MAJOR SOURCE OPERATING PERMIT

Transcription

1 MAJOR SOURCE OPERATING PERMIT Permitee: Facility Name: Facility No.: Location: INTERNATIONAL PAPER CO. INTERNATIONAL PAPER RIVERDALE MILL SELMA, ALABAMA In accordance with and subject to the provisions of the Alabama Air Pollution Control Act of 1971, as amended, Code of Alabama 1975, to (the "AAPCA") and the Alabama Environmental Management Act, as amended, Code of Alabama 1975, 22-22A-1 to 22-22A-15, and rules and regulations adopted thereunder, and subject further to the conditions set forth in this permit, the Permittee is hereby authorized to construct, install and use the equipment, device or other article described below. Pursuant to the Clean Air Act of 1990, all conditions of this permit are federally enforceable by EPA, the Alabama Department of Environmental Management, and citizens in general. Those provisions which are not required under the Clean Air Act of 1990 are considered to be state permit provisions and are not federally enforceable by EPA and citizens in general. Those provisions are contained in separate sections of this permit. Issuance Date: Draft Effective Date: January 1, 2018 Most Recent Modification: Expiration Date: December 31, 2022 Alabama Department of Environmental Management

2 TABLE OF CONTENTS GENERAL PERMIT PROVISOS SUMMARY PAGE FOR NO. 1 POWER BOILER NO. 1 POWER BOILER FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 1-2 SUMMARY PAGE FOR NO. 1 BARK BOILER NO. 1 BARK BOILER FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 2-3 SUMMARY PAGE FOR NO. 2 BARK BOILER NO. 2 BARK BOILER FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 3-3 SUMMARY PAGE FOR GAS TURBINE AND DUCT BURNER GAS TURBINE AND DUCT BURNER FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 4-4 SUMMARY PAGE FOR NO. 1 RECOVERY FURNACE NO. 1 RECOVERY FURNACE FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 5-3 SUMMARY PAGE FOR NO. 1 SMELT DISSOLVING TANK NO. 1 SMELT DISSOLVING TANK FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures

3 4. Emission Monitoring Recordkeeping and Reporting Requirements 6-3 NO. 1 SMELT DISSOLVING TANK STATE ONLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 6-4 SUMMARY PAGE FOR NO. 2 RECOVERY FURNACE NO. 2 RECOVERY FURNACE FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 7-3 SUMMARY PAGE FOR NO. 2 SMELT DISSOLVING TANK NO. 2 SMELT DISSOLVING TANK FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 8-3 SUMMARY PAGE FOR NO. 1 MULTIPLE EFFECT EVAPORATORS NO. 1 MULTIPLE EFFECT EVAPORATORS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 9-2 SUMMARY PAGE FOR NO. 2 MULTIPLE EFFECT EVAPORATORS NO. 2 MULTIPLE EFFECT EVAPORATORS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 10-2 SUMMARY PAGE FOR NO. 3 LIME KILN NO. 3 LIME KILN FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 11-3 SUMMARY PAGE FOR NOS. 1-4 DIGESTER SYSTEMS

4 NOS. 1-4 DIGESTER SYSTEMS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 12-2 NOS. 1-4 DIGESTER SYSTEMS STATE ONLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 12-3 SUMMARY PAGE FOR NOS DIGESTER SYSTEMS NOS DIGESTER SYSTEMS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 13-2 SUMMARY PAGE FOR NO. 1 BROWNSTOCK WASHER SYSTEM (INCLUDING 4 TH STAGE) NO. 1 BROWNSTOCK WASHER SYSTEM (INCLUDING 4 TH STAGE) FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 14-2 SUMMARY PAGE FOR NO. 2 BROWNSTOCK WASHER SYSTEM NO. 2 BROWNSTOCK WASHER SYSTEM FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 15-2 SUMMARY PAGE FOR PULPING SYSTEM PROCESSES PULPING SYSTEM PROCESSES FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 16-3 SUMMARY PAGE FOR PROCESS CONDENSATES PROCESS CONDENSATES FEDERALLY ENFORCEABLE PROVISOS Applicability

