technical support document for draft air emission permit no. … · 2019. 6. 21. · technical...

Technical Support Document, Permit Number: 01700002-102 Page 1 of 47

Technical Support Document for

Draft Air Emission Permit No. 01700002-102

This technical support document (TSD) is intended for all parties interested in the draft permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the preliminary determination to issue the draft permit.

1. General information

1.1 Applicant and stationary source location

Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 2611 - Pulp Mills)

Sappi North America 2201 Avenue B Cloquet, Minnesota 55720-2155

Sappi Cloquet LLC 2201 Avenue B Cloquet, MN 55720-2155

Contact: Robert Schilling Phone: 218-879-2300

1.2 Facility description Sappi Cloquet, LLC (Sappi) is an existing pulp and paper mill which manufactures kraft paper pulp, Dissolving Wood Pulp (DWP), and fine coated paper. The pulp-making procedure starts with wood being delivered onsite, debarked, and chipped. The wood chips are then fed into ten batch digesters where they are cooked with white liquor and steam. Exhaust gases from the digestion process are collected by the non-condensable gas systems (NCG), which consist of VOCs (volatile organic compounds) and odorous total reduced sulfur compounds (TRS) including hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The NCGs are vented to and controlled by the Incinerator-Quencher-Scrubber (IQS) system. The incinerator thermally oxidizes VOC, HAP, and TRS compounds from the gas stream to produce carbon dioxide (CO2), sulfur dioxide (SO2), and water vapor. The scrubber portion of the IQS controls SO2.

After being discharged from the digesters the spent cooking liquor and pulp must be separated. The pulp is sent on to be washed, bleached, dried, and sheeted. The spent cooking liquor and pulp wash water are combined to make weak black liquor solids (BLS). The weak BLS are concentrated in evaporators to make strong BLS, which can then be combusted in the recovery boiler. NCGs from the evaporators are vented to the IQS. In the recovery boiler, the organic portion of the BLS is burned and provides steam for electricity or heat for other processes at the plant. The cooking chemicals collect as molten smelt at the bottom of the boiler. The recovery boiler is a primary source of all criteria pollutant emissions, as well as sulfuric acid (H2SO4), TRS, and Hazardous Air Pollutants (HAPs). Particulate matter emissions from the recovery boiler are controlled by a high-efficiency electrostatic precipitator (ESP).

The smelt from the recovery boiler is collected and dissolved in process water in the smelt dissolving tank (SDT) to make green liquor which is a mixture of sodium carbonate and sodium sulfide. The SDT emits particulate matter, sulfur dioxide (SO2), volatile organic compounds (VOC), TRS, and HAPs. Emissions from the SDT are controlled by a Spray Tower and a Ventri-Rod Scrubber operated in series. The green liquor is then fed to the causticizers with slaked lime which reacts to produce white liquor. The white liquor is then returned to the fiberline to produce more pulp. Calcium carbonate (lime mud) is the byproduct of this


reaction. The lime mud is sent to the Lime Kiln where it undergoes a calcination reaction to reproduce lime (CaO) and CO2 . The lime kiln is a source of all criteria pollutants, in addition to H2SO4 , TRS, and HAPs. Particulate matter emissions are controlled by a high-efficiency, dry ESP.

Other major sources of emissions are from the three power boilers #7, #8, and #9. Boilers #7 and #9 are permitted to burn distillate oil, natural gas, wood waste, and sludge, and are also used as backup controls for NCGs. Particulate matter emissions from boiler #7 and #9 are controlled by multiclones and high-efficiency ESPs at each boiler. Power boiler #8 combusts natural gas and distillate oil. All three boilers are used to produce steam for electrical generation for use on site and for process heat.

Other emission sources include the bleach plant, paper machines #4 and #12, a coater, a market pulp machine, an emergency generator, a fire pump, a cooling tower, a research and development (R&D) boiler, and fugitive particulate matter sources such as dust from wood piles, paved and unpaved roads, track-out, a fuel yard, ash handling, and a landfill. The bleach plant consists of a chlorine dioxide plant and a bleach line. Chlorine dioxide emissions from the bleach plant and chlorine dioxide plant are controlled by a gas scrubber and a packed tower scrubber; the bleaching system is also a significant source of carbon monoxide (CO) and VOC emissions.

1.3 Description of the activities allowed by this permit action This permit action is a Part 70 reissunace, which incorporates all outstanding permit applications listed below. In addition to the reissuance, a major permit amendment (IND20180001) was incorporated into the permit to increase the permit limit for NOx for the Incinerator-Quencher-Scrubber (IQS) (EQUI 49). This permit also rolls in a major PSD (Prevention of Significant Deterioration) permit amendment (IND 20190002) to increase the throughput limits for BLS and steam production for the recovery boiler (EQUI 53). This permit action authorizes two performance test extensions (IND20170001, IND20190001) for the IQS (EQUI 49) and a performance test extension (IND20180006) for Boiler #7 (EQUI 2). These requests are to coordinate testing of similar pollutants, or to coordinate test dates on an EQUI. This permit action authorizes a permit reopening to increase the steam limit for the recovery boiler (EQUI 53). This was authorized through a performance test NOC dated 8/15/2015 (This limit is being increased again through the major amendment described below).

NOx limit increase for Incinerator-Quencher-Scrubber (IQS) (EQUI 49). Sappi proposed to increase the nitrogen oxides (NOx) limit for the Incinerator-Quencher-Scrubber (IQS) (EQUI 49). The limit in the existing permit is 9.1 pounds per hour (lb/hr) of NOx and the basis for the limit is cited as a Title I Condition under 40 CFR 52.21(k)(modeling) and MN Rules 7007.3000. The limit is being increased to 12.0 lb/hr in this permit. This project requires a major amendment under Minn. R. 7007.1500, subp. 1(B) because Sappi seeks to amend the NOx limit established through previously conducted modeling. This change is not subject to New Source Review (NSR) and this change is in compliance with applicable NAAQS (National Ambient Air Quality Standards).

Based on the calculation methodology, this increase does not trigger applicability of an EAW associated with the revised NOx limit on the IQS. Sappi has completed EBD (Equivalent or Better Dispersion) Modeling and submitted a Modeling Protocol to MPCA demonstrating compliance with the SIL for NOx under a 12.0 lb/hr NOx limit. A BACT (Best Available Control Technology) analysis was submitted as a part of this application to account for PSD regulations not considered when the IQS was originally permitted as a Pollution Control Project. More information can be found in section 3 below.


EQUI 53 (Recovery Boiler) BLS and Steam throughput increases This project requires a major permit amendment because the emissions increase that will result from the increase in production capacity requires PSD review (found in section 3 below). Sappi is requesting to combust 6.10 million pounds of black liquor solids per day. The mill currently has a limit on steam production established through performance testing for the recovery boiler (EQUI 53) of 853,000 pounds of steam per hour, which is requested to be increased to 925,000 pounds of steam per hour with this project. This project increases emissions of all criteria pollutants, some HAPs, and GHG, as it debottlenecks other units at the facility. The largest emission increase is NOx.

1.4 Description of notifications and applications included in this action Table 2. Notifications and applications included in this action

Date received Application/Notification type and description

9/15/2017 Administrative Amendment (IND20170001)



8/15/2018 Permit Reopening (IND201800003)

4/4/2018 Major Amendment (IND20180001)

1/24/2019 Major Amendment (IND 20190002)

8/29/2016 Part 70 Reissuance (IND20160002)

1.5 Facility emissions

Table 3. Title I Emissions Summary-Major Amendment NOx limit increase (IND20180001) for EQUI 49

Pollutant

Projected actual emissions

*

(tpy)

Baseline actual emissions

**

(tpy)

Projected emissions increase

(tpy)

NSR significant thresholds for major sources

(tpy)

NSR

review required? (Yes/No)

PM 0 0 0 25 No

PM10 0 0 0 15 No

PM2.5 0 0 0 10 No

NOx 52.56 36.33 16.2 40 No

SO2 0 0 0 40 No

CO 0 0 0 100 No

Ozone (VOC) 0 0 0 40 No

Lead 0 0 0 0.6 No

CO2e*** 0 0 0 75,000 No

*Projected Actual Emissions as defined in 40 CFR § 52.21(b)(41). **Baseline Actual Emissions as defined in 40 CFR § 52.21(b)(48). Baseline period for NOx calculations is calendar years 4/1/2014-3/31/2016 ***Carbon dioxide equivalents as defined in Minn. R. 7007.0100.


Table 4. Title I Emissions Summary Major Amendment (IND20190002) for EQUIs 7, 49, 50, 51, 52, 53 and FUGI 6 (Recovery Boiler throughput increase)

Pollutant

Projected actual emissions

*

(tpy)

Baseline actual emissions

**

(tpy)

Excludable emissions

(tpy)

Projected emissions increase

(tpy)

NSR significant thresholds for major sources

(tpy)

NSR

review required? (Yes/No)

PM 193.89 149.08 NA 44.80 25 Yes

PM10 164.50 126.43 NA 38.07 15 Yes

PM2.5 131.57 101.15 NA 30.42 10 Yes

NOx 1,062.06 844.96 NA 217.10 40 Yes

SO2 12.98 9.49 NA 3.49 40 No

CO 607.05 449.81 NA 157.24 100 Yes

Ozone (VOC) 52.64 41.80 NA 10.84 40 No

Lead 3.14E-02 2.413E-02 NA 7.27E-03 0.6 No

Fluorides N/A N/A NA N/A 3 No

H2S 8.23 6.33 NA 1.90 10 No

H2SO4 1.84 1.41 NA 0.43 7 No

TRS including H2S 13.2 10.26

NA

2.94 10 No

CO2e*** 1,352,426 1,043,940 NA 308,486 75,000 Yes

*Projected Actual Emissions as defined in 40 CFR § 52.21(b)(41). **Baseline Actual Emissions as defined in 40 CFR § 52.21(b)(48). Baseline period for PM, PM10, PM2.5, NOx. SO2, CO, VOC, Lead, H2S, TRS, and CO2e calculations is calendar years 4/1/2014-3/31/2016 ***Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

Table 5. Total facility potential to emit summary Table 6. *No*not reported in Minnesota emission inventory.

