APPLICATION & OTHER COMMUNICATION FACILITY … · equipment, that their alternate control approach...

New Hampshire Department of Environmental ServicesAir Resources Division P.O. Box 95, 29 Hazen Drive Concord, NH 03302-0095 Phone: 603-271-1370 Fax: 603-271-7053

PERMIT APPLICATION REVIEW SUMMARY

Facility: Groveton Paper Board, Inc. Engineer: Doug Laughton

Location: 19 Main St., Groveton, NH SIC Code: 3221 Pulp & Paper Manuf. Phone: (603) 271-6893

AFS #: 3300700093 Application #: FY06-0096 Date: November 22, 2006 of 25

APPLICATION & OTHER COMMUNICATION

August 23, 2006 DES received and filed the Title V Operating Permit renewal application.

FACILITY DESCRIPTION/PERMITTING HISTORY

Groveton Paper Board (GPB) is a stand-alone semi-chemical, integrated pulp and paper mill producing approximately 550 tons per day of corrugating medium. Pulp is manufactured from wood chips, using a very mild soda ash/caustic solution, at a rate of about 275 oven dry tons pulp production per day1. Pulping chemicals are recovered by concentrating the liquor solids in a set of evaporators and burning the spent cooking liquor (black liquor) in a recovery kiln and subsequent dissolution of the ash. GPB owns and operates two natural gas or No. 6 fuel oil fired Boilers (Boilers #4 & #5) and two combustion turbines (CT’s #1 & #2) equipped with heat recovery steam generator units (HRSG Units #1 & #2, including duct burners firing natural gas), which are collectively called the Steam and Power Plant. Electricity generated by the two combustion turbines is used by the facility for their own consumption in addition to power consumed from outside sources. The primary source of air pollutant emissions at the facility are fuel-burning devices at the Steam and Power Plant and the chemical recovery kiln, which produce criteria pollutant and hazardous air pollutant (HAP) emissions. In addition, methanol and other HAP emissions are generated from the pulping, chemical recovery, and papermaking processes at the facility. Methanol emissions from low volume high concentration sources in the pulp mill and evaporator area are regulated under 40 CFR 63 Subpart S. Methanol emissions from the recovery kiln are regulated under 40 CFR 63 Subpart MM. The GPB site is also occupied by Wausau Papers of New Hampshire Inc., which manufactures specialty papers derived from market pulp. The two facilities are not under common control and are considered separate and distinct facilities for air pollution control purposes. The two facilities were previously served by a common energy plant consisting of four boilers (Boilers #1, #2, #4, & #5) and a steam-driven turbine rated at 6500 kilowatts, with an 8500 kilowatt generator. Boilers #1 and #2, and the small turbine and generator were owned by Wausau, and Boilers #4 and #5 were owned by GPB. The steam plant used to be operated by Wausau for the benefit of both parties under an operating agreement between the two parties, and all four boilers were permitted in Wausau’s name as the operating entity via the Title V Operating Permit TV-OP-021, issued on January 26, 2000. In 1999, the two companies installed the capability to fire natural gas in Boilers #1, #4, and #5; modified the stacks for Boilers #2, #4, and #5; and reduced the sulfur content of oil fired in the Boilers as part of demonstrating compliance with the National Ambient Air Quality Standards for nitrogen oxides. The operating agreement between the two companies that governs the operation of the steam plant and other site operations expired in November 2001. This agreement was modified prior to its expiration so that each facility could operate its own energy plant. In conjunction with this separation, in order to provide a reliable steam source for each facility and to reduce electric power costs, each facility constructed and operated a combustion turbine generation facility, which became the primary source of steam and electricity for each facility. The existing Boilers were to be maintained by their respective owners to provide supplementary and backup steam, with the exception that Boiler #2 was required to be retired and removed from service once a combustion turbine and corresponding heat recovery steam generator were fully operational at one of the two facilities. It was the intention of both parties to have their combustion turbines and HRSG’s 1 Groveton Paper Board does not have any operational limitations on total pulp production. Typical daily production averaged on an annual basis is 275 oven dry tons pulp produced.






operational by November 2001 and to be allowed a reasonable time period for training of GPB operators in safe operation of combustion equipment (Boilers #4 & #5) by the Wausau operators and any training services and/or consultants hired by GPB. At the time of issuance of the Temporary Permit, GPB assumed responsibility for compliance for Boilers #4 and #5 and the two new Combustion Turbines #1 and #2 plus HRSG’s #1 and #2 at its facility. Simultaneous to the issuance of the Temporary Permit to GPB, Wausau was issued a Temporary Permit and assumed responsibility for compliance for Boilers #1 and #2 and its Combustion Turbine and HRSG Unit #1. In addition, at the time of issuance of these two Temporary Permits, all permit conditions applicable to Boilers #1, #2, #4, & #5 contained in the Wausau Title V Operating Permit TV-OP-021 remained in effect until a combustion turbine and corresponding heat recovery steam generator were fully operational at one of the two facilities. In its Temporary Permit application for its Combustion Turbines and Heat Recovery Steam Generators, GPB identified it would install two 5.5-6.0 Megawatt gas/oil-fired turbine co-generation systems. Each Combustion Turbine is rated at a maximum of 73.0 mmBtu/hr gross heat input while firing natural gas at 0 degrees F and 70.4 mmBtu/hr gross heat input while firing No. 2 fuel oil at O degrees F. GPB opted for the use of duct burners for supplemental fuel firing for each of its Heat Recovery Steam Generating Units operated in conjunction with its Combustion Turbine. The duct burners are rated at 84.5 mmBtu/hr gross heat input while firing natural gas only to supply each of the two HRSG Units, when its associated Combustion Turbine is in operation. In addition, in cases where a Combustion Turbine is off-line, the associated HRSG Unit may operate with fresh air makeup in place of heated combustion gases from its Combustion Turbine. In these instances where the Combustion Turbine is out of service, the HRSG Unit duct burner is permitted to operate at 126.9 mmBtu/hr gross heat input rate while firing natural gas. Steam generated by the Heat Recovery Steam generators is used to supply process and space heating needs by extracting heat from each of the combustion turbine exhaust gases into its corresponding heat recovery boiler. There is supplementary gas-only firing in the duct leading to each heat recovery boiler from the combustion turbine. All steam and electricity generated by the new equipment is used by GPB or sold off site. Exhaust gas is vented to the atmosphere from the heat recovery boiler via a new, dedicated stack. In the event that steam requirements are low or if there is a boiler malfunction, the combustion turbine exhaust gas may be directed to a by-pass duct connected to a stack separate from the main Turbine/HRSG main stack. It should be noted that DES granted a one-year extension to GPB to come into compliance with 40 CFR 63 Subpart S or any approved alternative permit terms under Section 63.94, i.e., by April 15, 2002. Furthermore, EPA published National Emission Standards for Hazardous Air Pollutants for Chemical recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills (40 CFR 63 Subpart MM) in the Federal Register on January 12, 2001, with a compliance deadline of March 13, 2004. DES has included applicable requirements from 40 CFR 63 Subpart MM in this Title V Operating Permit, which are applicable to the GPB facility. Note that on September 25, 2003, GPB submitted a request for a one year extension of the compliance deadline for 40 CFR 63 Subpart MM, i.e., from March 13, 2004 to March 13, 2005. In that this initial request was received by DES more than 120 days prior to the compliance deadline, DES may grant a one year extension provided it is for installation of pollution controls. DES reviewed the request with EPA Region 1 and determined that GPB needed to file a significant permit modification request in order to modify the original Title V Operating Permit and incorporate the one year extension for a federally enforceable emission limitation for the Recovery Kiln contained in 40 CFR 63 Subpart MM. DES officially received the significant permit modification request on November 26, 2003. Simultaneously with this significant permit modification request from GPB, the facility also filed an application for a minor permit modification to incorporate operating parameter ranges for various process variables that are monitored for purposes of demonstrating compliance with the alternative methanol reduction strategy for 40 CFR 63 Subpart S. Once performance testing was completed for low volume high concentration (LVHC) collection and treatment systems covered by 40 CFR 63 Subpart S and performance testing was completed on the recovery kiln covered by 40 CFR 63 Subpart MM, DES made minor permit amendments in accordance with Env-A 612.04 to incorporate operating parameter






ranges for various process variables to be monitored as part of the facility’s compliance demonstration as required by this Title V Operating Permit. GPB proposed an alternate control approach to what is required under the pulp and paper NESHAP (40 CFR 63 Subpart S). Instead of reducing HAP emissions from the digester and evaporator vents by 98 percent as required under 63.443(d)(1), GPB proposed to partially control those vents and control an additional HAP emission source to make up the difference in HAP reductions. Groveton uses their existing three Nash type vacuum pumps and treats the condensates generated by those pumps to partially control the digester and evaporator area vents. In early 2002, the mill rerouted all the digester blow tank direct contact condenser condensate (the additional source not regulated by the subject NESHAP) from use on open processes (brown stock washing and paper machine stock dilution) to controlling them in the wastewater collection and treatment system. Preliminary tests showed support for this proposal, and by October 15, 2002, GPB provided a demonstration through performance testing that the HAP emission reduction achieved after installation of equipment, that their alternate control approach reduced digester and evaporator baseline (before vacuum pump control and redirection of the digester blow heat recovery system condensates) emissions on a pound per ton of HAP basis, by more than reducing the digester and evaporator vents by 98 percent. Further and following the subject rule (63.453(a), (m), and (n)), GPB developed, demonstrated, and used parameter monitoring for all affected equipment that demonstrates continuous compliance with this alternative control approach by October 15, 2002. In order for alternative control options to become federally enforceable, there must be a legal mechanism for implementing the described alternative. There are two implementing mechanisms, a site-specific rule change to 40 CFR 63 Subpart S done by the EPA or an equivalency by permit (EBP) pursuant to 40 CFR 63, Subpart E. DES chose the EBP approach for the implementing mechanism to incorporate the alternative control option and its corresponding operating limitations, emissions limitations, monitoring, testing, performance test, record keeping, and reporting requirements contained in the original Title V Operating Permit. On May 16, 2001, EPA issued a direct final rulemaking which granted New Hampshire the authority to implement and enforce alternative requirements for GPB in the form of Title V permit terms and conditions after EPA has approved the New Hampshire’s alternative requirements. The requirement applicable to GPB remains the pulp and paper NESHAP (40 CFR 63 Subpart S) until EPA has approved the alternative permit terms and conditions and the final, original Title V permit was issued, January 17, 2002. On November 15, 2005 GPB submitted a minor permit amendment request in order to incorporate operating parameter ranges for the combustibles monitor on the recovery kiln required by 40 CFR 63 Subpart MM, update 40 CFR 60 Subpart GG sulfur and nitrogen content verification requirements for pipeline quality natural gas, and revisions to NOx RACT testing requirements for Boilers 4 & 5 while firing natural gas. In addition, it should be noted that DES issued two separate Temporary Permits for the like-kind replacements of Combustion Turbine #2 on February 1, 2006 and Combustion Turbine #1 on August 10, 2005. The Table below is a summary of Permitting History for the GPB facility:

Date Permit # Expiration Date

Description

12/11/06 TP-B-0524 06/30/08 Temporary Permit for the Recovery Kiln – Establish an annual NOx emission cap for the Recovery Kiln and operating limitations for front-end firing and center-firing of the Recovery Kiln.