5 2. Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 17-5 SUMMARY PAGE FOR ENCLOSURES AND CLOSED-VENT SYSTEMS ENCLOSURES AND CLOSED-VENT SYSTEMS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 18-4 SUMMARY PAGE FOR NO. 1 BLEACHING SYSTEM NO. 1 BLEACHING SYSTEM FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 19-2 NO. 1 BLEACHING SYSTEM STATE ONLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 19-3 SUMMARY PAGE FOR NO. 2 BLEACHING SYSTEM NO. 2 BLEACHING SYSTEM FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 20-2 NO. 2 BLEACHING SYSTEM STATE ONLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 20-4 SUMMARY PAGE FOR DEINK PLANT DEINK PLANT FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 21-2 SUMMARY PAGE FOR NO. 2 PULP DRYER DRY END REPULPER

6 NO. 2 PULP DRYER DRY END REPULPER FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 22-2 SUMMARY PAGE FOR RICE MACT UNITS RICE MACT UNITS FEDERALLY ENFORCEABLE PROVISOS Applicability Emission Standards Compliance and Performance Test Methods and Procedures Emission Monitoring Recordkeeping and Reporting Requirements 23-4 SOURCES SUBJECT ONLY TO THE GENERAL PROVISOS

7 General Permit Provisos Federally Enforceable Provisos 1. Transfer This permit is not transferable, whether by operation of law or otherwise, either from one location to another, from one piece of equipment to another, or from one person to another, except as provided in Rule (1)(a)5. 2. Renewals Rule (6) Rule (2) An application for permit renewal shall be submitted at least six (6) months, but not more than eighteen (18) months, before the date of expiration of this permit. The source for which this permit is issued shall lose its right to operate upon the expiration of this permit unless a timely and complete renewal application has been submitted within the time constraints listed in the previous paragraph. 3. Severability Clause The provisions of this permit are declared to be severable and if any section, paragraph, subparagraph, subdivision, clause, or phrase of this permit shall be adjudged to be invalid or unconstitutional by any court of competent jurisdiction, the judgment shall not affect, impair, or invalidate the remainder of this permit, but shall be confined in its operation to the section, paragraph, subparagraph, subdivision, clause, or phrase of this permit that shall be directly involved in the controversy in which such judgment shall have been rendered. Rule (e) 4. Compliance Rule (f) a. The permittee shall comply with all conditions of ADEM Admin. Code Noncompliance with this permit will constitute a violation of the Clean Air Act of 1990 and ADEM Admin. Code and may result in an enforcement action; including but not limited to, permit termination, revocation and reissuance, or modification; or denial of a permit renewal application by the permittee. b. The permittee shall not use as a defense in an enforcement action that maintaining compliance with conditions of this permit would have required halting or reducing the permitted activity. 5. Termination for Cause This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance will not stay any permit condition. 6. Property Rights The issuance of this permit does not convey any property rights of any sort, or any exclusive privilege. Rule (g) Rule (h) Rule (i) 0-12

8 General Permit Provisos Federally Enforceable Provisos 7. Submission of Information The permittee must submit to the Department, within 30 days or for such other reasonable time as the Department may set, any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon receiving a specific request, the permittee shall also furnish to the Department copies of records required to be kept by this permit. 8. Economic Incentives, Marketable Permits, and Emissions Trading No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are provided for in this permit. 9. Certification of Truth, Accuracy, and Completeness Any application form, report, test data, monitoring data, or compliance certification submitted pursuant to this permit shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. 10. Inspection and Entry Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized representatives of the Alabama Department of Environmental Management and EPA to conduct the following: Rule (j) Rule (k) Rule (a) Rule (b) a. Enter upon the permittee s premises where a source is located or emissions-related activity is conducted, or where records must be kept pursuant to the conditions of this permit; b. Review and/or copy, at reasonable times, any records that must be kept pursuant to the conditions of this permit; c. Inspect, at reasonable times, this facility s equipment (including monitoring equipment and air pollution control equipment), practices, or operations regulated or required pursuant to this permit; d. Sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with this permit or other applicable requirements. 11. Compliance Provisions Rule (c) a. The permittee shall continue to comply with the applicable requirements with which the company has certified that it is already in compliance. b. The permittee shall comply in a timely manner with applicable requirements that become effective during the term of this permit. 0-13