PM

tpy

PM10

tpy

PM2.5

tpy

SO2

tpy

NOx

tpy

CO

tpy

CO2e

tpy

VOC

tpy

Single

HAP

tpy

All

HAPs

tpy

TRS

tpy

Total facility limited potential emissions 677 690 443 5800 2540 26,600 2.2 E6 481 200 352 53.1

Total facility actual emissions (2017) 221 221 66.4 152 1440 1420 * 121 * *


Table 6. Facility classification

Classification Major Synthetic minor/area Minor/Area

New Source Review X

Part 70 X

Part 63 X

1.6 Changes to permit The MPCA has a combined operating and construction permitting program under Minnesota Rules Chapter 7007, and under Minn. R. 7007.0800, the MPCA has authority to include additional requirements in a permit. Under that authority, the following changes to the permit are also made through this permit action:

The permit has been updated to reflect current MPCA templates and standard citation formatting.

Completed requirements and the requirements for equipment that has been removed have been deleted.

Some requirements have been reordered to help with clarity (i.e., similar requirements are grouped).

CAM has been revised as discussed in Table 6 of this TSD.

40 CFR pt. 63, subps. A, S, MM, JJJJ, and DDDDD requirements that were previously listed at the Total Facility level have been moved to the appropriate sections of the permit for applicability reasons.

Requirements for COMG 3 (Process Condensates) have been updated for kraft pulp process HAPs-containing condensates collection and treatment.

Requirements for COMG 7 (NESHAP 5D Group) have been updated, use of COMs requirements moved to the applicable EQUI, etc…

The Steam limit for EQUI 53 (RB10) was increased through testing NOC (permit reopening).

Requirement added to EQUI 304 for 40 CFR pt. 63, subp. subp. JJJJ applicable subp. A general provision requirements.

EQUI 316 Chip Pre-Steaming Bin was deleted from the permit. This was part of Air Permit No. 01700002-101, but Sappi has decided not to proceed with this project.

The testing frequency for EQUI 2 FPM have been relaxed from every year to every third as instructed in 40 CFR 63, pt. DDDDD.

Updated performance testing schedules (see more information in Section 3 of the TSD).

EQUI 369 (Clarke fire pump engine), a No. 2 diesel-fired, emergency engine was added to the permit as an insignificant modification under Minn. R. 7007.1250.

EQUI 42 (EU 88 Ozone bleaching system) moved to Insignificant Activity list. Air Permit No. 01700002-015 took out Title I conditions, replaced with MN performance standards. Testing has shown that this unit has minimal emissions. Test results are attached to this TSD. TREA 8 (catalytic converter) was also removed, as it is not required for permitting purposes.

EQUI 302 (Clarifier) moved to Insignificant activities list. Sappi tracks this unit through air toxics inventory.

EQUI 23 was removed from facility. This unit was reclassified in Air Permit No. 01700002-101 to coordinate with the Tank Permitting program, but wasn’t deleted then.

EQUI 294 (EU 016) was added to the COMG 2 (NCG group).

Test burn requirements were added to COMG 1 to allow for feasibility tests for biomass combustion.

Control efficiencies at TREAs throughout the permit were taken out. See section 3 for more detail.

SO2 modeling requirements were added at the TFAC level. See section 3 for more detail.

New groups were added to the permit: COMG 13 40 CFR pt. 63, subp. S general provisions COMG 14 40 CFR pt. 63, subp. MM general provisions


2. Regulatory and/or statutory basis 2.1 New source review (NSR)

The facility is an existing major source under New Source Review regulations. The NOx limit increase project is not subject to PSD/NSR. The EQUI 53 (Recovery Boiler) BLS and Steam throughput increases project is subject to PSD/NSR (see more information in Section 3 of the TSD). An Endangered Species Act (ESA) and National Historic Preservation Act (NHPA) consultation correspondence was submitted previously on January 31, 2017, to EPA Region 5 discussing the previous project scope for this project (Air Permit No. 01700002-101). The March 7, 2017, response from EPA stated that the Sappi Cloquet project was not likely to impact any threatened or endangered species present in Carlton County and no further consultation was necessary under Section 7 of the Endangered Species Act. The EPA’s response also indicated the project was not likely to affect historic properties and no further action was required under Section 106 of the NHPA.

2.2 Part 70 permit program The facility is a major source under the Part 70 permit program.

2.3 New source performance standards (NSPS) The Permittee has stated that the following New Source Performance Standards apply to the operations at this Facility.

40 CFR pt. 60, subp. BB – Kraft Pulp Mills: recovery boiler (EQUI 53), smelt dissolving tank (EQUI 51), and NCG incineration group (COMG 2). There is an updated standard (40 CFR Part 60, subpart BBa) for Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013. The Recovery Boiler was physically modified to add quaternary air injection in April, 2013 (prior to the effective date of the rule) therefore it is not subject to the updated standard.

40 CFR pt. 60, subp. BBa – Kraft Pulp Mills: lime kiln. The Air Permit No. 01700002-015 authorized modification of the Lime Kiln (EQUI 52). The Lime Kiln had been subject to 40 CFR pt. 60, subp. BB, but upon modification, is now subject to 40 CFR pt. 60, subp. BBa.

40 CFR pt. 60, subp. D – Fossil-Fuel-Fired Steam Generators: Power Boiler #9 (EQUI 4)

40 CFR pt. 60, subp. Db – Industrial-Commercial-Institutional Steam Generating Units: Recovery Boiler (EQUI 53)

40 CFR pt. 60, Subp. IIII - Stationary Compression Ignition Internal Combustion Engines: Emergency Fire Pump Engine (EQUI 315)

2.4 National emission standards for hazardous air pollutants (NESHAP)

The facility is an existing major source of HAPs and is subject to the following NESHAPs:

• 40 CFR pt. 63, subp. S - Pulp & Paper Industry

• 40 CFR pt. 63, subp. MM – Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand- alone Semichemical Pulp Mills

• 40 CFR pt. 63, subp. JJJJ - Paper and Other Web Coating (EQUI 304)


• 40 CFR pt. 63, subp. DDDDD - Industrial, Commercial, and Institutional Boilers and Process Heaters (EQUI 2, EQUI 4, EQUI 18, and EQUI 290)

• 40 CFR pt. 63, subp. ZZZZ - Stationary Reciprocating Internal Combustion Engines (EQUI 38, EQUI 315, EQUI 369)

A natural gas-fired emergency engine, Clarke fire pump (EQUI 369), is being added to the facility and is subject to 40 CFR pt. 63, subp. ZZZZ for stationary reciprocating internal combustion engines. It is a new stationary RICE, as defined at 40 CFR 63.6590(a)(2)(ii) because the engine is less than 500 brake Hp, the facility installed the stationary RICE after June 12, 2006, and Sappi is a major source of HAPs. The engine must comply with 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. JJJJ, as specified at 40 CFR 63.6590(c)(3). However, the engine does not fit any of the applicability requirements in 40 CFR 60.4230(a). Therefore, no requirements from 40 CFR pt. 63, subp. ZZZZ or 40 CFR pt. 60, subp. JJJJ apply. This was a similar situation to EQUI 38, added in Air Permit No. 01700002-101.

2.7 Compliance assurance monitoring (CAM) The table below lists the sources subject to CAM, the control equipment used, whether the source is a large or other pollutant specific emission unit (PSEU), and the pollutants triggering CAM. Table 7. CAM summary Unit Control CAM applicability Pollutant

EQUI 2 TREA 15 ESP Other PM/PM10/PM2.5

EQUI 4 TREA 19 ESP Large PM/PM10/PM2.5 EQUI 53 TREA 20 ESP Large PM/PM10/PM2.5

Numerous TREA 30 Incinerator and TREA 31 Scrubber Other TRS, VOC

EQUI 52 TREA 21 ESP Other PM/PM10/PM2.5

EQUI 51 TREA 6 Venturi Scrubber and TREA 12 Spray Tower Other TRS, PM/PM10/PM2.5

For large pollutant specific emission units, records of the monitored parameter must be made at a minimum of four times per hour, or once every 15 minutes. For other PSEUs (not large), records must be made at a minimum of once per 24 hours. See Attachment 3 to this document for the CAM Plan submitted by the applicant. In previous permits, there were pieces of equipment listed as control equipment that are better defined as inherent process equipment as defined in 40 CFR 64.1. Because of this designation, these units/control equipment are not subject to CAM and have been removed from the CAM Plan: • TREA 11 Multiclone – Particulate control for Boiler #7 (EQUI 2) • TREA 18 Multiclone – Particulate control for Boiler #9 (EQUI 4) This permit requires a CAM plan update to establish a correlation between opacity and particulate matter for TREA 20 ESP that controls the recovery boiler (EQUI 53). This is required to be submitted after Sappi’s initial performance tests for particulate matter.

2.8 Regulatory Overview Table 7. Regulatory overview of facility

Subject item* Applicable regulations Rationale



COMG 1 - Fuel limits: #7, #8 and #9 Boilers

Title I Condition: 40 CFR 52(k) (modeling) and Title I Condition: Avoid major

modification under 40 CFR

52.21(b)(2); Minn. R.