04/14/06 TV-OP-040 01/31/07 Administrative and Minor Amendments to Title V Operating Permit, change in responsible official from Tom Pitts to Keith Wood and incorporation of exemption for NOx RACT testing requirements from Temporary Permit FP-T-0137, and Recovery Kiln operating parameter ranges for the Recovery Kiln combustibles analyzers for 40 CFR 63 Subpart MM.






Date Permit # Expiration Date

Description

02/01/06 FP-T-0137 08/31/07 Temporary Permit for the like-kind replacement of Combustion Turbine #2 and allowing greater than 3 years for NOx RACT testing of the Boilers on natural gas if the unit(s) were not in service the past 3 years on Natural gas and updates to 40 CFR 60 Subpart GG for fuel monitoring.

08/10/05 FP-T-0128 02/28/07 Temporary Permit for the like-kind replacement of Combustion Turbine #1.

03/09/04 TV-OP-040 01/31/07 Minor and Significant Modifications to Title V Operating Permit. This included adding a one year extension for compliance with 40 CFR 63 Subpart MM for the Recovery Kiln and putting in operating parameter ranges for the Alternative Methanol Reduction project.

01/17/02 TV-OP-040 01/31/07 Initial Title V Operating Permit including Equivalency By Permit approach for compliance with 40 CFR 63 Subpart S.

01/17/02 FP-T-0051 11/30/02 Amended and extended the initial construction permit for the two Combustion Turbines with Heat Recovery Steam Generators.

05/11/00 FP-T-0051 11/30/01 Administrative Amendment to the initial construction permit for the two Combustion Turbines with Heat Recovery Steam Generators. Added at 15% oxygen to the 25 ppmvd NOx emission limit for the Combustion Turbine throughout the permit.

05/08/00 FP-T-0051 11/30/01 Initial construction permit for the two Combustion Turbines and two Heat Recovery Steam Generators. In addition, Boilers #4 & #5, which were owned by GPB, but operated by Wausau Papers, were taken out of the Wausau Papers Title V Operating Permit and put over to GPB in this Temporary Permit, in that GPB was going to be responsible for owning and operating their Boilers #4 & #5.

PROJECT DESCRIPTION

This application is for the renewal of the original Title V Operating Permit TV-OP-040, issued on January 17, 2002. In addition, DES is simultaneously reviewing a Temporary Permit application from Groveton Paper Board, Inc. for a change in method of operation of the recovery kiln to allow for front-end firing of the black liquor solids into the unit in addition to the traditional center-firing of black liquor solids into the unit for compliance with the emissions limitation of 2.97 lb total hydrocarbons per ton black liquor solids fired contained in 40 CFR 63 Subpart MM Section 63.862(c). Front-end firing of the black liquor solids accounts for a higher emission rate of NOx emissions and the facility wishes to avoid Non-Attainment Review program requirements by having a federally enforceable emissions cap of 50.23 tons NOx per consecutive 12 month period for the Recovery Kiln2. In addition, based on November 2004 stack testing of the Recovery Kiln, GPB requested two new operations limitations for the Recovery Kiln: A maximum front end-firing of black liquor solids limit of 6,600 lbs black liquor solids per hour and a maximum center-firing of black liquor solids limit of 6,000 lbs black liquor solids per hour. DES will issue the Temporary Permit first, and then include this 50.23 tons NOx per consecutive 12 month period emissions limitation for the Recovery Kiln and the operating limitations mentioned for front end-firing and center-firing in this renewal of the Title V Operating Permit.

2 50.23 tons NOx/consecutive 12 months = 39 (significance threshold for Non-Attainment Review) + 11.23 (baseline average emissions for 2004 and 2005)






PROCESS/DEVICE DESCRIPTION

Device/Process Description and Maximum Permitted Capacity EU1 - Boiler #4 Combustion Engineering Model VP12W, Serial Number Not Available, Installed in

1966, Low NOx Burner Installed in 1995, 107 MMBtu/hr while firing natural gas or No. 6 fuel oil with a maximum sulfur content of 0.5% by weight

EU2 - Boiler #5 Combustion Engineering Model VP12W, Serial Number Not Available, Installed in 1967, Low NOx Burner Installed in 1995, 107 MMBtu/hr while firing natural gas or No. 6 fuel oil with a maximum sulfur content of 0.5% by weight

EU3 - Combustion Turbine #1

Solar Model Taurus 60S, Serial Number 0207T, Like-kind replacement done on 02/27/2004, Originally Installed in 2000, 73.0 MMBtu/hr while firing natural gas at 0 deg F or 70.4 MMBtu/hr while firing No. 2 fuel oil at 0 deg F with a maximum sulfur content of 0.4% sulfur by weight

EU4 - Combustion Turbine #2

Solar Model Taurus 60S, Serial Number 0012T, Like-kind replacement done on 10/10/2005, Originally Installed in 2000, 73.0 MMBtu/hr while firing natural gas at 0 deg F or 70.4 MMBtu/hr while firing No. 2 fuel oil at 0 deg F with a maximum sulfur content of 0.4% sulfur by weight

EU5 - Heat Recovery Steam Generating Unit #1

Installed in 2000, EMI Model Number MF-4/S-78, Serial Number W4377. 84.5 MMBtu/hr duct burner firing natural gas supplying heat input to the heat recovery steam generating unit when Combustion Turbine #1 is in service and 126.9 MMBtu/hr duct burner firing natural gas to the heat recovery steam generating unit when the Combustion Turbine #1 is out of service

EU6 - Heat Recovery Steam Generating Unit #2

Installed in 2000, EMI Model Number MF-4/S-78, Serial Number W4379. 84.5 MMBtu/hr duct burner firing natural gas supplying heat input to the heat recovery steam generating unit when Combustion Turbine #1 is in service and 126.9 MMBtu/hr duct burner firing natural gas to the heat recovery steam generating unit when the Combustion Turbine #1 is out of service

EU7 - Recovery Kiln (40 CFR 63 Subpart MM)

Installed in 1980, No Manufacturer or Model No. or Serial Number Available, Originally installed a Sonoco Process in 1977 and then redesigned it to be a Hot Soda type process in 1980. Maximum of 6,600 lbs black liquor solids/hour while front end-firing and a maximum of 6,000 lbs black liquor solids/hour while center-firing

EU8 - Pulp Mill Blow Heat Recovery System Nash type vacuum pump (LVHC source) (40 CFR 63 Subpart S)

Digester Blow Tank gaseous emissions are directed to a Direct Contact condenser where spray showers contact the gases and remove methanol from the gases and it leaves as condensate from the blow heat condenser. Gases that have been stripped of methanol exit the blow tank with help from a Nash type vacuum pump pulling a suction and exit the discharge of the Nash type vacuum pump to the atmosphere. Some methanol is further stripped out while going through the vacuum pump, as seal water going into the vacuum pump mixes with the blow tank gaseous emissions that enter the vacuum pump chamber. Condensate from the vacuum pump has some methanol in it and is routed to the sewer for collection and biodegradation at the wastewater treatment plant.

EU9 - (2) Evaporator Area LVHC Sources (Nash type vacuum pumps) (40 CFR 63 Subpart S)

Two Nash type vacuum pumps pull vapors from the 4th and 5th effects of the evaporators containing low levels of methanol and it is stripped out of the gases inside the vacuum chamber via contact with seal water fed into the vacuum pump. Condensate generated in the vacuum pumps is then piped to the sewer for conveying to the wastewater treatment plant for biodegradation of the methanol.