9 General Permit Provisos Federally Enforceable Provisos 12. Compliance Certification A compliance certification shall be submitted annually on February 28 th. Rule (e) a. The compliance certification shall include the following: 1. The identification of each term or condition of this permit that is the basis of the certification; 2. The compliance status; 3. The method(s) used for determining the compliance status of the source, currently and over the reporting period consistent with Rule (c) (Monitoring and Recordkeeping Requirements); 4. Whether compliance has been continuous or intermittent; 5. Such other facts as the Department may require to determine the compliance status of the source; b. The compliance certification shall be submitted to: Alabama Department of Environmental Management Air Division P.O. Box Montgomery, AL and to: Air and EPCRA Enforcement Branch EPA Region IV 61 Forsyth Street, SW Atlanta, GA Reopening for Cause Under any of the following circumstances, this permit will be reopened prior to the expiration of the permit: Rule (5) a. Additional applicable requirements under the Clean Air Act of 1990 become applicable to the permittee with a remaining permit term of three (3) or more years. Such a reopening shall be completed not later than eighteen (18) months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which this permit is due to expire. b. Additional requirements (including excess emissions requirements) become applicable to an affected source under the acid rain program. Upon approval by the Administrator, excess emissions offset plans shall be deemed to be incorporated into this permit. 0-14

10 General Permit Provisos Federally Enforceable Provisos c. The Department or EPA determines that this permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions of this permit. d. The Administrator or the Department determines that this permit must be revised or revoked to assure compliance with the applicable requirements. 14. Additional Rules and This permit is issued on the basis of Rules and existing on the date of issuance. In the event additional Rules and are adopted, it shall be the permit holder s responsibility to comply with such rules (d), Code of Alabama 1975, as amended 15. Equipment Maintenance or Breakdown Rule (1), (2) a. In the case of shutdown for more than one (1) hour of air pollution control equipment (which operates pursuant to any permit issued by the Director) for necessary scheduled maintenance, the intent to shut down such equipment shall be reported to the Director at least twenty-four (24) hours prior to the planned shutdown, unless such shutdown is accompanied by the shutdown of the source which such equipment is intended to control. Such prior notice shall include, but is not limited to the following: 1. Identification of the specific facility to be taken out of service as well as its location and permit number; 2. The expected length of time that the air pollution control equipment will be out of service; 3. The nature and quantity of emissions of air contaminants likely to occur during the shutdown period; 4. Measures such as the use of off-shift labor and equipment that will be taken to minimize the length of the shutdown period; 5. The reasons that it would be impossible or impractical to shut down the source operation during the maintenance period. b. In the event that there is a breakdown of equipment or upset of process for a period exceeding one (1) hour in such a manner as to cause, or is expected to cause, increased emissions of air contaminants which are above an applicable standard, the person responsible for such equipment shall notify the Director within 24 hours or the next working day and provide a statement giving all pertinent facts, including the estimated duration of the breakdown. The Director shall be notified when the breakdown has been corrected. 0-15