7007.3000

Prevention of Significant Deterioration. Fuel usage limits set for Boilers #7, #9 and #8, (EQUIs 2,4, and 18, respectively). Limits for wood and mill waste, fuel oil, and WWTP sludge.

COMG 2 - NCG System

40 CFR pt. 60, subp. BB; Minn. R. 7011.2450 A

Standards of Performance for Kraft Pulp Mills TRS control requirements

40 CFR pt. 63, subp. S; Minn. R. 7011.7700 A

National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry HAP emission and control requirements

COMG 3 - Process Condensates


National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry HAP emission and control requirements

COMG 7 - Air Component Group

40 CFR pt. 63, subp. DDDDD; Minn. R. 7011.7050

National Emission Standards for Hazardous Air Pollutants from Industrial, Commercial, and Institutional Boilers and Process Heaters

EQUI 2 – Boiler #7 40 CFR pt. 63, subp. DDDDD; Minn. R. 7011.7050


40 CFR pt. 64 CAM applies to EQUI 2as an “other” PSEU for PM, PM10 and PM2.5

Minn. R. 7011.0510 Standards of Performance for Existing Indirect Heating Equipment Determination of applicable limit from rule:

the unit started operation in 1965;

the facility is located outside the cities in Table I;

the unit capacity is greater than 250 MMBtu/hr

Title I Condition: 40 CFR 52.21(k)(modeling); Minn. R. 7007.3000

Prevention of Significant Deterioration. Modeling limits set for PM, PM10, PM2.5, SO2, CO, and NOx.

Title I Condition: Avoid major source under 40 CFR 52.21(b)(2); Minn. R. 7007.3000

Prevention of Significant Deterioration. Limits set on sulfuric acid mist to avoid major modification

Minn. R. 7007.0800, subp. 2(A), Minn. Stat. 116.07, subd. 4a

State-only mercury limit

EQUI 4 – Boiler #9 40 CFR pt. 60, subp. D Standards of Performance for Fossil-Fuel-Fired Steam Generators Determination of applicable limit from rule:

the unit started operation in 1981; • the unit capacity is greater than 250 MMBtu/h



40 CFR pt. 64 This unit is a Large PSEU for particulate controls.



Title I Condition: 40 CFR 52.21(k)(modeling); and

Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2); Minn. R. 7007.3000

Prevention of Significant Deterioration. Modeling and netting limits set for PM


Prevention of Significant Deterioration. Modeling limits set for PM10, PM2.5, CO, SO2, and NOx.


Prevention of Significant Deterioration. Limits set on sulfuric acid mist to avoid major modification



EQUI 7 – Bleach Plant

40 CFR pt. 63, subp. S; Minn. R. 7011.7700A

National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry

Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a

State-only chloroform and chlorine dioxide limits

Title I Condition: 40 CFR 52.21(j)(BACT); Minn. R. 7007.3000

Prevention of Significant Deterioration. BACT limits set for VOC and CO

EQUI 18 – Boiler #8 40 CFR pt. 63, subp. DDDDD; Minn. R. 7011.7050


Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment

PM, SO2, NOx, and opacity limits.


Prevention of Significant Deterioration. Modeling limits set for PM, PM10, PM2.5, SO2, and NOx.

EQUI 38 -

I&I Emergency Generator

Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

EQUI 49 - IQS -

Incinerator


National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry


State-only limits for PM, VOC, TRS, and H2SO4


Prevention of Significant Deterioration. Modeling limits set for SO2, NOx, CO, PM2.5 , and PM10

EQUI 50 – Market Pulp Machine

Minn. R. 7011.0715

Standards of Performance for Post-1969 Industrial Process Equipment Determination of applicable limits from rule: • the unit started operation in 1999

EQUI 51 - Smelt Dissolving Tank

40 CFR pt. 60, Subp. BB Standards of Performance for Kraft Pulp Mills

40 CFR pt. 63, subp. MM

National Emission Standards for Hazardous Air Pollutants from Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-alone Semichemical Pulp Mills




Prevention of Significant Deterioration. Modeling limits set for PM, PM10, PM2.5, and SO2


Prevention of Significant Deterioration. BACT limits set for VOC, TRS, PM, and PM10

40 CFR pt. 64 This unit is “Other” PSEU for particulate and TRS controls

EQUI 52 – Lime Kiln

40 CFR pt. 60, Subp. BB Standards of Performance for Kraft Pulp Mills


National Emission Standards for Hazardous Air Pollutants from Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-alone Semichemical Pulp Mills


Prevention of Significant Deterioration. Modeling limits set for PM, PM10, PM2.5, NOx, CO, and SO2


Prevention of Significant Deterioration. BACT limits set for VOC, NOx, TRS, CO, sulfuric acid mist, PM, PM2.5 , and PM10 , and also limit on Calcium Oxide Production Process Throughput



40 CFR pt. 64 This unit is “Other” PSEU for particulate controls.


Prevention of Significant Deterioration. Limits set on Calcium Oxide Production Process Throughput to avoid major modification

Limit set on NOx to avoid major modification.

EQUI 53 - Recovery Boiler #10

40 CFR pt. 60, subp. BB Standards of Performance for Kraft Pulp Mills


National Emission Standards for Hazardous Air Pollutants from Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-alone Semi-chemical Pulp Mills

40 CFR pt. 64 This unit is a Large PSEU for particulate controls.

40 CFR pt. 60, Subp. Db Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units


State-only mercury, CO, and NOX limits


Prevention of Significant Deterioration. Modeling limits set for PM, PM10, PM2.5, NOx, and SO2


Prevention of Significant Deterioration. BACT limits set for VOC, NOx, TRS, CO, sulfuric acid mist, CO2 equivalent, PM, PM2.5 , and PM10 , and also limits on fuel types

EQUI 261 - Methanol Tank

Title I Condition: 40 CFR 52.21(j)(BACT);

Minn. R. 7007.3000

Prevention of Significant Deterioration. BACT limit set for methanol

EQUI 290 - R&D Boiler



Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment

PM and opacity limits.



EQUI 298 - #4 Paper Machine

Minn. R. 7011.0715


EQUI 299 - #12 Paper Machine

Minn. R. 7011.0715


EQUI 304 - #13 Coater

40 CFR pt. 63, subp. JJJJ National Emission Standards for Hazardous Air Pollutants from Paper and Other Web Coating

EQUI 315 - Emergency Diesel Fire Water Pump

40 CFR pt. 60, subp. IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

40 CFR pt. 63, subp. ZZZZ National Emission Standards for Hazardous Air Pollutants For Stationary Reciprocating Internal Combustion Engines


EQUI 369 - Clarke fire pump engine


FUGI 2 - Cooling Tower

Minn. R. 7011.0715

Standards of Performance for Post-1969 Industrial Process Equipment

FUGI 6 - Paved Road


Prevention of Significant Deterioration. Modeling limits set for fugitive emissions of PM

FUGI 7 - Unpaved Roads


Prevention of Significant Deterioration. Modeling limits set for fugitive emissions of PM

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2, etc.).

The language 'This is a state-only requirement and is not enforceable by the U.S. Environmental Protection Agency (EPA) Administrator and citizens under the Clean Air Act' refers to permit requirements that are established only under state law and are not established under or required by the federal Clean Air Act. The language is to clarify the distinction between permit conditions that are required by federal law and those that are required only under state law. State law-only requirements are not enforceable by the EPA or by citizens under the federal Clean Air Act, but are fully enforceable by the MPCA and citizens under provisions of state law.

3. Technical information

EQUI 316 Chip Pre-Steaming Bin

This unit was deleted from the permit. This was part of Air Permit No. 01700002-101, but Sappi has decided not to proceed with this project. Sappi orginally planned on installing a chip pre-steaming bin to increase digester throughput capacity. However, Sappi determined it will be possible to increase pulp production without installing a chip pre-steaming bin by reducing digester cycle time by adding extra steam to the bottom of the digester during chip fill sequence. As a result, the chip pre-steaming bin was not installed, never will be, and therefore is requested to be removed from the permit. The proposed pulp production increase will still result in an increased production of black liquor solids (BLS) to be combusted in the recovery boiler (EQUI 53).


TREA 30/31 Requirements were clarified at TREA 30/31 to allow for alternative venting of IQS NCG to be combusted in the power boilers when TREA 30/31 are not operational. These TREAs work in series, so if either is not operational, emissions that are vented to the IQS system are vented to the power boilers for combustion. Control efficiencies at control equipment The control efficiencies were removed from the permit for cases where they are not used to calculate emissions and are not depended upon to limit a pollutant to below a regulatory threshold. These assumed control efficiencies were only used to back-calculate uncontrolled PTE; with Sappi being major for all pollutants, these control efficiencies do not need to be listed in the permit for any reason. While this is in conflict with normal practice and contradicts communications from EPA Region 5 on routine inclusion of control efficiencies in permits, we believe that in this specific case it is appropriate.

Natural gas combustion and ESP operation Sappi and their consultants did an extensive background study to show that they ESPs that control particulate matter from the power boilers (EQUIs 2 and 4) are not needed to meet particulate emission limits while burning natural gas only. Parts of this study can be found in TSD attachment 7. Performance Testing The performance test language for all units that show compliance through testing was updated throughout the permit using the updated Tempo profiles. The testing frequency for EQUI 49 NOx was changed from every 12 months to every 36 months in this permit action. Historically, this unit has consistently tested close to the permit limit of 9.1 lbs/hr NOx. Because the limit has been relaxed to 12.0 lbs/hr, and the test results have been consistent, the frequency for NOx testing was revised to every 36 months. In the last permit, 0170002-101, EQUIs 51 and 53 had testing requirements based on installation of EQUI 316. Sappi decided not to go ahead with that project and that piece of equipment was not installed. Because the steam limit and BLS limit increase for the recovery boiler (EQUI 53) also debottleneck and increase emissions from the SDT (EQUI 51), these units both have initial performance testing requirements for all pollutants on those units that show compliance through performance testing. EQUI 52 had initial performance testing requirements in the previous permit. The results for all pollutants, other than CO, were below 60% of permit limits. Testing frequency for those pollutants was set for every 60 months. The CO results were over 60% of the permit limits. Testing frequency for CO was set for every 36 months.