EU10 Kraft Pulper Exhaust (Stack ID 25) - NA EU11 Paper Machine Dry End Exhaust (Stack ID 28) - NA






Device/Process Description and Maximum Permitted Capacity EU12 Paper Machine Dry End Exhaust (Stack ID 29) - NA EU13 Paper Machine Hood Exhaust (Stack ID 30) - NA EU14 Paper Machine Wet End Exhaust (Stack ID 31) - NA EU15 Paper Machine Saveall Exhaust (Stack ID 37) – NA EU16 Paper Machine Vacuum Pump Exhaust (Stack ID 38) - NA EU17 Paper Machine Vacuum Pump Exhaust (Stack ID 39) - NA EU18 Filtrate Tank Vent (Stack ID 43) - NA EU19 #1 Brown Stock Washer Exhaust (Stack ID 44) - NA EU20 #2 Brown Stock Washer Exhaust (Stack ID 45) - NA EU21 #3 Brown Stock Washer Exhaust (Stack ID 46) - NA EU22 Wet End Vapor Vent - NA

INSIGNIFICANT ACTIVITIES Device/Process Description Not applicable

POLLUTION CONTROL EQUIPMENT Groveton has a Venturi Scrubber followed by a Wet Electrostatic Precipitator installed in 1980 on the discharge of the Recovery Kiln, as part of the conversion from the Sonoco process to the Hot Soda Neutral Sulfite Semi-Chemical (NSSC) process for pulp cooking and chemical recovery processes. Venturi Scrubber: Particulate Matter removal. Minimum 200 gallons per minute of water or liquid recycle rate. Wet Electrostatic Precipitator: Particulate Matter removal. Minimum of 100 gallons per minute of shower wash flow and a voltage range greater than 30 kilovolts Direct Current (DC). The Direct Contact Condenser is a control device which removes methanol and other organic vapors by the application of a water shower onto the incoming gaseous emissions from the pulp Blow Tank. Exiting gaseous emissions go to the Blow Heat Recovery Nash vacuum pump prior to release to the atmosphere, with a small amount of methanol emissions being removed via contact with vacuum pump seal water. There are two Nash type vacuum pumps which pull gaseous emissions from the two low volume high concentration sources of methanol in the 4th and 5th effect evaporators, with some methanol removed by the vacuum pump seal water prior to the gaseous emissions being discharged to the atmosphere. See Table 1 for a listing and identification of these pieces of pollution control equipment:






Table 1 – Pollution Control Equipment Identification

Pollution Control Equipment

Number (PCE#)

Emission Unit Number Description of Equipment Activity

PC1 EU7 Peabody Wet Venturi Scrubber and Peabody Wet Electrostatic Precipitator

Installed: 1980

Controls particulate matter emissions from the Recovery Kiln.

PC2 EU8 Direct Contact Condenser Installed: 1970

Controls methanol emissions from the blow tank.

PC3 EU8 Blow Heat Recovery System Nash Type Vacuum Pump Model: 1001-4 Installed: 1970

Controls methanol emissions from the blow heat recovery system.

PC4 EU9 Evaporator Area Nash Type Vacuum Pump Model: LR4-3 Installed: 1980’s

Controls methanol emissions from a LVHC source in the evaporator area.

PC5 EU9 Evaporator Area Nash Type Vacuum Pump Model: LR4-3 Installed: 1980’s

Controls methanol emissions from a LVHC source in the evaporator area.

EMISSION CALCULATIONS Boilers #4 & #5 (EU1 & EU2) Boilers #4 & #5 were not in operation for the whole calendar year of 2005. Hence, there are no emissions to be calculated for that year. When reporting annual emissions for No. 6 fuel oil or natural gas, Groveton uses the permit emissions limits in lb/MMBtu X MMBtu/yr from that source of fuel X ton/2,000 lb to determine the annual emissions in tons/yr of a criteria pollutant. Combustion Turbine #1 and HRSG Unit #1 (EU3 & EU5) On Oil (hrs) On Nat. Gas (hrs) HRSG Fresh Air

(hrs) HRSG Nat. Gas (hrs)

Turbine #1 360 7341 32 8046






Part 1 of 4 - 360 hours CT#1 on No. 2 fuel oil and HRSG #1 on Natural Gas For the CT #1: Note that the emissions factors for both the Combustion Turbine on oil and the HRSG on natural gas in this Part are a combined emission factor for when both units are in operation at the same time from stack testing conducted. 139,744 gallons No. 2 fuel oil combusted X 142,000 Btu/gal = 19,843 MMBtu PM = 19,843 MMBtu X 0.016524 lb PM/MMBtu = 327.9 lb PM SO2 = 19,843 MMBtu X 0.2331 lb SO2/MMBtu = 4,625.55 lb SO2 NOx = 19,483 MMBtu X 0.158 lb NOx/MMBtu = 3,135.30 lb NOx CO = 19,483 MMBtu X 0.011 lb CO/MMBtu = 218.28 lb CO NMVOC = 19,483 MMBtu X 0.00527 lb NMVOC/MMBtu = 104.58 lb NMVOC For HRSG Unit #1: 12,591,720 cubic feet of NG X 1,050 Btu/CF = 13,221 MMBtu PM = 13,221 MMBtu X 0.016524 lb PM/MMBtu = 218.47 lb PM SO2 = 13,221 MMBtu X 0.2331 lb SO2/MMBtu = 3,081.89 lb SO2 NOx = 13,221 MMBtu X 0.158 lb NOx/MMBtu = 2,088.97 lb NOx CO = 13,221 MMBtu X 0.011 lb CO/MMBtu = 145.43 lb CO NMVOC = 13,221 MMBtu X 0.00527 lb NMVOC/MMBtu = 69.68lb NMVOC Part 2 of 4 – 7431 hrs CT #1 on Nat. Gas and 7431 hrs HRSG Unit #1 on Nat. Gas For the CT #1: Note that the emissions factors for both the Combustion Turbine on natural gas and the HRSG on natural gas in this Part are a combined emission factor for when both units are in operation at the same time from stack testing conducted. 420,370,098 cubic feet Natural Gas consumed by CT #1 X 1,050 Btu/cf = 441,388.6 MMBtu PM = 441,388.6 MMBtu X 0.00714 lb PM/MMBtu = 3,151.51 lb PM SO2 = 441,388.6 MMBtu X 0.00141 lb SO2/MMBtu = 622.36 lb SO2 NOx = 441,388.6 MMBtu X 0.074 lb NOx/MMBtu = 32,662.76 lb NOx CO = 441,388.6 MMBtu X 0.021 lb CO/MMBtu = 9,269.16 lb CO NMVOC = 441,388.6 MMBtu X 0.00435 lb NMVOC/MMBtu = 1,920.04 lb NMVOC For HRSG Unit #1: 256,766,157 cubic feet of NG X 1,050 Btu/CF = 269,604.46 MMBtu PM = 269,604.46 MMBtu X 0.00714 lb PM/MMBtu = 1,924.98 lb PM SO2 = 269,604.46 MMBtu X 0.00141 lb SO2/MMBtu = 380.14 lb SO2 NOx = 269,604.46 MMBtu X 0.074 lb NOx/MMBtu = 19,950.73 lb NOx CO = 269,604.46 MMBtu X 0.021 lb CO/MMBtu = 5,661.69 lb CO NMVOC = 269,604.46 MMBtu X 0.00435 lb NMVOC/MMBtu = 1,172.78 lb NMVOC






Part 3 of 4 – HRSG Unit #1 Fresh-Air Firing on Natural Gas for 32 hours 1,119,264 cubic feet of Natural Gas X 1,050 Btu/cf = 1175.2272 MMBtu PM = 1,175.2272 MMBtu X 0.0076 lb PM/MMBtu = 8.93 lb PM SO2 = 1,175.2272 MMBtu X 0.0014 lb SO2/MMBtu = 1.66 lb SO2 NOx = 1,175.2272 MMBtu X 0.1920 lb NOx/MMBtu = 225.64 lb NOx CO = 1,175.2272 MMBtu X 0.0250 lb CO/MMBtu = 29.38 lb CO NMVOC = 1,175.2272 MMBtu X 0.0055 lb NMVOC/MMBtu = 6.46 lb NMVOC Part 4 of 4 – HRSG Unit #1 313 hours alone on Natural Gas (not fresh air firing) 10,951,474 cubic feet of Natural Gas X 1,050 Btu/cf = 11,499.048 MMBtu PM = 11,499 MMBtu X 0.0066 lb PM/MMBtu = 75.89 lb PM SO2 = 11,499 MMBtu X 0.0014 lb SO2/MMBtu = 16.21 lb SO2 NOx = 11,499 MMBtu X 0.0770 lb NOx/MMBtu = 885.43 lb NOx CO = 11,499 MMBtu X 0.0020 lb CO/MMBtu = 23.00 lb CO NMVOC = 11,499 MMBtu X 0.0030 lb NMVOC/MMBtu = 34.50 lb NMVOC Combustion Turbine #2 and HRSG Unit #2 (EU4 & EU6) On Oil (hrs) On Nat. Gas (hrs) HRSG Fresh Air

(hrs) HRSG Nat. Gas (hrs)

Turbine #1 360 7341 32 8046 Part 1 of 4 - 72 hours CT#2 on No. 2 fuel oil and HRSG #2 on Natural Gas For the CT #2: Note that the emissions factors for both the Combustion Turbine on oil and the HRSG on natural gas in this Part are a combined emission factor for when both units are in operation at the same time from stack testing conducted. 30,745 gallons No. 2 fuel oil combusted X 142,000 Btu/gal = 4,365.79 MMBtu PM = 4,365.79 MMBtu X 0.019284 lb PM/MMBtu = 72.14 lb PM SO2 = 4,365.79 MMBtu X 0.2331 lb SO2/MMBtu = 1,017.67 lb SO2 NOx = 4,365.79 MMBtu X 0.152 lb NOx/MMBtu = 689.79 lb NOx CO = 4,365.79 MMBtu X 0.004 lb CO/MMBtu = 48.02 lb CO NMVOC = 4,365.79 MMBtu X 0.00389 lb NMVOC/MMBtu = 23.01 lb NMVOC For HRSG Unit #2: 2,068,128 cubic feet of NG X 1,050 Btu/CF = 2,171.5344 MMBtu PM = 2,171.5344 MMBtu X 0.019284 lb PM/MMBtu = 35.88 lb PM SO2 = 2,171.5344 MMBtu X 0.2331 lb SO2/MMBtu = 506.18 lb SO2 NOx = 2,171.5344 MMBtu X 0.152 lb NOx/MMBtu = 343.10 lb NOx CO = 2,171.5344 MMBtu X 0.004 lb CO/MMBtu = 23.89 lb CO NMVOC = 2,171.5344 MMBtu X 0.00389 lb NMVOC/MMBtu = 11.44 lb NMVOC