11 General Permit Provisos Federally Enforceable Provisos 16. Operation of Capture and Control Devices All air pollution control devices and capture systems for which this permit is issued shall be maintained and operated at all times in a manner so as to minimize the emissions of air contaminants. Procedures for ensuring that the above equipment is properly operated and maintained so as to minimize the emission of air contaminants shall be established. 17. Obnoxious Odors This permit is issued with the condition that, should obnoxious odors arising from the plant operations be verified by Air Division inspectors, measures to abate the odorous emissions shall be taken upon a determination by the Alabama Department of Environmental Management that these measures are technically and economically feasible. 18. Fugitive Dust Reasonable precautions to prevent fugitive dust shall be taken so that provisions of the Department's rules and regulations shall not be violated. 19. Additions and Revisions Any modifications to this source shall comply with the modification procedures in Rules or (d), Code of Alabama 1975, as amended Rule Rule Rule & Recordkeeping Requirements Rule (c)2 a. Records of required monitoring information of the source shall include the following: 1. The date, place, and time of all sampling or measurements; 2. The date analyses were performed; 3. The company or entity that performed the analyses; 4. The analytical techniques or methods used; 5. The results of all analyses; and 6. The operating conditions that existed at the time of sampling or measurement. b. Retention of records of all required monitoring data and support information of the source for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation and copies of all reports required by the permit. Off-site records may be maintained if they are retrievable within 4 hours. Either paper copy or electronic formats are acceptable. 0-16

12 General Permit Provisos Federally Enforceable Provisos 21. Reporting Requirements Rule (c)3 a. Reports to the Department of any required monitoring shall be semiannually on February 28 th and August 31 st. All instances of deviations from permit requirements must be clearly identified in said reports. All required reports must be certified by a responsible official consistent with Rule (9). b. Deviations from permit requirements shall be reported within 48 hours or 2 working days of such deviations, including those attributable to upset conditions as defined in the permit. The report will include the probable cause of said deviations, and any corrective actions or preventive measures that were taken. 22. Emission Testing Requirements Each point of emission which requires testing will be provided with sampling ports, ladders, platforms, and other safety equipment to facilitate testing performed in accordance with procedures established by Part 60 of Title 40 of the Code of Federal, as the same may be amended or revised. As allowed in MACT and other regulations, flexibility is provided to use alternative test methods, as approved by EPA, ADEM or permit condition. Rule (3) Rule (1) The Air Division must be notified in writing at least 10 days in advance of all emission tests to be conducted and submitted as proof of compliance with the Department s air pollution control rules and regulations. To avoid problems concerning testing methods and procedures, the following shall be included with the notification letter: 1. The date the test crew is expected to arrive, the date and time anticipated of the start of the first run, how many and which sources are to be tested, and the names of the persons and/or testing company that will conduct the tests. Rule A complete description of each sampling train to be used, including type of media used in determining gas stream components, type of probe lining, type of filter media, and probe cleaning method and solvent to be used (if test procedures require probe cleaning). 3. A description of the process(es) to be tested including the feed rate, any operating parameters used to control or influence the operations, and the rated capacity. 4. A sketch or sketches showing sampling point locations and their relative positions to the nearest upstream and downstream gas flow disturbances. A pretest meeting may be held at the request of the source owner or the Air Division. The necessity for such a meeting and the required attendees will be determined on a case-by-case basis. Rule