3.1 Emissions increase analysis

EQUI 49 (IQS) NOx limit increase The emission calculations for the proposed project were conducted according to federal Prevention of Significant Deterioration (PSD) requirements and are included in attachment 1 of this TSD. For the Prevention of Significant Deterioration (PSD) analysis, calculations were performed considering the IQS as an existing unit because it was permitted as a major modification under federal PSD rules and policy (PCP Project) at the time. Changes in emissions were determined based on the potential to emit to baseline actual emissions of NOx based on solely changing the existing NOx limit from 9.1 lb/hr to 12.0 lb/hr. There is no physical construction associated with this change, only the change to emission limit. Therefore, there is no emissions increase in any other pollutant associated with this change; any required PSD analysis would have been conducted prior to equipment installation for the other pollutants. Netting calculations and excludable emissions were not used in this PSD analysis.


BASELINE ACTUAL EMISSIONS (BA) Under PSD rules for existing units (other than electric utility steam generating units), baseline actual emissions means the average rate, in tons per year, at which the emissions unit actually emitted the pollutant during any consecutive 24-month period selected by the owner or operator within the 10-year period immediately preceding either the date the owner or operator begins actual construction of the project, or the date a complete PSD permit application is received by the Permitting Authority. A different 24-month period may be used for each pollutant. However, the same 24-month period must be used for all emissions units for a single pollutant. The baseline period selected for this project is April 2014 to March 2016. Process throughput and operating hours data for the IQS (EQUI 49) were taken from this time period. Baseline calculations were based on the results of the December 20, 2011 stack test. Baseline NOx emissions were determined to be 36.33 tons per year based on the period selected. POTENTIAL TO EMIT CALCULATIONS (PTE) This analysis is conducted using limited potential to emit compared to baseline actual emissions. As noted in 40 CFR § 52.21(b)(4): “Potential to emit means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Secondary emissions do not count in determining the potential to emit of a stationary source.” The limited potential to emit was calculated based on the proposed NOx limit of 12.0 lb/hr assuming the IQS will be operating at the maximum possible 8,760 hours per year. Potential emissions are 52.56 tons per year. SUMMARY OF EMISSION CALCULATIONS The project must be evaluated for applicability of federal PSD modification requirements because the existing facility constitutes a “major stationary source” under 40 CFR 52.21b(1)(i)(a). If emissions attributable to the project are shown to exceed certain PSD de minimis thresholds, otherwise known as significant emission rates, the modification must be reviewed under PSD as a “major modification” to a major stationary source. Emissions calculations evaluate emissions based on the limited potential emissions to baseline actual emissions given that the unit is an existing unit, however only NOx emissions are compared to the PSD significance level, since that is the only pollutant whose permit limit is proposed to be relaxed. Any required PSD analysis for other pollutants would have been conducted at the time of initial permit issuance. The potential to baseline actual emissions increase is found as the difference between the potential to emit and the baseline actual emissions:

PTE to BA Emissions Increase (tpy) = PTE – BA = 52.56 tpy NOx – 36.33 tpy NOX = 16.23 tpy NOx The emissions increase for the project is 16.23 tons per year NOx. 16.23 tons per year is less than the PSD significant emission rate for NOx of 40 tons per year. The project, as documented in this analysis, will have not have emission increases greater than the PSD Significance Level for NOx, therefore PSD review is not required for this pollutant. However, to account for PSD regulations not considered when the IQS was originally permitted as a PCP Project, a Best Available Control Technology (BACT) Determination has been conducted for the unit and is included in Section 3.2.


EQUI 53 (Recovery Boiler) BLS and Steam throughput increases BASELINE ACTUAL EMISSIONS (BA) Under PSD rules for existing units (other than electric utility steam generating units), baseline actual emissions means the average rate, in tons per year, at which the emissions unit actually emitted the pollutant during any consecutive 24-month period selected by the owner or operator within the 10-year period immediately preceding either the date the owner or operator begins actual construction of the project, or the date a complete PSD permit application is received by the Permitting Authority. A different 24-month period may be used for each pollutant. However, the same 24-month period must be used for all emissions units for a single pollutant. The baseline period selected for this project is April 2014 to March 2016, which is the same period as was used in the previous PSD analysis (Air Permit No. 01700002-101). Process throughput and operating hours data for each unit affected by this project was taken from this time period. Baseline actual (BA) calculations were generally based on the emission factors used in the 2015 emission inventory, including continuous emission monitors (CEMS), or stack test data when available. As the emissions inventory did not include emissions data for total reduced sulfur, sulfuric acid, hydrogen sulfide, and greenhouse gases (CO2e), emissions were calculated separately based on site specific emission factors. Emissions of CO2e were also calculated separately based on EPA Tier 1 methodology. Sulfuric acid emissions from the lime kiln were calculated based on site specific emission factors in the previous PSD analysis, however the more recent 2017 stack test provided a more specific emission factor that was not previously available. This factor was used in the baseline as well as the future projected actual calculations. FUTURE PROJECTED ACTUAL EMISSIONS (FPA) This analysis is conducted using future projected actual emissions (FPA) compared to baseline actual emissions. Consistent with the baseline actual calculations, emission factors from the 2015 air emissions inventory were used. This means that for pollutants measured by continuous emission monitors (CEMS), or for which there is stack test data, the most recent available data is used. Future projected calculations are based on process throughput and operating hour assumptions as were outlined previously. Where process throughput assumptions were not estimated, an average overall pulp production rate increase was calculated and applied to BA data using the production increase percentage. There were some cases where the emission calculations for pollutants that used an emission factor in pounds per hour were multiplied by a process throughput ratio between FPA and BA to account for increased emissions. The process throughput ratios were used in calculations for the recovery boiler (EQUI 53), lime kiln (EQUI 52), and IQS units. The pulp process throughput ratios used were representative of each unit’s throughput, except for the IQS system (EQUI 49), which was based on the corresponding BLS production ratio. An amendment application was submitted to the MPCA on April 2, 2018 in order to change the NOx emission limit on the IQS. This limit change is not associated with this project, but was an unrelated facility change that occurred after the previous PSD analysis submitted for the project scope in 2016 (Air Permit No. 01700002-101). The new NOx emission limit of 12.00 lb NOx/hr is used to calculate FPA emissions. The lime kiln was recently modified to include low NOx burners (authorized in Air Permit No. 01700002-015, issued April 2015) with start-up occurring on May 13, 2016. Stack testing had not yet been performed on the modified unit at the time of the previous PSD analysis. The FPA calculations are now based on the most recent stack test completed in April 26, 2017 instead of an emission factor derived from the current permit limit of 38.9 lb NOx/hr, which was used in the previous PSD analysis submitted for the project scope in 2016


(Air Permit No. 01700002-101). The 2017 stack test provided factors for NOx, SOx, CO, VOC, and sulfuric acid. The calculation assumes 8,760 annual hours of operation. The recovery boiler steam flow limit of 853,000 pounds per hour as an 8-hour rolling average established as a Title 1 PSD condition is currently the bottleneck for the recovery system and pulping operations as previously described in Section 2.0. With the increase in pulp and BLS production capacity and recovery boiler BLS combustion capacity increase, steam production will surpass this limit. The steam flow limit was established based on previous stack test results. Sappi understands that they will need to retest to demonstrate compliance at the higher steaming rate of 925,000 pounds per hour. SUMMARY OF EMISSION CALCULATIONS The project must be evaluated for applicability of federal PSD modification requirements because the existing facility constitutes a “major stationary source” under 40 CFR 52.21b(1)(i)(a). If emissions attributable to the project are shown to exceed certain PSD de minimis thresholds, otherwise known as significant emission rates, the modification must be reviewed under PSD as a “major modification” to a major stationary source. The current federal PSD analysis guidance allows the major modification applicability test to be completed in one step to determine the significant net emissions increase analysis. EPA has clarified that for individual emission units that result in an emissions decrease, the emission change can be represented as a negative number in the summation for the project if a decrease in emissions occurred at that specific emission unit. However, Sappi has indicated that there are no creditable decreases to be obtained that are unrelated to this project, it is not necessary to complete netting emission calculations including creditable increases and/or decreases in this analysis. The results of the PSD analysis are compared to the significant emission rates in tons per year (tpy). Table 4 (above) summarizes the proposed project emissions increases.

3.2 BACT Analysis EQUI 49 (IQS) NOx limit increase NOX EMISSIONS FROM THE IQS (EQUI 49) (A BACT analysis was submitted as a part of this application to account for PSD regulations not considered when the IQS was originally permitted as a Pollution Control Project.) NCGs consist of gases generated during the pulping process and consist primarily of the High Volume Low Concentration (HVLC) system, Low Volume High Concentration (LVHC) and the Stripper Off-Gas (SOG) system. Emission units that comprise the NCG system are listed in Sappi’s current air permit under the group COMG2. The NCGs are vented to and controlled by the Incinerator-Quencher-Scrubber (IQS) system (EQUI 49). The incinerator (TREA 30) thermally oxidizes the VOC, HAP, TRS, and nitrogen compounds from the gas stream to produce carbon dioxide (CO2), sulfur dioxide (SO2), water vapor and NOx. The quencher cools the gas stream from the incinerator by spraying and evaporating a circulating scrubbing solution. The scrubber portion (TREA 31) of the IQS removes SO2 by contacting the flue gas with an alkaline spraying solution. Controlling HAPs and TRS compounds from the HVLC, LVHC and the SOG, Sappi operates the IQS system to comply with 40 CFR Part 63, Subpart S (National Emission Standard for Hazardous Air Pollutants from the Pulp and Paper Industry).