Part 2 of 4 – 7691 hrs CT #2 on Nat. Gas and 7691 hrs HRSG Unit #2 on Nat. Gas For the CT #2: Note that the emissions factors for both the Combustion Turbine on natural gas and the HRSG on natural gas in this Part are a combined emission factor for when both units are in operation at the same time from stack testing conducted. 442,763,179 cubic feet Natural Gas consumed by CT #2 X 1,050 Btu/cf = 464,901.34 MMBtu PM = 464,901.34 MMBtu X 0.00714 lb PM/MMBtu = 3,319.40 lb PM SO2 = 464,901.34 MMBtu X 0.00141 lb SO2/MMBtu = 655.51 lb SO2 NOx = 464,901.34 MMBtu X 0.082 lb NOx/MMBtu = 34,402.70 lb NOx CO = 464,901.34 MMBtu X 0.013 lb CO/MMBtu = 9,762.93 lb CO NMVOC = 464,901.34 MMBtu X 0.00394 lb NMVOC/MMBtu = 2,022.32 lb NMVOC For HRSG Unit #2: 220,916,284 cubic feet of NG X 1,050 Btu/CF = 231,962.1 MMBtu PM = 231,962.1 MMBtu X 0.00714 lb PM/MMBtu = 1,656.21 lb PM SO2 = 231,962.1 MMBtu X 0.00141 lb SO2/MMBtu = 327.07 lb SO2 NOx = 231,962.1 MMBtu X 0.082 lb NOx/MMBtu = 17,165.20 lb NOx CO = 231,962.1 MMBtu X 0.013 lb CO/MMBtu = 4,871.20 lb CO NMVOC = 231,962.1 MMBtu X 0.00394 lb NMVOC/MMBtu = 1,009.04 lb NMVOC Part 3 of 4 – HRSG Unit #2 Fresh-Air Firing on Natural Gas for 30 hours 861,720 cubic feet of Natural Gas X 1,050 Btu/cf = 904.806 MMBtu PM = 904.806 MMBtu X 0.0076 lb PM/MMBtu = 6.88 lb PM SO2 = 904.806 MMBtu X 0.0014 lb SO2/MMBtu = 1.28 lb SO2 NOx = 904.806 MMBtu X 0.1710 lb NOx/MMBtu = 173.72 lb NOx CO = 904.806 MMBtu X 0.0290 lb CO/MMBtu = 22.62 lb CO NMVOC = 904.806 MMBtu X 0.0055 lb NMVOC/MMBtu = 4.98 lb NMVOC Part 4 of 4 – HRSG Unit #2 313 hours alone on Natural Gas (not fresh air firing) 8,040,109 cubic feet of Natural Gas X 1,050 Btu/cf = 8,442.1145 MMBtu PM = 8,442.1145 MMBtu X 0.0066 lb PM/MMBtu = 55.72 lb PM SO2 = 8,442.1145 MMBtu X 0.0014 lb SO2/MMBtu = 11.90 lb SO2 NOx = 8,442.1145 MMBtu X 0.0770 lb NOx/MMBtu = 650.04 lb NOx CO = 8,442.1145 MMBtu X 0.0030 lb CO/MMBtu = 16.88 lb CO NMVOC = 8,442.1145 MMBtu X 0.0021 lb NMVOC/MMBtu = 25.33 lb NMVOC Annual Emissions Caps for Combined Emissions from EU1 through EU6 (Total Steam Plant) NOx = 218.07; SO2 = 489.0; CO = 241.76; PM10 = 46.29; NMVOC = 23.46






2005 Actual Annual Emissions for EU1 through EU6 NOx = 55.49; SO2 = 5.55; CO = 17.26; PM10 = 4.95; NMVOC = 2.36 Recovery Kiln (EU7) 2005 Actual Annual Emissions Emission factors are in lb/ton of black liquor solids (lb/ton BLS) based on stack testing conducted at the facility and a separate factor only for sulfur dioxide emissions from No. 2 fuel oil agreed upon by DES and GPB. Other criteria pollutants resulting from combustion of No. 2 fuel oil are already included in the other criteria pollutant emissions factors for the Recovery Kiln. TSP = 12,013 tons BLS/yr X 0.345 lb TSP/ton BLS X ton/2,000 lb = 2.072 tons TSP/yr NOx = 12,013 tons BLS/yr X 1.910 lb NOx/ton BLS X ton/2,000 lb = 11.47 tons NOx/yr CO = 12,013 X 0.180 lb CO/ton BLS X ton/2,000 lb = 1.08 tons CO/yr NMVOC = 12,013 X 0.013 lb NMVOC/ton BLS X ton/2,000 lb = 0.078 tons NMVOC/yr VOC = 12,013 X 0.47 lb VOC/ton BLS X ton/2,000 lb = 2.82 tons VOC/yr Methanol = 12,013 X 0.125 lb Methanol/ton BLS X 2,000 lb/ton = 0.75 tons/yr New Annual Emissions Cap for NOx = 50.23 tons/yr Groveton Paper Board Equivalency in Methanol Reduction Required for EU8 and EU9 The performance test was conducted from October 10 through November 8, 2002. Test data provided by Groveton Paper Board (GPB) were the following: Gaseous methanol emissions leaving the DCC = 6.39 + 4.45/2 = 5.42 lb/hr methanol Average gaseous methanol emissions leaving Evap Pump 1 = 0.0008 lb/hr methanol Average gaseous methanol emissions leaving Evap Pump 2 = 0.004 lb/hr methanol Wastewater treatment plant air emissions of methanol were 0.87 lb/hr methanol Methanol leaving in the PL13 Tank Overflow to the sump = 34.87 + 37.51/2 = 36.19 lb/hr methanol Methanol leaving in the Evaporator area vacuum pumps = 0.345 lb/hr methanol, which is included in the PL-13 Tank Overflow The equivalency in methanol reduction required for the project can be summarized by the following statement: The sum of the gaseous methanol emissions leaving Direct Contact Condenser (DCC) and going to the inlet of the Blow Heat Recovery Nash Vacuum Pump plus the gaseous methanol emissions leaving the two evaporator area vacuum pumps in lb methanol per day divided by the pulp mill production rate in oven dry tons pulp per day (ODTP/Day) times 98% reduction is the equivalent methanol reduction required. Hence, the equivalent methanol reduction required is: (((5.42 lb/hr + 0.0008 + 0.004) X 24 hr/day)/289) X 0.98 = 0.44 lb methanol/ODTP To determine the methanol removed by this project, it is determined by summing the methanol going to the wastewater treatment plant from the DCC condensate and the three Nash type vacuum pumps (the PL-13 Tank Overflow to the GPB






sump) and subtracting the air losses from the aeration pond dividing by the oven dry tons pulp produced per day and multiplying by the biodegradation rate of the effluent treatment system. Hence, the methanol removed is: ((36.19 – 0.87 lb/hr) X 24) X 0.98)/289 = 2.87 lb methanol/ODTP The yardstick used in showing the effectiveness of this project was to look at what methanol was destroyed in the liquid stream in place of 98% destruction of the gaseous emissions leaving the DCC and two evaporator area Nash Vacuum Pumps. Note that prior to this change in process, the facility did sewer about 15 lb/hr of methanol from the PL-13 Tank, which went to the WWTP for destruction. Now it sends approximately 35 lb/hr methanol to the WWTP instead of recycling the PL-13 Tank water to the paper machine area and emitting methanol as gaseous emissions from various process sources in the paper mill. The baseline test and performance test included testing of gaseous methanol emissions from process sources in the pulp mill and paper machine areas and showed a drop of about 40 tons per year facility wide of methanol emissions. Emissions Calculations for EU10 through EU22 Emissions Units EU10 through EU22 have no emissions limits associated with them. Groveton Paper Board has done stack testing as part of its overall evaluation of methanol and RTAP emissions from these sources and has site-specific emissions factors in lb pollutant/air dry ton paper produced or lb pollutant/oven dry ton pulp production and multiplies the total tons of pulp manufactured or total tons of paper produced for the year to come up with emissions for EU10 through EU22.

STACK INFORMATION

Table 2 – Stack Criteria

Device/Stack # Minimum Stack Height (feet) Maximum Stack Diameter (feet)

Boilers #4 & #5 (Common stack) 135.0 6.0

Comb. Turb/HRSG #1

And

Comb. Turb/HRSG #2

135.0 5.58 (Combined Stack)

Recovery Kiln 127.0 2.95

ALTERNATE OPERATING SCENARIOS

Groveton Paper Board has identified several alternate operating scenarios for its steam and power plant composed of Boilers #4 & #5, Combustion Turbines #1 & #2, and the Heat Recovery Steam Generators #1 & #2. Groveton Paper






Board updated its list of alternate operating scenarios in the Temporary Permit FP-T-0137 issued on February 1, 2006. These 8 alternate operating scenarios designated as Groveton1 through Groveton8 have been listed below. Note that all of these alternate operating scenarios will not result in an exceedance of the National Ambient Air Quality Standards for criteria pollutants provided the devices are operated within permitted hourly and annual emissions limitations listed in this permit. In addition, each of these alternate operating scenarios will not subject the facility to PSD or Non-Attainment Review program requirements provided the combustion devices are operated within hourly and annual emissions limitations contained in this permit.

Table 3 – Federally Enforceable Alternative Operating Scenarios

Scenario Name Scenario Description

Groveton1 Normal Operating Scenario (Interruptible Gas/Oil) 1. Both turbines firing No. 2 fuel oil at maximum capacity, 70.3 MMBtu/hr gross heat input each,

for up to 75 days in a consecutive 365-day period and both turbines firing natural gas at maximum capacity, 65.2 MMBtu/hr gross heat input each, for up to 288 days in a consecutive 365-day period.

2. Both duct burners would be firing natural gas only, at maximum capacity, 84.5 MMBtu/hr gross heat input each, for up to 363 days in a consecutive 365-day period.