13 General Permit Provisos Federally Enforceable Provisos All test reports must be submitted to the Air Division within 30 days of the actual completion of the test unless an extension of time is specifically approved by the Air Division or an alternative time is specified by an applicable regulation. 23. Payment of Emission Fees Annual emission fees shall be remitted each year according to the fee schedule in ADEM Admin. Code R Other Reporting and Testing Requirements Submission of other reports regarding monitoring records, fuel analyses, operating rates, and equipment malfunctions may be required as authorized in the Department's air pollution control rules and regulations. The Department may require emission testing at any time. Rule Rule (1) 25. Title VI Requirements (Refrigerants) 40 CFR Part 82 Any facility having appliances or refrigeration equipment, including air conditioning equipment, which use Class I or Class II ozone-depleting substances as listed in 40 CFR Part 82, Subpart A, Appendices A and B, shall service, repair, and maintain such equipment according to the work practices, personnel certification requirements, and certified recycling and recovery equipment specified in 40 CFR Part 82, Subpart F. No person shall knowingly vent or otherwise release any Class I or Class II substance into the environment during the repair, servicing, maintenance, or disposal of any device except as provided in 40 CFR Part 82, Subpart F. The responsible official shall comply with all reporting and recordkeeping requirements of 40 CFR Reports shall be submitted to the US EPA and the Department as required. 26. Chemical Accidental Prevention Provisions If a chemical listed in Table 1 of 40 CFR Part is present in a process in quantities greater than the threshold quantity listed in Table 1, then: 40 CFR Part 68 a. The owner or operator shall comply with the provisions in 40 CFR Part 68. b. The owner or operator shall submit one of the following: 1. A compliance schedule for meeting the requirements of 40 CFR Part 68 by the date provided in 40 CFR 68.10(a) or, 2. A certification statement that the source is in compliance with all requirements of 40 CFR Part 68, including the registration and submission of the Risk Management Plan. 27. Display of Permit This permit shall be kept under file or on display at all times at the site where the facility for which the permit is issued is located and will be made Rule (1)(d) 0-18

14 General Permit Provisos Federally Enforceable Provisos readily available for inspection by any or all persons who may request to see it. 28. Circumvention No person shall cause or permit the installation or use of any device or any means which, without resulting in reduction in the total amount of air contaminant emitted, conceals or dilutes any emission of air contaminant which would otherwise violate the Division 3 rules and regulations. 29. Visible Emissions Unless otherwise specified in the Unit Specific provisos of this permit, any source of particulate emissions shall not discharge more than one 6-minute average opacity greater than 20% in any 60-minute period. At no time shall any source discharge a 6-minute average opacity of particulate emissions greater than 40%. Opacity will be determined by 40 CFR Part 60, Appendix A, Method 9, unless otherwise specified in the Unit Specific provisos of this permit. Rule Rule (1) 30. Fuel-Burning Equipment Rule Rule a. Unless otherwise specified in the Unit Specific provisos of this permit, no fuel-burning equipment may discharge particulate emissions in excess of the emissions specified in Part b. Unless otherwise specified in the Unit Specific provisos of this permit, no fuel-burning equipment may discharge sulfur dioxide emissions in excess of the emissions specified in Part Process Industries General Unless otherwise specified in the Unit Specific provisos of this permit, no process may discharge particulate emissions in excess of the emissions specified in Part Averaging Time for Emission Limits Unless otherwise specified in the permit, the averaging time for the emission limits listed in this permit shall be the nominal time required by the specific test method. 33. Permit Shield A permit shield exists under this operating permit in accordance with ADEM Administrative Code R in that compliance with the conditions of this permit shall be deemed compliance with any applicable requirements as of the date of permit issuance. The permit shield is based on the accuracy of the information supplied in the application for this permit. Under this shield, it has been determined that requirements listed as non-applicable in such section are not applicable to this source. Rule Rule Rule

15 No. 1 Power Boiler Informational Summary Description: No. 1 Power Boiler Emission Unit No: PB01 Installation Date: 1966 Reconstruction / Modification date: Operating Capacity: 300 MMBtu/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR 63 DDDDD Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z007 No. 1 Power Boiler Opacity < 20% with one 6-min period up to 40% in any one hour period Rule (1) Z007 No. 1 Power Boiler PM 0.12 lb/mmbtu Rule (1) Z007 No. 1 Power Boiler SO 2 < 0.5% sulfur content; < 3,834,864 gal fuel oil/12 month period Permitted Fuels Fuel Max % Sulfur Max % Ash Natural Gas No. 2 4 Fuel Oil