In general, NOx emissions from IQS are a combination of thermal NOx and fuel NOx. Thermal NOx is produced by a series of chemical reactions in which diatomic nitrogen and oxygen in the combustion air react to form NOx in a high temperature combustion zone. A large part of the NOx is generated from ammonia that is contained in some of the waste gas stream. Fuel NOx is generated when nitrogen available in the fuel (natural gas) is oxidized to NOx. The existing IQS is operated using staged combustion techniques, limiting the formation of thermal NOx which minimizes the generation of NOx. Due to variations in waste gas compositions, NOx emissions are usually more difficult to control in a thermal oxidizer than in a fired heater. APPLICABLE CONTROL TECHNOLOGIES FOR NOX EMISSIONS FROM THE IQS (EQUI 49) A search of the RBLC only identified one similar entry for a similar system. From 2001, it is older than the 10-year look back traditionally included in other BACT analyses. It was entry PA-0177 for the P.H. Glatfelter Company. In that case high volume, low concentration NCG were to be combusted in a recovery boiler. The BACT Limit was identified as 120 ppm @ 15% oxygen. The recovery boiler also was assigned a NOx limit of 574 tons per year. The entry also included a BACT Limit for SO2 but did not identify any control equipment for SO2. Because this is a recovery boiler also combusting black liquor solids, it is not possible to compare the Sappi IQS system proposed NOx limit to the P.H. Glatfelter Company limit. The California Air Resources Board BACT Clearinghouse was also consulted. There were no entries for chemical pulping sources. Because there were no comparable entries in the RBLC, traditional combustion NOx control technologies were reviewed. Technologies available to potentially control NOx emissions from the thermal incinerators include the following: 1. Selective Catalytic Reduction (SCR); 2. Selective Noncatalytic Reduction (SNCR); 3. Staged Combustion 4. Low NOx Burners (LNB); 5. Flue Gas Recirculation. These units were discussed in the BACT analysis section of the major permit amendment application. Both SNCR and SCR are not feasible control types for the IQS. Additionally, low-NOx burners and flue gas recirculation are not feasible control technologies. The only applicable control technology identified above is two-stage combustion. Sappi’s IQS is equipped with staged combustion. This is a top-ranked control technology, so no economic justification is required. EQUI 53 (Recovery Boiler) BLS and Steam throughput increases PM, PM10 AND PM2.5 EMISSIONS FROM THE RECOVERY BOILER (EQUI 53) To accommodate the pulp production increase, Sappi is proposing to increase the recovery boiler (EQUI 53) BLS firing limit from 904,200 tons/yr to 1,113,250 tons per year. This increase corresponds to the recovery boiler (EQUI 53) capacity of 6.10 MMlbs BLS/day. Currently, particulate emissions from the recovery boiler (EQUI 53) are controlled by an electrostatic precipitator (CE 007/TREA 20) and vented externally through a stack (SV 006/ STRU 042).


Particulate matter emissions from recovery boilers are a combination of filterable (fronthalf) and condensable (back-half) particulate. A small amount of supplemental natural gas and diesel fuel is combusted in the recovery boiler (EQUI 53) for specific operational situations such as start up or for supplemental steam; these fuels are already authorized in the current permit and will not change as a result of this project. APPLICABLE CONTROL TECHNOLOGIES FOR PM, PM10 AND PM2.5 EMISSIONS FROM RECOVERY BOILER (EQUI 53) A search of the RBLC for similar sized recovery boilers was conducted. A list of the results is located in Appendix B. Based on this search, technologies available to potentially control PM, PM10 and PM2.5 emissions from the recovery boilers include the following: 1. Fabric Filter; 2. Electrostatic Precipitator (ESP); and 3. Wet Scrubber. Please note that there were no entries in the RBLC for PM2.5. Therefore, entries for PM10 and PM were used for the analysis. Fabric Filter Fabric filters, or baghouses, consist of a structure containing tubular bags made of a woven or felted fabric in which particulate matter is removed by drawing the particulate laden gas through the bags with the bags capturing the particulate matter. The collected particulate is periodically removed by shaking the bag, sending a pulse of high velocity air in the opposite direction, or by other means. Most of the particulate matter is collected by a cake of solid material that forms on the bags by the already collected particulate matter. The technical feasibility of using fabric filters depends on exhaust gas temperatures and moisture content. Exhaust gas temperatures must be less than 500°F to avoid damaging the bag material. Additionally, moisture must be minimized to avoid condensation and possible blinding of the bags. Since wet particles in the exhaust stream can clog the bag pores and block gas movement, the high level of moisture and the temperature in the exhaust streams of Sappi’s recovery boiler (EQUI 53) makes this alternative unsuitable. Fabric filters are not identified in the RBLC as an acceptable control technology for PM/PM10/PM2.5 emissions from recovery boilers. Therefore, fabric filters are not considered to be technically feasible for control of PM/PM10/PM2.5 from the recovery boiler(EQUI 53). Electrostatic Precipitator (ESP) ESPs clean particulate matter from exhaust streams in three steps: 1. Passing the suspended particles through a direct current corona to electrically charge them; 2. Collecting the charged particles on a grounded plate; and 3. Removing the particles from the plates by mechanical means or water flushing. ESPs can be further classified as dry ESPs and wet ESPs. Dry ESPs are typically used for applications where the exhaust stream has very little moisture content. Wet ESPs are typically used to collect particulate matter from streams that have relatively high moisture contents. While dry ESPs are primarily effective at collecting filterable PM, wet ESPs have shown effectiveness at collecting condensable PM via the mechanism of condensation on to liquid covered plates. Sappi currently utilizes an ESP (CE 007/TREA 20) to control emissions from the recovery boiler (EQUI 53). With the 2016 project Sappi indicated that there could be changes to the ESP. In October 2018, field 3/4 was


split into two fields (field 3 and field 4) and two new controllers were installed for these fields. In April 2019, Field 5/6 was split into field 5 and field 6. In addition to splitting field 5/6, two more controllers were installed and two new transformer/rectifiers were added for fields 5 and 6. ESPs are considered the base case, so they are not evaluated further in this analysis. Wet Scrubber Wet scrubbers remove particulate matter from exhaust gases by capturing the particles in liquid droplets and subsequently separating the droplets from the exhaust gas stream. Wet scrubbers are effective at removing both condensable and filterable particulates. Condensable PM is removed due to the reduction in the temperature of the exhaust stream thereby condensing the condensable PM. Wet scrubbers can be grouped into the following major categories: 1. Venturi scrubbers; 2. Mechanically aided scrubbers; 3. Pump aided scrubbers; 4. Wetted filter-type scrubbers; and 5. Tray or sieve-type scrubbers. The difference between these scrubber types is the manner in which the liquid is introduced into the gas stream, the methods by which the particles are captured by the liquid droplets, and the fashion in which the liquid droplets are removed. The main advantages of a wet scrubber include its ease of maintenance and its ability to remove both filterable and condensable PM. The main drawbacks of a wet scrubbing system include the operational and maintenance expenses resulting from the water supply requirements and liquid effluent disposal requirements. However, in pulp mill operations the spent scrubbing solution can be returned to the causticizing process. Wet scrubbing is considered to be technically feasible for application to recovery boilers for the control of PM/PM10/PM2.5 emissions. Equipment Description Proposed PM, PM10 and PM2.5

BACT Limitation

EQUI 53 Recovery Boiler Recovery Boiler 0.020 gr filterable PM /dscf @ 8% O2 0.025 gr PM10/dscf @ 8% O2 0.025 gr PM2.5/dscf @ 8% O2

See BACT analyses for more pollutants for EQUI 53 (Recovery Boiler) BLS and Steam throughput increases in TSD attachment 8.

3.3 Dispersion modeling

Requirements to perform refined modeling for SO2 were added to the permit.. The facility’s PTE for SO2 is over 5000 tons per year, due to the potential for uncontrolled SO2 emissions from the power boilers while combusting NCG as an alternative to the IQS. The facility’s reported actual emissions of SO2 were 152 tons in 2017, the most recent year that QA/QC’d emissions inventory data is available. Modeling requirements were updated for all other pollutants, placing CO and PM in Tier 1, PM10 and PM2.5 in Tier 2, and placing NO2 in Tier 4, the most stringent modeling tier.

EQUI 49 (IQS) NOx limit increase AIR DISPERSION MODELING As required by permit condition 5.1.4, “Changes that affect any modeled parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD (Equivalent or


Better Dispersion) Modeling Submittal requirement.” Sappi has completed EBD Modeling and submitted a Modeling Protocol to MPCA demonstrating compliance with the SIL for NOx at 12.0 lb/hr. Modeled Emission Rates Emission rates were established for the 1-hour and annual averaging periods for the project. EPA has indicated that modeling for the significant impact levels (SILs) must be calculated for the significant net emissions increase, which is defined as the difference between future allowable emissions and current actual emissions. On a 1-hour basis, the future allowable emission limit is proposed at 12 lb/hr. Current emissions are limited to an emission rate of 9.1 lb/hr,. Therefore, the emission rate for the 1-hour modeling analysis will be based on 2.9 lb/hr (0.365 grams/second). On an annual basis, the modeled emission rate was on the future allowable emission limit of 52.56 tons per year (tpy) and the current baseline actual emissions of 36.33 tpy. The current actual emissions are based on the emissions calculated for the baseline actual time period of April 2014 – March 2016 developed for the NSR emission calculations completed for the project. The difference of 16.23 tpy (0.467 grams/second) was used in the annual modeling analysis.