Groveton2 Normal Operating Scenario (Gas only) 1. Both turbines firing natural gas only at maximum capacity, 65.2 MMBtu/hr gross heat input each,

for up to 363 days in a consecutive-365 day period. 2. Both duct burners would be firing natural gas only, at maximum capacity, 84.5 MMBtu/hr gross

heat input each, for up to 363 days in a consecutive 365-day period. Groveton3 Boiler Backup Scenario (Turbines and HRSG’s Unavailable)

1. Boilers #4 & #5 firing No. 6 fuel oil with a maximum sulfur content of 0.5% by weight at maximum capacity, 107 MMBtu/hr gross heat input rate each for up to 102.5 days in a consecutive 365-day period and Boilers #4 & #5 firing natural gas at maximum capacity, 107 MMBtu/hr gross heat input rate each for up to 260.5 days in a consecutive 365-day period.

Groveton4 Boiler Backup Scenario (Oil Only) 1. Boilers #4 & #5 firing No. 6 fuel oil with a maximum sulfur content of 0.5% by weight at

maximum capacity, 107 MMBtu/hr gross heat input rate each for up to 120 days in a consecutive 365-day period.

2. Both Turbines and HRSG Units down. Groveton5 Backup Scenario (One turbine and one HRSG Unit out of service)

1. Boiler #4 or Boiler #5 firing No. 6 fuel oil with a maximum sulfur content of 0.5% by weight at maximum capacity, 107 MMBtu/hr gross heat input rate for up to 112 days in a consecutive 365-day period and firing natural gas at maximum capacity, 107 MMBtu/hr gross heat input rate for up to 251 days in a consecutive 365-day period.

2. One turbine firing No. 2 fuel oil at maximum capacity, 70.3 MMBtu/hr gross heat input rate for up to 112 days in a consecutive 365-day period and firing natural gas at maximum capacity, 65.2 MMBtu/hr gross heat input rate for up to 251 days in a consecutive 365-day period.

3. One duct burner firing natural gas at maximum capacity, 84.5 MMBtu/hr gross heat input rate for up to 363 days in a consecutive 365-day period.






Table 3 – Federally Enforceable Alternative Operating Scenarios

Scenario Name Scenario Description

Groveton6 Maximized Fuel Use of Natural Gas Scenario 1. Both turbines firing natural gas at maximum capacity, 65.2 MMBtu/hr gross heat input rate for up

to 363 days in a consecutive 365-day period 2. Both duct burners would be firing natural gas only, at maximum capacity, 84.5 MMBtu/hr gross

heat input each, for up to 363 days in a consecutive 365-day period. 3. Boilers #4 & #5 firing natural gas at maximum capacity, 107 MMBtu/hr each for up to 118 days

in a consecutive 365 day period. Groveton7 Maximum Natural Gas to Turbines/HRSG’s and No. 6 Fuel Oil to Boilers Scenario

1. Boilers #4 & #5 firing No. 6 fuel oil with a maximum sulfur content of 0.5% by weight at maximum capacity, 107 MMBtu/hr gross heat input rate each for up to 20 days each in a consecutive 365 day period.

2. Turbines firing natural gas at maximum capacity, 65.2 MMBtu/hr gross heat input rate each for up to 363 days in a consecutive 365-day period.

3. Both duct burners would be firing natural gas only, at maximum capacity, 84.5 MMBtu/hr gross heat input each, for up to 363 days in a consecutive 365-day period.

Groveton8 Additional operating scenarios are implicitly allowed, since their emissions are lower than those listed in Groveton1 through Groveton7 above, and not NSR or NA limited. These scenarios include, but are not limited to: 1. One or both HRSGs operating at maximum rates, with one or both Turbines shut down. 2. One or both HRSGs operating at maximum firing rates with both turbines shut down. 3. Other combinations of all six combustion devices operating at varying firing rates and operating

days, provided that the annual steam and power plant emissions listed in Tables 3a and 3b are not exceeded.

4. Based on performance testing of the combustion turbines and heat recovery steam generating units, the days of operation while firing fuel oil or natural gas in the above alternate operating scenarios may be changed via a permit modification in accordance with Env-A 612, provided that the annual steam and power plant emissions listed in Tables 6a and 6b are not exceeded.

MODELING DES conducted an ambient air impact analysis for the Temporary Permit for the Recovery Kiln recently issued. This modeling was done to determine the impacts of the increase in Recovery Kiln NOx emissions from the change in method of operation of the Recovery Kiln, i.e., using front-end firing of black liquor solids in addition to the traditional method of operation of center-firing of black liquor solids in the Recovery Kiln. DES modeled the Recovery Kiln for front-end firing at 6,600 lb of black liquor solids/hour with 1.5 gal/min No. 6 fuel oil with a maximum sulfur content of 0.5%, by weight. The modeling included GPB’s two combustion turbines with heat recovery steam generators at full capacity and at maximum rates for oil and natural gas, along with interactive sources from Wausau Papers and the PSNH Lost Nation facility. The modeling showed the facility to be in compliance with the national ambient air quality standards for NOx.






DES previously conducted modeling for the installation of the 2 new Combustion Turbines and Heat Recovery Steam Generators at Groveton Paper Board and the new Combustion Turbine and Heat Recovery Steam Generator at Wausau Papers back in 2000 and again in 2005 for the addition of an additional heat economizer on the discharge stack from the Wausau Papers Combustion Turbine/Heat Recovery Steam Generator. There were restrictions imposed on Groveton Paper Board from the initial modeling of the combustion turbine projects at Wausau Papers and Groveton Paper Board, which are listed below as a result of that modeling:

• No. 6 fuel oil is restricted to less than or equal to 0.5% sulfur by weight for Boilers #4 & #5. • Combustion Turbines #1 & #2 and Boilers #4 & #5 are limited to 363 days operation per consecutive 365 day period. • Less than 3 consecutive hours per 24-hour period when both Turbines are burning No. 2 fuel oil at the same time,

while discharging through their bypass stacks. This condition only applies if Boiler 1 at Wausau Papers and Boilers #4 & #5 at Groveton Paper are burning No. 6 fuel oil at maximum load during the same period.

GPB and DES modeled the Recovery Kiln for compliance with the original state air toxics program contained in Env-A 1300 on May 24, 1994 and determined the facility was in compliance with the state air toxics program. Since that time the facility has become subject to 40 CFR 63 Subparts S and MM, which have federal maximum achievable control technology requirements for reduction of methanol and organic hazardous air pollutants, respectively. During preparation of the original Title V Operating Permit, the facility made improvements in its combustion of black liquor solids, namely an increase in combustion temperature at the entry point of the black liquor solids to the Kiln. Subsequent testing and modeling of those stack test data by GPB’s consultant showed the facility to be in compliance with the new state air toxics program requirements contained in Env-A 1400. The facility maintains a copy of the ambient air dispersion modeling analysis on site for proof of compliance with Env-A 1400.

EMISSION TESTING

NOx RACT testing is required every 3 years for the Combustion Turbines #1 & #2 alone and combined Combustion Turbine with its Heat Recovery Steam Generator, along with Boilers #4 & #5. Note that via Temporary Permit FP-T-0137 issued on February 1, 2006, DES has allowed Groveton Paper not to have to conduct NOx RACT testing of Boilers #4 & #5 on oil every 3 years if the unit has not fired fuel oil for the past three years and requires it to test on fuel oil within 60 days of startup on oil. The same requirement for Boilers #4 & #5 applies for natural gas firing of the Boilers with respect to requiring the NOx RACT testing every 3 years. Groveton Paper completed its pre-testing and performance testing of its innovative methanol reduction strategy for compliance with 40 CFR 63 Subpart S Section 63.443(d)(1), reducing high volume low concentration sources of methanol (i.e., from the digester system and evaporator system) by 98% or more by weight, incorporated in its original Title V Operating Permit. Final test results showed it could remove approximately 4 times more methanol than required by 40 CFR 63 Subpart S Section 63.443(d)(1), by collecting the condensate from the Blow Heat Recovery Direct Contact condenser along with liquid discharges from the Nash vacuum pump on the gases leaving the Blow Heat Recovery Direct Contact Condenser and the 2 evaporator Nash vacuum pumps that pulled gaseous emissions from the 4th and 5th effects of the evaporators. This alternative methanol reduction strategy was done in that taking the Blow Heat Condenser Direct Contact Condenser gaseous emissions and the gaseous emissions from the two evaporators for combustion in the Recovery Kiln or another combustion device were very low concentration sources of methanol and the cost to pipe them to the Recovery Kiln or another combustion device would cost 1 million dollars, and would remove very little total methanol emissions, approximately 10 tons per year as compared to 40 tons methanol removed per year by the alternate methanol reduction strategy. See the emissions calculations provided above for the proof of compliance.






In addition, Groveton Paper Board was required to complete performance testing for 40 CFR 63 Subpart MM to show it could meet the total hydrocarbon (THC) emissions limitation of 2.97 lb THC per ton of black liquor solids fired from the Recovery Kiln in Section 63.862(c)(2)(i). Note that Groveton Paper Board did several tests to show it could operate the Recovery Kiln with center-firing or front-end firing of the black liquor in the Recovery Kiln. Groveton Paper Board uses its two combustibles monitors readings to show continuous compliance with this emissions limitation and DES placed these operating parameter ranges for the Ametek continuous combustibles monitors in its original Title V Operating Permit via a Minor Permit Modification on April 14, 2006. The following operating parameter ranges for the combustibles analyzers (Ametek is the brand or name of the combustibles monitors) were added to the Title V Operating Permit:

1. 1900 ppm as methane Ametek reading corrected to 12% oxygen (all wet basis)



In addition to including the operating parameter ranges for the combustibles monitors, DES included several updates to the Subpart MM monitoring requirements which were published in the Federal Register after the original Title V Operating Permit was issued.

SITE VISITS/INSPECTIONS

Date Brief Description April 18, 2006 Offsite Full Compliance Evaluation completed. No items need to be addressed, the facility is in

full compliance with all permit terms and conditions.

COMPLIANCE REPORTS/EMISSION FEES

Annual emissions report and fees for calendar year 2005 received on April 10, 2006.

Below is a Table summarizing facility wide emissions of criteria pollutants for the last 5 years.