16 Federally Enforceable Provisos No. 1 Power Boiler Provisos Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R Rule , "Major Source Operating Permits". 2. This source is subject to the requirements of ADEM Admin. Code , Rule Visible Emissions. 3. This source is subject to the requirements of ADEM Admin. Code for Rule particulate matter from Fuel Burning Equipment. 4. This source is subject to the requirements of ADEM Admin. Code for sulfur dioxide. 5. This source is subject to 40 CFR Part 63, Subpart DDDDD Emission Standards for Hazardous Air Pollutants for Major Sources: Commercial, Industrial, and Institutional Boilers and Process Heaters as a Gas 1 Boiler. Rule (107) Emission Standards 1. Visible emissions shall not be greater than 20% opacity, as determined by six (6) Rule (1) minute averages, except during one six (6) minute period in any sixty (60) minute period, an opacity not greater than that designated as forty percent (40%) may be discharged to the atmosphere. 2. Particulate matter emissions shall not exceed 0.12 pounds per million Btu. Rule The fuel oil sulfur content shall not exceed 0.5 percent and fuel oil use is limited to a Rule maximum of 3,834,864 gallons per rolling twelve month period. 4. This unit shall be classified as a Gas 1 Unit as defined in 40 CFR 63 Subpart DDDDD. Rule (107) In order to maintain this classification this unit is limited to firing liquid fuel for periodic testing of liquid fuel, maintenance, or operator training to a combined total of 48 hours during any calendar year. This limitation may be exceeded only during periods of gas curtailment or gas supply interruptions. 5. This source shall meet the energy assessment and tune-up requirements found in Table 3 of 40 CFR Part 63, Subpart DDDDD as referenced in 40 CFR (a). Rule (107) Compliance and Performance Test Methods and Procedures 1. Compliance with the Opacity limit shall be determined by 40 CFR Part 60 Appendix A, Reference Method 9. Rule Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Appendix A, Reference Method 5, or other method approved by the Department. 3. Compliance with the fuel oil sulfur content limit shall be determined in accordance with the appropriate ASTM method, or other method approved by the Department. Emission Monitoring 1. For sulfur dioxide periodic monitoring, obtain fuel oil vendor certification of sulfur Rule in fuel for every load received by the mill. 2. For particulate matter and opacity periodic monitoring (while firing fuel oil), if any six-minute opacity average exceeds 20 percent, up to 40 percent in any one hour period, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Rule Recordkeeping and Reporting Requirements 1. Records of daily one-minute visible emissions readings when the unit is burning fuel oil shall be made and maintained in a form suitable for inspection for a period of five years. 2. Fuel receipts from the fuel oil supplier that certify sulfur content in fuel for every load received by the mill shall be maintained on site available for inspection for at least five years. 1-2

17 Federally Enforceable Provisos 3. Records of when fuel oil is fired in the unit shall be made. It shall be documented if the fuel oil-firing is for burner testing/clean-out and if the firing period is less than 30 minutes. These records shall be kept available for inspections for at least five years. 4. This source shall maintain the records required under 40 CFR (a) concerning initial notifications. 5. This source shall submit a report annually documenting the required tune-ups, as specified in 40 CFR (c)(1). Rule (107) Rule (107) Rule (107) 1-3

18 No. 1 Bark Boiler Informational Summary Description: No. 1 Bark Boiler Emission Unit No: BK01 Installation Date: 1978 Reconstruction / Modification date: Operating Capacity: 245 MMBtu/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 61 Subpart E 40 CFR Part 63 Subpart DDDDD Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z009 No. 1 Bark Boiler Opacity < 20 percent with one 6-min period up to 40% in any one hour period Rule Z009 No. 1 Bark Boiler PM < 0.15 gr / 50% EA Z009 No. 1 Bark Boiler SO 2 < 8.9 lb / hr Z009 No. 1 Bark Boiler Filterable PM Z009 No. 1 Bark Boiler CO 0.44 lb.mmbtu (heat input) Rule (107) 3,500 ppmv on a dry basis, corrected to 3% O 2, 3-run average Rule (107) Z009 No. 1 Bark Boiler Hg < 3,200 grams per 24-hour period Rule (4) Z009 No. 1 Bark Boiler Hg 5.7E-06 lb/mmbtu (heat input) Rule (107) Z009 No. 1 Bark Boiler HCl 2.2E-02 lb/mmbtu (heat input) Rule (107) Permitted Fuels Fuel Max % Sulfur Max % Ash Natural Gas Wood Wastewater Treatment Plant Residuals