NO2 SIL Analysis for permit #01700002-102

Averaging

Period

SIL

(µg/m3)

Total Modeled

Concentration

(µg/m3)

Percent of

Standard

(%)

1-hr 7.52 7.32 97.34

Annual 1 0.52 52.0

EQUI 53 (Recovery Boiler) BLS and Steam throughput increases An ambient air quality analysis has not been completed for this project because air dispersion modeling demonstrating compliance with National Ambient Air Quality Standards (NAAQS) and NAAQS increment analysis at the permitted emission rates has been previously completed, and these permitted emission limits will not increase as a result of the project

3.4 Monitoring In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. For CAM, the Permittee submitted a CAM proposal as required by 40 CFR § 64.3. It can be found in Attachment 3 to this TSD. Further discussion of decisions about CAM can be found in Table 7. In evaluating the monitoring included in the permit, the MPCA considered the following:

the likelihood of the facility violating the applicable requirements;

whether add-on controls are necessary to meet the emission limits;

the variability of emissions over time;

the type of monitoring, process, maintenance, or control equipment data already available for the emission unit;

the technical and economic feasibility of possible periodic monitoring methods; and

the kind of monitoring found on similar units elsewhere. Table 5 summarizes the monitoring requirements.


Table 8. Monitoring

Subject Item* Requirement (basis)

What is the monitoring? Why is this monitoring adequate?

COMG 1

Fuel Usage




COMG 2 HAPs - Total = 11.1 pounds per ton of ODP (oven-dried pulp) [40 CFR 63.446(c)(3), Minn. R. 7011.7700]

Conductivity is continually monitored, Methanol concentration is sampled periodically

No additional beyond monitoring prescribed in the federal standard (40 CFR Section 63.453).

All gases must be combusted in the

Incinerator/Quencher/Scrubber (IQS, EQUI 49), or in backup units which in this case are Power

Boilers 7 & 9 (EQUI 2 and EQUI 4).

The Permittee shall reduce HAPs - Total >= 92 percent by weight.

[40 CFR 63.446(e), Minn. R. 7011.7700]

Conductivity is continually monitored, Methanol concentration is sampled periodically

No additional beyond monitoring prescribed in the federal standard (40 CFR Section 63.453).

All gases must be combusted in the

Incinerator/Quencher/Scrubber (IQS, EQUI 49), or in backup units which in this case are Power

Boilers 7 & 9 (EQUI 2 and EQUI 4).

EQUI 2

PM < 10 micron




Carbon Monoxide




Sulfur Dioxide




EQUI 4

Nitrogen Dioxide




Opacity




Sulfur Dioxide




PM < 2.5 micron




Sulfur Dioxide




Carbon Monoxide




Sulfur - Total Reduced including H2S




PM < 2.5 micron




Volatile Organic Compounds




Process Throughput




Particulate Matter




Sulfur Content of Fuel




Volatile Organic Compounds




Opacity




The Permittee shall limit Sulfur Content of Fuel




Opacity


Insignificant activity General applicable emission limit Discussion

Indirect heating equipment with a capacity less than 420,000 Btu/hour, etc.

PM < 0.60 or 0.40, depending on year constructed

Opacity < 20% with exceptions

(Minn. R. 7011.0515)

Sappi has 2 portable air compressors and fewer than 10 pumps which fire gasoline. Capacity of each is less than 420,000 Btu/hour, and the total combined capacity is less than 1.4 MMBtu/hour Btu/hour.

For these units, based on the fuels used and EPA published emissions factors, it is highly unlikely that they could violate the applicable requirements.

Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons

Minn. R. 7011.0715, 40 CFR pt. 60, subp. Kb Minn. R. 7011.0715, 40 CFR pt. 60, subp. Kb

Minn. R 7011.1505, subp. 2(B)/1505, subp. 3(B)

Sappi has 7 of these tanks. These tanks are subject to the recordkeeping requirements of Minn. R. 7011.0715, 40 CFR pt. 60, subp. Kb. These tanks do not need to be classied as emission units if they are only subject to the recordkeeping in the NSPS.

Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G)

PM, variable depending on airflow

Opacity < 20%

(Minn. R. 7011.0715)

Sappi has four laboratories at its facility: Pulp QC, Paper QC; Technical and Environmental Department QC and environmental analysis; and Research and Development. Materials processed in all four of these laboratories are not sold for profit. Sappi has process control labs within the mill operating departments.

These are very small, intermittent, bench-top operations that typically do not even have any emissions. It is highly unlikely that they could violate the applicable requirement.

Brazing, soldering or welding equipment


Opacity < 20%

(Minn. R. 7011.0715)

Brazing, soldering and welding are performed for maintenance, repair and fabrication. Sappi has a maximum of 75 welding units on-site including electric welders and oxy/acetylene torches.

For these units, based on EPA published emissions factors, it is highly unlikely that they could violate the applicable requirement. In addition, these units are typically operated and vented inside a building, so testing for PM or opacity is not feasible.

Individual units with potential emissions less than 2000 lb/year of certain pollutants


Opacity < 20% (with exceptions)

(Minn. R. 7011.0715)

Chlorine bleach plant cooling tower, Caustisizer Tank #5, Recausticizer Swing Tank, White liquor surge tank, Emergency Generator, Ozone Bleaching system, Decarbonators (2).

Individual units with potential or actual emissions meeting the criteria in Minn. R. 7007.1300, subp. 4(A)-(D)

PM, variable depending on airflow Opacity


the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. In this permit, federal requirements from NESHAPs and NSPS are included in two different formats. The requirements for 40 CFR pt. 63, subp. S, MM, ZZZZ, JJJJ and 40 CFR pt. 60, subp. BB, BBa, D, Db, and IIII are incorporated into the permit as individual permit requirements, which has historically been MPCA’s standard practice. However, the requirements for 40 CFR pt. 63, subp. DDDDD and the associated General Provisions in 40 CFR pt. 63, subp. A and 40 CFR pt. 60, subp. A are included in a different way. For these rules, limits and submittal/actions are included individually in the permit like the other standards. For the remaining portions of the rule, a requirement in Section 5 of the permit lists the citations of all of the applicable parts of the standard along with a reference to the permit appendix where the full text of the standard is included. 40 CFR pt. 63, subp. DDDDD, 40 CFR pt. 63, subp. A , and 40 CFR pt. 60, subp. A are included in Appendices G, F, and H respectively.

3.7 Comments received Public Notice Period: [start date] – [end date] EPA Review Period: [start date] – [end date] MPCA has been in contact with the Fond du Lac tribe as prescribed in the May 2016 MPCA Guidance on Air Quality Permit Consultation with Minnesota Tribal Nations, prior to public notice, and they were provided with an advance copy of the draft permit. Tribal representatives and Sappi are not aware of additional community groups that may be interested in the permit. The public notice was published in a newspaper of local circulation as a means of additional outreach.

4. Permit fee assessment This permit action is the reissuance of an individual Part 70; therefore, no application fees apply under Minn. R. 7002.0016, subp. 1 to the changes that are covered by the reissuance application. However, the permit action rolls in several additional permit applications to which fees do apply. Attachment 5 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee as required by Minn. R. 7002.0019.

5. Conclusion Based on the information provided by Sappi Cloquet LLC the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 01700002-102 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Brady Krueger (permit engineer) Amrill Okonkwo (permit engineer)

Toni Volkmeier (peer reviewer) Michaela Leach (permit writing assistant) Laurie O'Brien (administrative support)

TEMPO360 Activities: Administrative Amendment (IND20170001), Administrative Amendment (IND20180006), Major Amendment (IND20180001), Part 70 Reissuance (IND20160002), Major Amendment (IND20190002), Administrative Amendment (IND20190001), Permit Reopening (IND201800003)


Attachments: 1. PTE summary and emissions increase calculation spreadsheets 2. Subject item inventory and facility requirements 3. CAM Plan 4. EQUI 42 (EU 88 Ozone bleaching system) performance test results 5. Points Calculator 6. NOx SIL modeling results for Major Amendment (IND20180001) 7. Natural gas combustion and ESP operation 8. BACT analyses for major amendments

Attachment 1 – [PTE Summary and Emissions Increase Calculation Spreadsheets]

Attachment 1 – PTE summary and emissions increase calculation spreadsheets

Facility Name: Sappi Cloquet LLCFacility ID: 01700002Agency Interest No.: 2309Emissions Summary

Description: EQUI 2 Power Boiler #7 Description: EQUI 4 Power Boiler #9 Description: Recovery Boiler (#10) Description: Bleach Plant Description: Methanol Tank Description:Delta ID No.: EU 002 Delta ID No.: EU 004 Delta ID No.: EU005 Delta ID No.: EU011 Delta ID No.: Delta ID EU017) Delta ID No.:Tempo ID No.: EQUI 2 Tempo ID No.: EQUI 4 Tempo ID No.: EQUI 53 Tempo ID No.: EQUI 7 Tempo ID No.: EQUI 261 Tempo ID No.:

PollutantCAS #

(if applicable)Emission rate

(lb/hr)Uncontrolled

tpyLimited

tpyEmission rate

(lb/hr)Uncontrolled

tpyLimited

tpyEmission rate

(lb/hr)Uncontrolled

tpyLimited

tpyEmission rate

(lb/hr)Uncontrolled

tpyLimited

tpyEmission rate

(lb/hr)Uncontrolled

tpyLimited

tpyEmission rate

(lb/hr)PM - 15.0 6570 65.7 21.5 9,417 94.2 40 17,520 175 - - - - - - 12.5

PM10 - 21.0 9198 91.98 30.1 13,184 132 40.0 17,520 175 - - - - - - 12.5PM2.5 - 10.5 919.8 45.99 13.5 1182.6 59.1 37.9 3,320 166 - - - - - - 11.46SO2 - 493 2160 2160 707 3096 3096 73.0 320 320 - - - - - - 6.25NOx - 90.0 394.2 394.2 151 662 662 226.5 992 992 - - - - - - -CO - 2,200 9,636 9,636 3,400 14,892 14,892 359 1,573 1,573 67.57 295.95 295.95 - - - -

VOC - 5.10 22.3 15.6 9.1 39.8 38.1 44.0 193 193 10.63 46.54 46.54 - - - 12.91Pb 7439-92-1 0.0144 0.0631 0.0433 0.0206 0.0904 0.0870 0.004 0.017 0.017 - - - - - - 1.04E-03

Fluorides - 0.0799 0.350 0.0233 0.115 0.502 0.0352 - 16 - - - - - - - -H2SO4 7664-93-9 0.130 0.569 0.569 0.190 0.832 0.832 3.60 15.77 15.77 - - - - - - -

TRS - 0.935 4.10 4.10 0.583 2.55 2.55 4.80 21.02 21.02 - - - - - - 2.14H2S 7783-06-4 - - - - - - 2.98 13.04 13.04 0.650 2.90 2.90 - - - 1.63CO2 - 63273 277136 240231 90691 397228 395974 273602 1198337 1198377 - - - - - - -CH4 - 21.16 92.70 63.9 30.3 132.87 127.22 7.13 31.25 31.25 - - - - - - -N2O - 3.90 17.08 12.25 5.59 24.5 23.3 5.71 25.00 25.00 - - - - - - -CO2e - 64964 284544 245478 93116 407846 406111 275481 1206609 1206609 - - - - - - -

Total HAPs - 1.13 4.96 4.94 1.66 7.27 7.27 40.78 178.63 178.63 1.52 6.63 6.63 6.39E-02 2.80E-01 2.80E-01 3.42Acetaldehyde 75-07-0 0.0330 0.145 0.145 0.0473 0.207 0.207 0.0635 0.278 0.278 0.280 1.20E+00 1.20E+00 - - - 6.99E-02

Acetophenone 98-86-2 0.000270 0.00118 0.00118 0.000387 0.00170 0.00170 - - - - - - - - - -Acrolein 107-02-8 0.00360 0.0158 0.0158 0.00516 0.0226 0.0226 - - - 0.0134 0.0584 0.0584 - - - 8.39E-04Benzene 71-43-2 0.0186 0.0815 0.0815 0.0267 0.117 0.117 0.0801 0.351 0.351 0.00882 0.0382 0.0382 - - - 7.12E-05Chlorine 7782-50-5 0.237 1.04 1.04 0.377 1.65 1.65 - - - 0.116 0.530 0.530 - - - -

Chloroform 67-66-3 0.000219 0.000959 0.000959 0.000314 0.00137 0.00137 0.00496 0.0217 0.0217 1.10E+00 4.80E+00 4.80E+00 - - - 2.92E-041,3-Butadiene 106-99-0 - - - - - - - - - - - - - - - -

Carbon Disulfide 75-15-0 - - - - - - - - - - - - - - - 1.05E-03Carbon Tetrachloride 58-23-5 - - - - - - - - - - - - - - - -

Chlorobenzene 108-90-7 - - - - - - - - - - - - - - - 2.41E-02Chloromethane 74-87-3 - - - - - - - - - - - - - - - 1.40E-02

Cumene 98-82-8 - - - - - - - - - - - - - - - 8.51E-04Dibutylphthalate 84742 0.00990 0.0434 0.0434 0.0142 0.0622 0.0622 - - - - - - - - - -Dichlorobenzene 25321-22-6 - - - - - - - - - - - - - - - -

1,2-Dichloroethylene 540-59-0 - - - - - - - - - - - - - - - -1,3-Dichloropropene 542756 - - - - - - - - - - - - - - - -

Ethylbenzene 100-41-4 0.000231 0.00101 0.00101 0.000331 0.00145 0.00145 - - - - - - - - - 6.61E-04Ethylene dibromide 106-93-4 - - - - - - - - - - - - - - - -

Formaldehyde 50-00-0 0.102 0.447 0.447 0.146 0.640 0.640 0.991 4.34E+00 4.34E+00 - - - - - - 6.61E-01Hexane 110-54-3 0.165 0.723 0.723 0.237 1.04 1.04 0.0483 0.212 0.212 - - - - - - 1.91E-03

Hydrogen Chloride 7647-01-0 - - - - - - 3.18E+01 1.39E+02 1.39E+02 - - - - - - -Methanol 67561 0.420 1.84 1.84 0.602 2.64 2.64 6.35E+00 2.78E+01 2.78E+01 - - - 6.39E-02 2.80E-01 2.80E-01 1.27E+00

Methylene Chloride 74-87-3 - - - - - - 0.979 4.29E+00 4.29E+00 - - - - - - 3.27E-01Methyl Isobutyl Ketone (MIBK) 108101 0.0630 0.276 0.276 0.0903 0.396 0.396 0.00394 0.0173 0.0173 - - - - - - 4.89E-01

Naphthalene 91-20-3 0.0360 0.158 0.158 0.0516 0.226 0.226 6.86E-02 3.01E-01 3.01E-01 - - - - - - 6.35E-02POM - 0.00136 0.00596 0.00596 0.00195 0.00854 0.00854 0.00903 0.0395 0.0395 - - - - - - 1.16E-02

Phenol 106-51-3 0.000630 0.00276 0.00276 0.000903 0.00396 0.00396 - - - - - - - - - -Styrene 100-42-5 - - - - - - 0.0712 0.312 0.312 - - - - - - 1.59E-02

1,1,2,2-Tetrachloroethane 79345 - - - - - - - - - - - - - - - -Tetrachloroethylene 127-18-4 - - - - - - 0.0724 0.317 0.317 - - - - - - 1.78E-02

TCDD EQ - 1.95E-08 8.54E-08 8.54E-08 2.30E-08 1.00E-07 1.00E-07 2.70E-07 1.18E-06 1.18E-06 - - - - - - -Toluene 108-88-3 0.00300 0.0131 0.0131 0.00430 0.0188 0.0188 0.0369 0.161 0.161 - - - - - - 4.07E-02

1,2,4-Trichlorobenzene 120821 - - - - - - 0.140 0.612 0.612 - - - - - - 1.53E-021,1,1-Trichloroethane 71-55-6 0.000360 0.00158 0.00158 0.000516 0.00226 0.00226 - - - - - - - - - 2.29E-031,1,2-Trichloroethane 79005 - - - - - - - - - - - - - - - 6.99E-02

Trichloroethylene 79016 0.000840 0.00368 0.00368 0.00120 0.00527 0.00527 - - - - - - - - - 1.19E-01Vinyl Chloride 75-01-4 - - - - - - - - - - - - - - - -

Xylenes (o,m,p) - 0.000750 0.00329 0.00329 0.00108 0.00471 0.00471 0.0648 2.84E-01 2.84E-01 - - - - - - 1.05E-01Antimony 7440-36-0 0.000652 0.00286 0.00286 0.000652 0.00854 0.00854 0.00356 0.0156 0.0156 - - - - - - 1.11E-03

Arsenic 7440-38-2 0.0000630 0.000276 0.000276 0.0000903 0.000396 0.000396 0.000610 0.00267 0.00267 - - - - - - 3.81E-04Beryllium 7440-41-7 - - - - - - 5.34E-05 0.000234 0.000234 - - - - - - 1.22E-04Cadmium 7440-43-9 0.0000840 0.000368 0.000368 0.000120 0.000527 0.000527 0.001068 0.00468 0.00468 - - - - - - 3.81E-04

Chromium 7440-47-3 0.000330 0.00145 0.00145 4.73E-04 0.00207 0.00207 0.000686 0.00301 0.00301 - - - - - - 4.32E-04Cobalt 7440-48-4 - - - - - - - - - - - - - - - -

Manganese 7439-96-5 0.0183 0.0802 0.0802 0.0262 0.115 0.115 0.00648 0.0284 0.0284 - - - - - - 4.83E-03Mercury 7439-97-6 0.000924 0.00400 0.00400 0.000845 0.00370 0.00370 0.00270 0.0120 0.0120 - - - - - - 2.29E-05

Nickel 7440-02-0 0.00102 0.00447 0.00447 0.00146 0.00640 0.00640 0.00521 0.0228 0.0228 - - - - - - 7.63E-02Phosphorus 7723140 - - - - - - - - - - - - - - - 1.53E-02

Selenium 7782-49-2 0.0000848 0.000372 0.000372 8.48E-05 0.000372 0.000372 0.000153 0.000668 0.000668 - - - - - - 3.81E-04Highest Facility Single HAP: -

Hydrogen Chloride 7647-01-0

Highest Single HAP Emissions- 0.0000 0.000 0.000 0.0000 0.000 0.000 3.18E+01 1.39E+02 1.39E+02 - - - - - - -


PollutantCAS #

(if applicable)