Year Total Particulate

Matter (tons/yr)

Sulfur Dioxide (tons/yr)

Nitrogen Oxides

(tons/yr)

Carbon Monoxide (tons/yr)

Non-methane Volatile Organic

Compounds (tons/yr)

HAPs & RTAPs

(tons/yr)

2001 15.51 2.74 17.27 208.45 102.54 11.20

2002 36.47 12.00 71.32 7.44 54.67 5.68

2003 16.24 4.57 68.46 7.08 45.99 4.76

2004 15.52 3.77 70.20 7.26 49.11 5.39

2005 14.71 6.69 69.15 19.95 43.55 4.93






REVIEW OF REGULATIONS

State–only Enforceable Regulations • Env-A 404.01 – Applicable facility wide - State acid rain requirement for Class B sources, average emission rate

of 1.6 pounds sulfur dioxide per million Btu heat input, equivalent to No. 6 oil with 1.5% sulfur by weight. • Env-A 609.01(a) – Applicable facility wide - Requirement for “major sources” to obtain a Title V Operating

Permit. • Env-A 1400 – Applicable facility wide – State Air Toxics Program - Facility is in compliance. Retention of

ambient air modeling analysis on site. • Env-A 2002.02(c)-(f) – Applicable to EU1 & EU2 (Boilers #4 & #5) - Opacity exemptions.

Federally Enforceable Regulations

• Env-A 1203.05 – Applicable to EU7 (Recovery Kiln) - 20% opacity requirement. • Env-A 1203.09 – Applicable to EU7 - Particulate matter emission limit. • Env-A 1211.06(c)(1)b. and Env-A 1211.06(d) – Applicable to EU3 & EU4 (Combustion Turbines #1 & #2 or

CT’s #1 & #2) - NOx RACT emissions limits of 25 ppmvd at 15% oxygen dry basis while firing natural gas and 65 ppmvd at 15% oxygen for while firing No. 2 fuel oil in the CT’s. Note that these emission limitations are more stringent than 40 CFR 60 Subpart GG Section 60.332(a)(2).

• Env-A 1211.05(c)(3)a.1. & 2. – Applicable to EU5 & EU6 (Duct Burners #1 & #2 and HRSG Units #1 & #2) when operating at less than 100 MMBtu/hr - 0.10 lb NOx/MMBtu emission limit and low NOx burner requirements for the Duct Burners and HRSG’s.

• Env-A 1211.05(d)(3)a.2. – Applicable to EU1 & EU2 - Requirement to use low NOx burners. • NOx RACT Order ARD-95-001 – Applicable to EU7 - 0.85 lbs NOx/ton of black liquor solids fired during any

24-hour period while firing spent liquor solids and fuel oil and 34 lbs NOx/1000 gallons of No. 2 fuel oil while firing No. 2 fuel oil in the Recovery Kiln. Please note that the testing conducted by Groveton for the NOx RACT limit of 0.85 lb NOx per ton of black liquor solids was done while firing spent liquor only, without No. 2 fuel oil. However, the facility normally operates the Recovery Kiln with 1.5 gallons per minute of No. 2 fuel oil to aid in complete combustion and recovery of cooking chemicals on a daily basis. DES and Groveton Paper should have conducted testing of the combined combustion of spent cooking liquor and No. 2 fuel oil in establishing the NOx RACT limit for the Recovery Kiln. The facility only burns No. 2 or No. 6 fuel oil alone when it is initially warming up the Recovery Kiln after a short or long outage.

• Env-A 1604.01(a) & Temporary Permit FP-T-0051 – Applicable facility wide - Sulfur content limit of 0.4% sulfur by weight for No. 2 fuel oil.

• Env-A 1604.01(c)(1) & State Permit to Operate PO-BP-2240 – Applicable only to the Recovery Kiln - 2.2% sulfur content by weight limit in No. 6 fuel oil.

• Env-A 2002.02 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU6 - 20% opacity limit for Boilers #4 & #5, CT’s #1 & #2, and HRSG’s #1 & #2.






• Env-A 2002.08 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU6 - Particulate matter emission limitation of 0.15 lb/MMBtu. Note that Temporary Permit FP-T-0051 had more stringent particulate matter emissions limitations than this as the facility counted on lower emissions of several criteria pollutants in order to net out of Prevention of Significant Deterioration (PSD) and Non-Attainment program requirements.

• State Permit to Operate PO-BP-2240 – Applicable to EU7 – This permit has several federally enforceable operating and emission limitations for the Recovery Kiln, including the following: 12.8 MMBtu/hr maximum heat input rate from No. 2 fuel oil; maximum oil firing rate of 307 MMBtu/day gross heat input rate from No. 2 fuel oil; maximum oil firing rate of 58.9 MMBtu/day gross heat input rate from No. 6 fuel oil with a maximum sulfur content of 2.2% sulfur by weight; minimum 200 gallons per minute water or liquid recycle rate for the Peabody Wet Venturi Scrubber on the Recovery Kiln; and minimum of 100 gallons per minute shower wash flow and voltage range greater than 30 kilovolts DC for the Wet Electrostatic Precipitator on the Recovery Kiln.

• Temporary Permit FP-T-0051 – Applicable to EU3 through EU6 - This was the initial construction permit issued for the 2 new Combustion Turbines with Heat Recovery Steam Generators at Groveton Paper Board. In addition, this permit and the Temporary Permit FP-T-0050 issued to Wausau Papers of New Hampshire took Boilers #1 and #2 and put them in Wausau’s Temporary and Title V Operating Permit and took away Boilers #4 & #5 from Wausau’s Title V Operating Permit and assigned them to Groveton Paper Board in its new Temporary Permit and later issued Title V Operating Permit. This Temporary Permit included maximum operating rates in MMBtu/hr gross heat input rate, maximum fuel firing rates for the various fuels fired in these devices, and sulfur content limitations on liquid fuels. In addition, there was an operating limit of 363 days per consecutive 365 day period for Boilers #4 & #5, Combustion Turbines #1 & #2, and Heat Recovery Steam Generating Units #1 & #2 for purposes of netting out of Non-Attainment program requirements. Modeling conducted with the issuance of Temporary Permit FP-T-0051 had operating restrictions of using No. 6 fuel oil with a maximum sulfur content of 0.5% sulfur by weight in Boilers #4 & #5 at the Groveton Paper Board facility and likewise at the Wausau Papers of New Hampshire facility in order to meet the National Ambient Air Quality Standards for sulfur dioxide. In addition, modeling imposed a less than 3 consecutive hours per 24-hour period when both Combustion Turbines are burning No. 2 fuel oil at the same time, while discharging through their bypass stacks. This restriction only applies if Boilers #1, #4, & #5 are burning No. 6 fuel oil at maximum load during the same time period. This Temporary Permit also included Federally enforceable emissions limitations for EU1 through EU6, some of which are more stringent than 40 CFR 60 Subpart GG and the New Hampshire Code of Administrative Rules Chapters Env-A 100 et seq. These emissions limits are included in the separate Table 6B in this Title V Operating Permit.

• Temporary Permit TP-B-0524 – Applicable to EU7 – 50.23 tons NOx per consecutive 12 month period for the Recovery Kiln, maximum front end-firing of black liquor solids less than or equal to 6,600 lb black liquor solids/hr and maximum center-firing of black liquor solids less than or equal to 6,000 lb black liquor solids/hr.

• 40 CFR 52 or old rule Env-A 402.03 – Applicable facility wide - Sulfur content limit of 5 grains sulfur per 100 cubic feet of natural gas.

• 40 CFR 60 Subpart GG Section 60.333 – Applicable to EU3 & EU4 - Sulfur dioxide emission limitation of 0.015% sulfur dioxide by volume at 15% oxygen on a dry basis while firing natural gas.

• 40 CFR 63 Subpart MM Section 63.862(c)(2) – Applicable to EU7 - Note that 40 CFR 63 Subpart MM applies to Chemical Recovery Combustion Sources, which in this case is the Recovery Kiln or EU7 in the permit. This is the 2.97 lb total hydrocarbons per ton of black liquor solids fired emission limitation. There is an alternative of 90% reduction of THC, but that would be for an add-on control device, such as the Wet Venturi Scrubber or the Wet Electrostatic Precipitator. Each of these two devices has minimal effect on total hydrocarbons removal.






• 40 CFR 63 Subpart MM Section 63.860(c) – Applicable to EU7 - Essentially states that the Recovery Kiln is subject to the General Requirements to Table 1 in Subpart MM, various monitoring, testing, recordkeeping, and reporting requirements, which have all been included in the applicable sections of this Title V Operating Permit.

• 40 CFR 63 Subpart S Section 63.443(c) – Applicable to the Pulp Mill Blow Heat Recovery System (a low volume high concentration (LVHC) source of methanol, (EU8)) & (2) Evaporator Area LVHC sources (EU9) - This requirement if for collection of all LVHC sources of methanol in the digester and evaporator systems (LVHC sources are defined in the definitions section of Section 63.441). In the case of the Groveton Paper Board mill the 3 HVLC sources are the gaseous emissions from the pulp blow tank which go through a Direct Contact Condenser with shower water applied and on to a Nash type vacuum pump prior to discharging the gaseous emissions to the ambient atmosphere and the two evaporator sources, i.e., gaseous emissions from the 4th and 5th stage evaporators, which are routed to two Nash type vacuum pumps prior to being emitted to the ambient atmosphere.

• 40 CFR 63 Section 63.94 Equivalency By Permit, Item 32 in Table 6A – Applicable to EU8 & EU9 - Rather than complying with the 98% methanol removal requirement of 40 CFR 63 Subpart S Section 63.443(d), Groveton proposed using an alternative methanol reduction strategy which removes 4 times more methanol than required and the legally enforceable mechanism to include this alternative emission limitation, DES has used the Equivalency By Permit approach laid out in 40 CFR 63 Section 63.94. GPB shall achieve methanol emissions reductions equal to or greater than 98 percent, on a pound per oven dry ton basis, of the emissions from the digester blow tank direct contact condenser vent before the vacuum pump (EU8, the Pulp Mill Blow Heat Recovery System) and evaporator vacuum pumps (EU9, the two evaporator area LVHC sources). GPB shall use their existing three vacuum pumps and treat the condensates generated by those pumps to partially control the digester and evaporator vents. In addition, GPB shall reroute all of the digester blow tank direct contact condenser condensate (an additional source not regulated by the subject NESHAP) from use in open processes to controlling them in the wastewater treatment plant.