19 Federally Enforceable Provisos No. 1 Bark Boiler Provisos 2-2 Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R Rule , "Major Source Operating Permits". 2. This source is subject to the requirements of ADEM Admin. Code , Rule Visible Emissions. 3. This source is subject to the requirements of ADEM Admin. Code for particulate matter and sulfur dioxide. 4. This source is subject to the applicable requirements of 40 CFR Part 61 Subpart E for 40 CFR Part 61 Subpart E mercury and 40 CFR 61 Subpart A, General Provisions. 5. This source is subject to the applicable requirements of 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, as an existing hybrid suspension grate unit. Rule (107) Emission Standards 1. Visible emissions shall not be greater than 20% opacity, as determined by six (6) Rule minute averages, except during one six (6) minute period in any sixty (60) minute period, an opacity not greater than that designated as forty percent (40%) may be discharged to the atmosphere. 2. Particulate matter shall not exceed 0.15 grains per standard dry cubic foot adjusted to 50% excess air. 3. Sulfur dioxide emissions shall not exceed 8.9 pounds per hour. 4. Mercury emissions shall not exceed 3200 grams per 24-hour period. 40 CFR Part 61 Subpart E 5. As a surrogate for HAPs, carbon monoxide emissions shall not exceed 3,500 ppm by Rule (107) volume on a dry basis corrected to 3% oxygen, 3-run average. 6. Mercury emissions shall not exceed 5.7E-06 lb/mmbtu of heat input. Rule (107) 7. Hydrogen chloride emissions shall not exceed lb/mmbtu of heat input. Rule (107) 8. As a surrogate for HAPs, filterable particulate matter emissions shall not exceed 0.44 lb/mmbtu of heat input. Rule (107) Compliance and Performance Test Methods and Procedures 1. Compliance with the opacity limit shall be determined by 40 CFR Part 60, Appendix A, Reference Method 9. Rule Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60, Appendix A, Reference Method 5 or 17, or other method approved by the Department. 3. Compliance with the sulfur dioxide emission limit shall be determined by 40 CFR Part 60 Appendix A, Reference Method 6, or other method approved by the Department. 4. Compliance with the mercury emission limit shall be determined in accordance with the 40 CFR Part 60, Method 105 for Subpart E, and Methods 29, 30A, or 30B for Subpart DDDDD. Alternate test methods may be used provided prior approval by the Department is granted. 5. Compliance with the carbon monoxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 10. Alternate test methods may be used provided prior approval by the Department is granted. 6. Compliance with the hydrogen chloride emission limit shall be determined in accordance with the 40 CFR Part 60 Method 26 or 26A. Alternate test methods may be used provided prior approval by the Department is granted. Rule (107) Rule (107) Rule (107) Rule (107) Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. 2. For sulfur dioxide periodic monitoring, if any three-hour block average steam production rate is greater than 110 percent of its average value set by the required Rule

20 Federally Enforceable Provisos complying periodic test or a complying test approved by the Department, the steam production rate is to be lowered until compliance is successfully demonstrated at the higher rate. 3. For particulate matter periodic monitoring, if any three-hour block average pressure drop or liquid flow rate is less than 90 percent of its respective average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. 4. A sulfur dioxide emission test shall be performed at least once every five years. 5. Mercury re-testing for Subpart E is only required if changes are made in the operation that would potentially increase emissions above the level determined by the most recent sludge test. 6. A hydrogen chloride (HCl) performance test shall be performed annually within 13 Rule (107) months of the previous test. If performance tests for at least 2 consecutive years show that the hydrogen chloride emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for hydrogen chloride every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. 7. A mercury (Hg) performance test shall be performed annually within 13 months of Rule (107) the previous test. If performance tests for at least 2 consecutive years show that the mercury emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for mercury every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. 8. A carbon monoxide (CO) performance test shall be performed annually within 13 months of the previous test. If performance tests for at least 2 consecutive years show that the carbon monoxide emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for carbon monoxide every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. Rule (107) Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all three-hour block average steam production rates shall be made and maintained in a form suitable for inspection for at least five years. 3. Records of all three-hour block average wet scrubber pressure drops and liquid flow rates shall be made and maintained in a form suitable for inspection for at least five years. 4. A sulfur dioxide emission test shall be submitted to the Department at least once every five years. 5. This source shall maintain all applicable records required under 40 CFR Rule (107) 6. This source shall submit all applicable reports required under 40 CFR Rule (107) 2-3