PM -PM10 -PM2.5 -SO2 -NOx -CO -

VOC -Pb 7439-92-1

Fluorides -H2SO4 7664-93-9

TRS -H2S 7783-06-4CO2 -CH4 -N2O -CO2e -

Total HAPs -Acetaldehyde 75-07-0

Acetophenone 98-86-2Acrolein 107-02-8Benzene 71-43-2Chlorine 7782-50-5

Chloroform 67-66-31,3-Butadiene 106-99-0

Carbon Disulfide 75-15-0Carbon Tetrachloride 58-23-5

Chlorobenzene 108-90-7Chloromethane 74-87-3

Cumene 98-82-8Dibutylphthalate 84742Dichlorobenzene 25321-22-6

1,2-Dichloroethylene 540-59-0 1,3-Dichloropropene 542756

Ethylbenzene 100-41-4Ethylene dibromide 106-93-4

Formaldehyde 50-00-0Hexane 110-54-3

Hydrogen Chloride 7647-01-0Methanol 67561

Methylene Chloride 74-87-3Methyl Isobutyl Ketone (MIBK) 108101

Naphthalene 91-20-3POM -

Phenol 106-51-3Styrene 100-42-5

1,1,2,2-Tetrachloroethane 79345Tetrachloroethylene 127-18-4

TCDD EQ -Toluene 108-88-3

1,2,4-Trichlorobenzene 1208211,1,1-Trichloroethane 71-55-61,1,2-Trichloroethane 79005

Trichloroethylene 79016Vinyl Chloride 75-01-4

Xylenes (o,m,p) -Antimony 7440-36-0

Arsenic 7440-38-2Beryllium 7440-41-7Cadmium 7440-43-9

Chromium 7440-47-3Cobalt 7440-48-4

Manganese 7439-96-5Mercury 7439-97-6

Nickel 7440-02-0Phosphorus 7723140

Selenium 7782-49-2Highest Facility Single HAP: -


Highest Single HAP Emissions-

Smelt Dissolving Tank Description: Lime Kiln Description: EU 037 Power Boiler #8EU031 Delta ID No.: EU033 Delta ID No.: EU 037

EQUI 51 Tempo ID No.: EQUI 52 Tempo ID No.: EQUI 18

Uncontrolled tpy

Limited tpy

Emission rate (lb/hr)

Uncontrolled tpy

Limited tpy


Uncontrolled tpy

Limited tpy

18,250.0 54.8 13.6 5,944 59.4 29.8 131 131

2,138.67 54.8 13.6 5,943.66 59.44 26.1 114.32 114.32

1,568.59 50.2 12.8 1,118.21 55.91 4.13 18.09 18.09

27.38 27.4 8.40 36.79 36.79 21.3 93.29 93.29

- - 39.02 170.89 170.89 55.95 245.06 245.06

- - 12.9 56.5 56.5 29.84 130.7 126.51

56.54 9.4 20.83 91.25 91.25 1.95 8.56 8.20

4.56E-03 4.6E-03 1.28E-02 1.08E-01 5.39E-02 0.000178 0.000778 0.000734

- - - - - 0.00991 4.34E-02 0.00252

- - 5.30E-01 2.32 2.32 - - -

0.00 9.35 1.70 7.45 7.45 - - -

7.13 7.13 0.250 1.05 1.05 - - -

- - 16631 69849 69849 60818 266385 195631

- - 0.810 3.40 3.40 2.47 10.81 5.09

- - 0.298 1.25 1.25 0.78 3.42 3.40

- - 16740 70306 70306 61087 267559 196772

15.00 15.00 1.34 5.67 5.61 1.02 4.47 4.47

3.06E-01 3.06E-01 1.82E-01 7.66E-01 7.66E-01 - - -

- - - - - - - -

3.67E-03 3.67E-03 - - - - - -

3.12E-04 3.12E-04 1.46E-01 6.13E-01 6.13E-01 0.000746 0.00327 0.00327

- - - - - - - -

1.28E-03 1.28E-03 - - - - - -

- - - - - - - -

4.62E-03 4.62E-03 - - - - - -

- - - - - - - -

1.06E-01 1.06E-01 - - - - - -

6.12E-02 6.12E-02 - - - - - -

3.73E-03 3.73E-03 - - - - - -

- - - - - - - -

- - - - - 0.000426 0.00187 0.00187

- - - - - - - -

- - - - - - - -

2.89E-03 2.89E-03 - - - 0.000169 0.000742 0.000742

- - - - - - - -

2.89E+00 2.89E+00 1.29E-01 5.43E-01 5.43E-01 8.79E-02 0.385 0.385

8.35E-03 8.35E-03 1.56E-01 6.56E-01 6.56E-01 0.639 2.80E+00 2.80E+00

- - - - - - - -

5.57E+00 5.57E+00 1.52E-01 6.39E-01 6.39E-01 - - -

1.43E+00 1.43E+00 - - - - - -

2.14E+00 2.14E+00 1.15E-01 4.81E-01 4.81E-01 - - -

2.78E-01 2.78E-01 - 0.00301 1.32E-02 1.32E-02

5.08E-02 5.08E-02 1.90E-03 7.98E-03 7.98E-03 0.000162 0.000712 0.000712

- - - - - - - -

6.96E-02 6.96E-02 6.51E-03 2.73E-02 2.73E-02 - - -

- - - - - - - -

7.79E-02 7.79E-02 - - - - - -

- - - - - - - -

1.78E-01 1.78E-01 1.52E-01 6.39E-01 6.39E-01 1.65E-02 7.24E-02 7.24E-02

6.68E-02 6.68E-02 - - - - - -

1.00E-02 1.00E-02 - - - - - -

3.06E-01 3.06E-01 - - - - - -

5.23E-01 5.23E-01 - - - - - -

- - - - - - - -

4.62E-01 4.62E-01 2.60E-01 1.09E+00 1.09E+00 0.000290 0.00127 0.00127

4.84E-03 4.84E-03 6.88E-05 3.01E-04 3.01E-04 1.40E-02 6.13E-02 6.13E-02

1.67E-03 1.67E-03 - - - 0.00352 1.54E-02 1.54E-02

5.34E-04 5.34E-04 - - - 7.41E-05 0.000324 0.000324

1.67E-03 1.67E-03 6.04E-03 2.65E-02 2.65E-02 0.00106 0.00464 0.00464

1.89E-03 1.89E-03 2.47E-03 1.04E-02 1.04E-02 0.00225 0.00986 0.00986

- - 1.02E-03 4.47E-03 4.47E-03 1.60E-02 7.03E-02 7.03E-02

2.12E-02 2.12E-02 - - - 0.00799 3.50E-02 3.50E-02

1.00E-04 1.00E-04 2.50E-04 1.10E-03 1.10E-03 0.000301 0.00132 0.00132

3.34E-01 3.34E-01 1.20E-02 5.25E-02 5.25E-02 0.225 0.986 0.986

6.68E-02 6.68E-02 - - - - - -

1.67E-03 1.67E-03 - - - 0.00182 0.00797 0.00797

- - - - - - - -


PollutantCAS #

(if applicable)

PM -PM10 -PM2.5 -SO2 -NOx -CO -

VOC -Pb 7439-92-1

Fluorides -H2SO4 7664-93-9

TRS -H2S 7783-06-4CO2 -CH4 -N2O -CO2e -

Total HAPs -Acetaldehyde 75-07-0

Acetophenone 98-86-2Acrolein 107-02-8Benzene 71-43-2Chlorine 7782-50-5

Chloroform 67-66-31,3-Butadiene 106-99-0

Carbon Disulfide 75-15-0Carbon Tetrachloride 58-23-5

Chlorobenzene 108-90-7Chloromethane 74-87-3

Cumene 98-82-8Dibutylphthalate 84742Dichlorobenzene 25321-22-6

1,2-Dichloroethylene 540-59-0 1,3-Dichloropropene 542756

Ethylbenzene 100-41-4Ethylene dibromide 106-93-4

Formaldehyde 50-00-0Hexane 110-54-3

Hydrogen Chloride 7647-01-0Methanol 67561

Methylene Chloride 74-87-3Methyl Isobutyl Ketone (MIBK) 108101

Naphthalene 91-20-3POM -

Phenol 106-51-3Styrene 100-42-5

1,1,2,2-Tetrachloroethane 79345Tetrachloroethylene 127-18-4

TCDD EQ -Toluene 108-88-3

1,2,4-Trichlorobenzene 1208211,1,1-Trichloroethane 71-55-61,1,2-Trichloroethane 79005

Trichloroethylene 79016Vinyl Chloride 75-01-4

Xylenes (o,m,p) -Antimony 7440-36-0

Arsenic 7440-38-2Beryllium 7440-41-7Cadmium 7440-43-9

Chromium 7440-47-3Cobalt 7440-48-4

Manganese 7439-96-5Mercury 7439-97-6

Nickel 7440-02-0Phosphorus 7723140

Selenium 7782-49-2Highest Facility Single HAP: -


Highest Single HAP Emissions-

Description: EU 049 #4 Paper Machine Description: EU 050 #12 Paper Machine Description: Market Pulp Machine Description: Chlorine Dioxide Plant Description: EU 051 #13 Coater Description: IQSDelta ID No.: EU 049 Delta ID No.: EU 050 Delta ID No.: EU080 Delta ID No.: EU 009 Delta ID No.: EU 051 Delta ID No.: EU081Tempo ID No.: EQUI 298 Tempo ID No.: EQUI 299 Tempo ID No.: EQUI 50 Tempo ID No.: EQUI 301 Tempo ID No.: EQUI 304 Tempo ID No.: EQUI 49


Uncontrolled tpy

Limited tpy


Uncontrolled tpy

Limited tpy


Unco

technical support document for draft air emission permit no. … · 2019. 6. 21. · technical...

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