• 40 CFR 63 Subpart S Section 63.440(g) – Applicable to EU8 & EU9 - GPB must comply with the requirements of Table 1 of this Subpart (general monitoring, testing, recordkeeping, and reporting requirements, which are included in the applicable sections of this Title V Operating Permit for the Pulp Mill Blow Heat Recovery System and the two evaporator sources.

• 40 CFR 63 Subpart S Section 63.443(e)(1) – Applicable to EU8 & EU9 - Defines excess emissions. • 40 CFR 63 Subpart S Section 63.450 – Applicable to EU8 & EU9 - Collection requirements for the gaseous

emissions from the LVHC sources. • 40 CFR 63 Subpart S Section 63.453(o) – Applicable to EU8 & EU9 - Essentially requires the owner or operator

to establish minimum or maximum operating parameter ranges for the Direct Contact Condenser shower flow rate and seal water flow rate to the three Nash type vacuum pumps servicing the gaseous emissions leaving the blow tank (EU8) and the 4th and 5th effects of the evaporators (EU9). The wastewater treatment plant must achieve a 73% biochemical oxygen demand (BOD) removal rate in order for the owner or operator to achieve greater than 98 percent reduction of methanol from LVHC sources (EU8 & EU9). The Direct Contact Condenser must be operated with a minimum cooling water shower flow of 100 gallons per minute and a cooling water temperature of no greater than 210 degrees F. Condensates recovered from the blow heat recovery Nash type vacuum pump and the two evaporator Nash type vacuum pumps and the shower water to the Direct Contact Condenser are required to be hard-piped to the PL-13 Tank and this is source along with overflows from the PL-13 Tank are then required to be routed to the effluent sump pit for conveying in a closed pipe to the wastewater treatment plant for methanol destruction. The Direct Contact Condenser and the Evaporator bodies 2 through 5 are required to be operated under a vacuum no less than 0.01 inches of mercury. Requirement for a vacuum no






less than 0.1 inches mercury on the gaseous emissions leaving the Blow Tank to the Direct Contact Condenser and the bypass line to remain shut for venting to the atmosphere from the Blow Tank.

• 40 CFR 63 Section 63.94 Equivalency By Permit Item 42 in Table 6A – Gasketed covers required to prevent methanol emissions to the atmosphere from the top of the PL-13 Tank and the effluent sump pit, and a submerged overflow pipe from the PL-13 Tank to the effluent sump pit.

• 40 CFR 63 Subpart S Section 63.6(e) – Applicable to EU8 & EU9 - This is mostly the operation and maintenance requirements, which is largely having a startup, shutdown, and malfunction plan for the HVLC sources.

• 40 CFR 64 – Compliance Assurance Monitoring (CAM) – Not applicable. There are no pollution controls on Boilers #4 & #5 (EU1 & EU2), Combustion Turbines #1 & #2 (EU3 & EU4), or Heat Recovery Steam Generator Units #1 & #2 (EU5 & EU6). In addition, EU7-EU9 are sources which must comply with 40 CFR 63 Subparts S and MM, therefore, they are exempt from CAM requirements as listed in Section 64.2(b)(1)(i).

• CAAA 112(r)(1) – Applicable facility wide - Accidental Release Program Requirements – Purpose and general duties clause of the 1990 Clean Air Act Section 112(r)(1).

• Env-A 806.05 & Temporary Permit FP-T-0051 – Applicable facility wide - Fuel sulfur content verification for fuel oils.

• State Permit to Operate PO-BP-2240 & 40 CFR 70.6(a)(3) – Applicable to EU7 - Continuous monitoring of wet venturi scrubber liquor flow and shower water flow to the wet electrostatic precipitator and operation and maintenance requirements.

• Temporary Permit FP-T-0051 & 40 CFR 70.6(a)(3)(i)(B) – Applicable to EU1 through EU6 - Fuel monitoring required for EU1 through EU6.

• 40 CFR 60 Subpart Db Section 60.49b(d) & (g) – Applicable to the Duct Burners on HRSG Units #1 & #2 – Records of daily fuel consumption, etc.

• 40 CFR 60 Subpart Db Section 60.48b(h) – Applicable to the Duct Burners on HRSG Units #1 & #2, when fresh air firing above 100 MMBtu/hr – No NOx CEMS are required for the Duct Burners on HRSG Units #1 & #2.

• 40 CFR 60 Subpart GG Section 60.334(h)(3) – Applicable to EU3 & EU4 - Natural gas sulfur and nitrogen content verification. As long as the owner or operator combusts pipeline quality natural gas and has records from its performance testing that the natural gas meets the 20 grains sulfur per 100 cubic feet of natural gas requirement, it is not required to do any further testing of its natural gas combusted in the CT’s. Pipeline natural gas is exempt from the nitrogen content testing or monitoring required by Subpart GG.

• 40 CFR 60 Subpart GG Section 60.334(b)(2) – Applicable to EU3 & EU4 – Verification of sulfur content of fuel oil fired in the CT’s. The owner or operator keeps No. 2 fuel oil delivery receipts for proof of compliance with the 0.5% sulfur by weight limit in Subpart GG. New Hampshire requires No. 2 fuel oil to be less than 0.4% sulfur by weight.

• Env-A 802 and 803 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU7 – General stack testing and NOx RACT stack testing requirements.

• Env-A 3705.01(b) & Temporary Permit FP-T-0098 – Applicable to EU3 & EU4 - Monitoring electrical power generation.

• 40 CFR 63 Subpart S Section 63.453(a) – Applicable to EU8 & EU9 – Requirements for continuous monitors for the Pulp Mill Blow Heat Recovery System and 2 Evaporator area Nash type vacuum pumps.

• 40 CFR 63 Subpart S Section 63.453(m) & Equivalency by Permit – Applicable to EU8 & EU9






o Installation, calibration, operation, and maintenance of a vacuum sensor and monitor and vent open monitor on the digester blow tank line.

o Installation, calibration, operation, and maintenance of a temperature indicator and continuous recorder and a flow meter with continuous recorder on the cooling water supply to the Blow Heat Direct Contact Condenser.

o Installation, calibration, operation, and maintenance of a flow meter and continuous recorder on the condensate flow from the PL-13 Tank to the Groveton Paper Board effluent sump pit.

o Installation, calibration, operation, and maintenance of a vacuum monitor and continuous recorder on the Direct Contact Condenser to ensure the blow heat recovery system Nash type vacuum pump is continuously pulling a vacuum and is recovering methanol from the exiting blow heat condenser outlet gas stream.

o Installation, calibration, operation, and maintenance of a vacuum monitor and continuous recorder on each of the evaporator effects (5) to ensure the evaporator Nash type vacuum pumps are continuously pulling a vacuum and recovering non-condensibles with methanol from the evaporator area LVHC sources.

o Wastewater Treatment Plant operators are required to fill out logsheets as required by their NPDES Permit with certain operating parameters to ensure the treatment plant achieves the 73% BOD removal efficiency required.

o Procedures for calculating quarterly methanol emissions reductions. o Visual inspection requirements for the condensate collection and transport system. o Visual inspection of each enclosure and closed-vent system requirements.

• 40 CFR 63 Subpart S Section 63.453(n) – Applicable to EU8 & EU9 - Procedures for reestablishing operating parameter ranges.

• 40 CFR 63 Subpart S Section 63.457(f) – Applicable to EU8 & EU9 - The owner or operator shall measure the total HAP concentration as methanol for EU8 and EU9 testing done.

• 40 CFR 63 Subpart MM Section 63.864(e)(14) and (j) – Applicable to EU7 – Procedures for establishing an alternative monitoring request for using an air pollution control system other than an ESP, wet scrubber, RTO, or fabric filter. The owner or operator is using their distinctive combustion process in the Recovery Kiln with front end firing or center firing to meet the 2.97 lb THC per ton of black liquor solids fired emission limit and using its Ametek combustibles analyzer to show compliance and submitted its test results and operating parameter ranges for the Ametek to ensure compliance on a continuous basis.

• 40 CFR 63 Subpart MM Section 63.864(k)(1)(vi) – Applicable to EU7 – If the monitoring exceedances occur, i.e., Ametek readings are outside the range based on a 3-hour average value, the owner or operator is required to take corrective actions and document them.

• 40 CFR 63 Subpart MM Section 63.864(k)(2)(vii) – Applicable to EU7 – If six or more 3-hour average values of the Ametek meter readings are out of range, it is considered a violation of the emission limitation of 2.97 lb THC/ton black liquor solids fired.

• 40 CFR 63 Subpart MM Section 63.864(k)(3) – Applicable to the EU7 – For purposes of determining the number of Ametek monitoring exceedances, no more than one exceedance will be attributed in any given 24-hour period.

• State Permit to Operate PO-BP-2240 – Applicable to EU7 – Requirement for the owner or operator to monitor and keep records of pounds or tons of black liquor solids fired per day for the Recovery Kiln and daily consumption of No. 2 fuel oil and No. 6 fuel oil fired by the Recovery Kiln.

• Env-A 803 & Temporary Permit TP-B-0524 – Applicable to EU7 - NOx RACT testing required for the Recovery Kiln once every 3 years and what is required to be obtained in testing.

• Env-A 902.01 & 40 CFR 70.6(a)(3)(ii)(B) – Applicable facility wide - 5 year record retention requirement. • 40 CFR 70.6(a)(3)(iii)(A) – Applicable facility wide - Maintenance of records of monitoring and testing

requirements specified from Table 7.






• Env-A 3103.08 & Temporary Permit FP-T-0051 – Applicable to EU3 through EU7 - NOx Discrete Emissions Reductions recordkeeping and public availability requirements.

