifies another time period, any information that the DEQ may request to determine whether cause exists for modifying, reopening, revoking, reissuing, terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8-6 (a)(7)(E)] TITLE V STANDARD CONDITIONS October 15, 2003 6B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment. [OAC 252:100-8-6 (a)(7)(E)]C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall be made in writing within 10 days after such date. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)]SECTION XII. REOPENING, MODIFICATION & REVOCATIONA. The permit may be modified, revoked, reopened and reissued, or terminated for cause. Except as provided for minor permit modifications, the filing of a request by the permittee for a permit modification, revocation, reissuance, termination, notification of planned changes, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)](1) Additional requirements under the Clean Air Act become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the effective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements. (3) The DEQ determines that inaccurate information was used in establishing the emission standards, limitations, or other conditions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ.C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1](1) It only applies to that specific item by serial number or some other permanent identification. (2) Grandfathered status is lost if the item is significantly modified or if it is relocated outside the boundaries of the facility.D. To make changes other than (1) those described in Section XVIII (Operational Flexibility), (2) administrative permit amendments, and (3) those not defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)] TITLE V STANDARD CONDITIONS October 15, 2003 7E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8-6 (c)(6)]SECTION XIII. INSPECTION & ENTRYA. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized regulatory officials to perform the following (subject to the permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18) for confidential information submitted to or obtained by the DEQ under this section):(1) enter upon the permittee's premises during reasonable/normal working hours where a source is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit; (2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit. [OAC 252:100-8-6 (c)(2)]SECTION XIV. EMERGENCIESA. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall notification be more than 24 hours after the exceedance. [The degree of promptness in reporting shall be proportional to the degree of danger.] [OAC 252:100-8-6 (a)(3)(C)(iii)(II)]B. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. [OAC 252:100-8-2]C. An emergency shall constitute an affirmative defense to an action brought for noncompliance with such technology-based emission limitation if the conditions of paragraph D below are met. [OAC 252:100-8-6 (e)(1)] TITLE V STANDARD CONDITIONS October 15, 2003 8D. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that:(1) an emergency occurred and the permittee can identify the cause or causes of the emergency; (2) the permitted facility was at the time being properly operated; (3) during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; (4) the permittee submitted notice of the emergency to AQD within 24 hours of the time when emission limitations were exceeded due to the emergency. This notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emissions, and corrective actions taken; and (5) the permittee submitted a follow up written report within 10 working days of first becoming aware of the exceedance. [OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6 (e)(3)]SECTION XV. RISK MANAGEMENT PLANThe permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date. [OAC 252:100-8-6 (a)(4)]SECTION XVI. INSIGNIFICANT ACTIVITIESExcept as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are either on the list in Appendix I, or whose actual calendar year emissions do not exceed any of the limits below. Any activity to which a State or federal applicable requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2](1) 5 tons per year of any one criteria pollutant. (2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule. (3) 0.6 tons per year for any one category A substance, 1.2 tons per year for any one category B substance or 6 tons per year for any one category C substance as defined in 252:100- 41-40. TITLE V STANDARD CONDITIONS October 15, 2003 9SECTION XVII. TRIVIAL ACTIVITIESExcept as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]SECTION XVIII. OPERATIONAL FLEXIBILITYA. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in the permit). When an operating scenario is changed, the permittee shall record in a log at the facility the scenario under which it is operating. [OAC 252:100-8-6 (a)(10) and (f)(1)]B. The permittee may make changes within the facility that:(1) result in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted emission rate of any existing emissions unit to be exceeded; provided that the facility provides the EPA and the DEQ with written notification as required below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8-6 (f) (2)]SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTSA. The following applicable requirements and state-only requirements apply to the facility unless elsewhere covered by a more restrictive requirement:(1) No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] (2) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning Subchapter. [OAC 252:100-13] (3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19] TITLE V STANDARD CONDITIONS October 15, 2003 10(4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60, NSPS, no discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. [OAC 252:100-25] (5) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29] (6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31] (7) Volatile Organic Compound (VOC) storage tanks built after December 24, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)] (8) All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252:100-37-36] (9) Except as otherwise provided, no person shall cause or permit the emissions of any toxic air contaminant in such concentration as to cause or to contribute to a violation of the MAAC. (State only) [OAC 252:100-41]SECTION XX. STRATOSPHERIC OZONE PROTECTIONA. The permittee shall comply with the following standards for production and consumption of ozone-depleting substances. [40 CFR 82, Subpart A]1. Persons producing, importing, or placing an order for production or importation of certain class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the requirements of §82.4. 2. Producers, importers, exporters, purchasers, and persons who transform or destroy certain class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping requirements at §82.13. 3. Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane (Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include HCFCs.B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term “motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B] TITLE V STANDARD CONDITIONS October 15, 2003 11C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F](1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to § 82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to § 82.158. (3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to § 82.161. (4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with record-keeping requirements pursuant to § 82.166. (5) Persons owning commercial or industrial process refrigeration equipment must comply with leak repair requirements pursuant to § 82.158. (6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to § 82.166.SECTION XXI. TITLE V APPROVAL LANGUAGEA. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not inconsistent with Federal requirements, to provide for incorporation of requirements established through construction permitting into the Sources’ Title V permit without causing redundant review. Requirements from construction permits may be incorporated into the Title V permit through the administrative amendment process set forth in Oklahoma Administrative Code 252:100-8-7.2(a) only if the following procedures are followed:(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice shall include notice to the public that this permit is subject to Environmental Protection Agency (EPA) review, EPA objection, and petition to EPA, as provided by 40 CFR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit. (2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR § 70.8(b). (4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as provided by 40 CFR § 70.8(a) and (c). (5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 CFR § 70.8 (d). TITLE V STANDARD CONDITIONS October 15, 2003 12(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a). (8) The DEQ shall not issue the proposed construction permit until any affected State and EPA have had an opportunity to review the proposed permit, as provided by these permit conditions. (9) Any requirements of the construction permit may be reopened for cause after incorporation into the Title V permit by the administrative amendment process, by DEQ as provided in OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR § 70.7 (f) and (g). (10) The DEQ shall not issue the administrative permit amendment if performance tests fail to demonstrate that the source is operating in substantial compliance with all permit requirements.B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.SECTION XXII. CREDIBLE EVIDENCEFor the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [OAC 252:100-43-6] Mr. Karl L. Meyers, Operating Vice President Georgia Pacific Corporation 4901 Chandler Road Muskogee, OK 74403RE: Operating Permit No. 99-113-TV Fort James Operating Company – Muskogee MillDear Mr. Meyers:Air Quality Division has completed the initial review of your permit application referenced above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 2-14-302 and OAC 252:4-7-13, the enclosed draft permit is now ready for public review. The requirements for public review include the following steps that you must accomplish:1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the county where the facility is located. (Instructions enclosed)2. Provide for public review (for a period of 30 days following the date of the newspaper announcement) a copy of this draft permit and a copy of the application at a convenient location within the county of the facility. Your facility is not an acceptable location.3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any additional comments or requested changes that you may have on the draft permit.Thank you for your cooperation in this matter. If we may be of further service, please contact me at (918) 293-1617 or by mail at DEQ Regional Office at Tulsa, 3105 East Skelly Drive, Suite 200, Tulsa, Oklahoma, 74105.Sincerely,David Pollard, Professional Engineer II AIR QUALITY DIVISIONEnclosure(s) cc: DEQ Office, Muskogee County

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