• 40 CFR 60 Subpart A Section 60.7(b) – Applicable to EU3 through EU6 - Startup, shutdown, and malfunction recordkeeping requirements.

• 40 CFR 60 Subpart A Section 60.7(c) – Applicable to EU3 through EU6 – Record retention requirements for continuous monitoring systems for the CT’s and HRSG’s.

• Temporary Permit FP-T-0137 – Applicable to EU1 through EU6 - The owner or operator shall retain copies of performance testing conducted on the CT’s and HRSG’s and Boilers.

• Temporary Permit FP-T-0051 – Applicable to EU3 through EU6 – Recordkeeping requirements for the CT’s and HRSG’s: Hours of operation each day of each unit, hours of operation in the fresh air makeup mode for the HRSG’s when the CT is off-line, running total days of operation of the Boilers, CT’s, and HRSG’s, records of fuel oil sulfur content for all deliveries, and criteria pollutant emissions for all combustion devices.

• Temporary Permit FP-T-0051 & 40 CFR 70.6(a)(3)(i)(B) – Applicable to EU1 through EU6 – Fuel use recordkeeping requirements.

• 40 CFR 60 Subpart Db Section 60.49b(d) – Applicable to EU5 & EU6 when fresh air firing above 100 MMBtu/hr – fuel recordkeeping requirements.

• 40 CFR 60 Subpart Db Section 60.49b(g) – Applicable to EU5 & EU6 when fresh air firing above 100 MMBtu/hr – daily recordkeeping requirements.

• Temporary Permit FP-T-0051 – Applicable to EU1 & EU2 – Daily recordkeeping requirements. • Env-A 806.05 & 40 CFR 70.6(a)(3) – Applicable facility wide – Retention of fuel oil delivery receipts which

indicate the sulfur content of each load delivered. • Env-A 3704.01, 3706.01, 3707.03, & Temporary Permit FP-T-0051 – Applicable to EU1 & EU2 – Keeping

records of power generation of the CT’s and calculations of monthly and annual NOx emissions and NOx emissions fund fees for the CT’s on a monthly basis using power generation records.

• 40 CFR 63 Subpart S Section 63.454(a) – Applicable to EU8 & EU9 – Comply with the recordkeeping requirements of 40 CFR 63 Subpart A Section 63.10 as shown in Subpart S Table 1. All of these recordkeeping requirements are included in this Title V Operating Permit.

• 40 CFR 63 Section 63.94 Equivalency by Permit – Applicable to EU8 & EU9 – Item 17 in Table 8 contains records to be kept by the owner or operator for the alternative control option or site-specific methanol reduction strategy. Essentially this requires the owner or operator to keep records of all of the continuous monitoring system data for the operating parameters required to show compliance with the 98% methanol reduction requirement in 40 CFR 63 Subpart S Section 63.443(d).

• 40 CFR 63 Subpart S Section 63.454(b) – Applicable to EU8 & EU9 – Records of the site specific inspection plan for each applicable enclosure opening, closed-vent system, and closed collection system (hard piping condensates to the PL-13 Tank and the outflow of the PL-13 Tank to the effluent sump pit and covering of the effluent sump pit and the closure on the top of the PL-13 Tank. This includes inspection results and corrective actions taken.

• 40 CFR 63 Subpart MM Section 63.866(a) – Applicable to EU7 – Developing and keeping records of the startup, shutdown, and malfunction plan for the Recovery Kiln.

• 40 CFR 63 Subpart MM Section 63.866(b) – Applicable to EU7 – Keep records of any occurrence when corrective action is required by Section 63.864(c)(1), and when a violation is noted under Section 63.864(c)(2).






• 40 CFR 63 Subpart MM Section 63.866(c) – Applicable to EU7 – Records of operational information for the Recovery Kiln that must be maintained on a continuous basis.

• Env-A 903.03 & Temporary Permit FP-T-0051 – Applicable facility wide - General recordkeeping requirements for all combustion sources.

• 40 CFR 70.6(a)(9) – Applicable to EU1 through EU6 - Keep records of which alternate operating scenario the facility is operating under on a continuous basis.

• Env-A 901.04(old rule from the State Implementation Plan) – Applicable facility wide - Keep annual records of actual emissions for each significant and insignificant activity at the facility for determination of emission-based fees.

• Env-A 903.02 & Temporary Permit TP-B-0524 – Applicable to EU7 - General recordkeeping requirements for process operations.

• Env-A 905.02 & Temporary Permit FP-T-0051 – Applicable facility wide - NOx recordkeeping requirements. • Env-A 904.02 & Temporary Permit FP-T-0051 – Applicable facility wide - VOC recordkeeping requirements. • Env-A 906 & Temporary Permit TP-B-0524 – Applicable to EU7 - Additional Recordkeeping Requirements –

Keep records of 12-month running total of Recovery Kiln NOx emissions for tracking against the 50.23 tons per consecutive 12 month period NOx emission limitation for the Recovery Kiln.

• 40 CFR 70.6(a)(3)(iii)(A) – Applicable facility wide - Semi-annual monitoring, testing, and permit deviation summary report.

• Env-A 908 & Temporary Permit FP-T-0051 – Applicable facility wide – Annual VOC emissions report. • Env-A 909 & Temporary Permit FP-T-0051 – Applicable facility wide – Annual NOx emissions report. • Env-A 3704.01(b) & Temporary Permit FP-T-0051 – Applicable to EU3 & EU4 - NOx emitting generating

sources are not required to pay NOx emission reduction fund fees for the first 7 lbs NOx per megawatt-hour of electricity produced. The owner or operator’s CT’s are less than 7 lb NOx per megawatt-hour at this current time.

• Env-A 3706.02 & Temporary Permit FP-T-0051 – Applicable to EU3 & EU4 – Submit annually by April 15th the previous calendar years monthly actual NOx emissions and monthly power generation for the CT’s.

• Env-A 3707.01(a), 3707.02, 3707.04, & Temporary Permit FP-T-0051 – Applicable to EU3 & EU4 – Submission of annual NOx emission fund fees along with the calculations to determine annual fees.

• Env-A 907.01 & Temporary Permit FP-T-0051 – Applicable facility wide – Annual emissions report. • Env-A 705.04(new rule), Env-A 704.03(old rule in SIP) – Applicable facility wide – Payment of annual

emission-based fees. • Env-A 3104.08 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU6 – Annual discrete emissions

reduction trading program notice of intent to use DERs reporting requirement. • Env-A 3104.09 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU6 – Discrete emissions

reduction trading program notice and certification of use reporting requirement. • Env-A 3103.08 & Temporary Permit FP-T-0051 – Applicable to EU1 through EU6 – Discrete emissions

reduction trading program notice and certification of generation reporting requirement. • 40 CFR 60 Subpart A Section 60.7(c) - Applicable to EU3 & EU4 – Excess emissions reporting requirements for

the CT’s.






• 40 CFR 63 Subpart S Section 63.455(a) – Applicable to EU8 & EU9 – General reporting requirements for Subpart S, which are included in Table 1 to Subpart S. DES has included the appropriate reporting requirements from Table 1 to Subpart S in this Title V Operating Permit.

• 40 CFR 63 Section 63.94 Equivalency by Permit – Applicable to EU8 & EU9 – Quarterly excess emissions report and quarterly performance summary reporting requirements for the alternative methanol reduction strategy.

• 40 CFR 63 Subpart MM Section 63.867(c) – Applicable to EU7 – Recovery Kiln excess emissions reporting requirements.

• Env-A 910.01 & Temporary Permit TP-B-0524 – Applicable to EU7 – Annual reporting of the monthly running 12 month total NOx emissions for the Recovery Kiln to show compliance with the rolling 12 month total emissions cap of 50.23 tons NOx.

• 40 CFR 70.6(a)(3)(iii)(B) – Applicable facility wide - Prompt reporting of permit deviations within 24 hours of occurrence to DES and in accordance with Section XXVIII of the permit.

• 40 CFR 70.6(c)(1) – Applicable facility wide – The truth, accuracy, and completeness statement and signature by the responsible official on all reports submitted to DES or EPA.

• 40 CFR 70.6(c)(1) – Applicable facility wide – Annual compliance certification report submittal by April 15th each year for the previous calendar year.

CHANGES FROM PREVIOUS PERMIT

This permit contains two Combustion Turbines that were like-kind replacements of the existing Combustion Turbines, as Solar has a routine maintenance policy of swapping out the “gas producer and power turbine modular component exchange”. Combustion manufacturers have an exchange fleet of gas producer and power turbine modular components and perform an overhaul of these units typically at operation levels of about 30,000 hours to maintain the life expectancy of the engine. Pre-Performance Testing and Performance Testing Requirements (Tables 7 & 8 of the original Title V Operating Permit TV-OP-040) after the physical modifications were done of the alternative control option for methanol reduction from the blow heat recovery system and evaporators was completed for proof of compliance with the emissions reductions required by 40 CFR 63 Subpart S and are not included in this permit. In addition, the owner or operator completed performance testing of the Recovery Kiln for compliance with 40 CFR 63 Subpart MM and is not included in this permit. Performance testing of the initial installation of Combustion Turbines and Heat Recovery Steam Generators was completed and is not included in this permit. A federally enforceable NOx emissions cap for the Recovery Kiln of 50.23 tons per consecutive 12 month period and the two operating limitations of 6,600 and 6,000 lb black liquor solids/hr for front end-firing and center-firing, respectively, have been added to this permit so the facility could opt out of Non-Attainment and PSD permitting and accommodate a change in the method of operation of the recovery kiln to allow for front-end firing of the black liquor solids in addition to its normal center-firing capability.






SUMMARY AND CONCLUSIONS

In summary, the combustion equipment and process operations will be capable of meeting all regulations and standards for air quality. A Title V Operating Permit has been drafted.

APPLICATION & OTHER COMMUNICATION FACILITY … · equipment, that their alternate control approach...

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