21 No. 2 Bark Boiler Informational Summary Description: No. 2 Bark Boiler Emission Unit No: BK02 Installation Date: 1984 Reconstruction / Modification date: Operating Capacity: 667 MMBtu/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR 60 Subpart Db 40 CFR 61 Subpart E 40 CFR 63 Subpart DDDDD Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard X018 No. 2 Bark Boiler Opacity < 20% except for one 6-min period per Rule (1) & (2) hour of < 27% X018 No. 2 Bark Boiler PM <0.10 lb / MMBtu Rule (1) & (2) Rule X018 No. 2 Bark Boiler NOx < 0.30 lb / MMBtu, 30-day rolling Rule (1) & (2) average Rule < the more stringent of 0.8 lb / MMBtu Rule (1) & (2) and 38.6 tpy X018 No. 2 Bark Boiler SO 2 Fuel oil sulfur content shall be < 0.5% by weight X018 No. 2 Bark Boiler CO < 0.5 pounds per million Btu heat input. Rule X018 No. 2 Bark Boiler VOC Good combustion control techniques Rule Filterable Rule (107) X018 No. 2 Bark Boiler 0.44 lb/mmbtu (heat input) PM 3,500 ppmv, corrected to 3%, 3-run Rule (107) X018 No. 2 Bark Boiler CO average X018 No. 2 Bark Boiler Hg < 3,200 grams per 24-hour period Rule (4) X018 No. 2 Bark Boiler Hg 5.7E-06 lb/mmbtu (heat input) Rule (107) X018 No. 2 Bark Boiler HCl 2.2E-02 lb/mmbtu (heat input) Rule (107) Permitted Fuels Fuel Max % Sulfur Max % Ash Natural Gas No. 2 4 Fuel Oil Wastewater Treatment Plant Residuals Wood

22 Federally Enforceable Provisos No. 2 Bark Boiler Provisos Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (2) for opacity, particulate matter, nitrogen oxides, and sulfur dioxide. 3. This source is subject to the applicable requirements of Rule (1) and (2) and a prevention of significant deterioration best available control technology limit for particulate matter, nitrogen oxide and carbon monoxide. 4. This source is subject to the applicable requirements of Rule (1) and (2) and a prevention of significant deterioration synthetic minor limit for sulfur dioxide. 5. This source is subject to the requirements of ADEM Admin. Code (9)(b) for volatile organic compounds. 6. This source is subject to the applicable requirements of 40 CFR Part 60 Subpart Db and Rule (1) and (2)(b) for nitrogen oxides. 7. This source is subject to the applicable requirements of 40 CFR Part 61 Subpart E for mercury. 8. This source is subject to the applicable requirements of 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, as an existing hybrid suspension grate unit. Emission Standards 1. Opacity shall not be greater than 20 percent except for one six-minute period per Rule Rule (1) & (2) Rule (1) & (2) Rule (9) Rule (1) & (2) Rule Rule (9) Rule (1) & (2)(b) Rule (4) Rule (107) Rule (2) hour of not more than 27 percent. 2. Particulate emissions shall not exceed 0.1 pounds per million Btu heat input. Rule (2) Rule Nitrogen oxide emissions shall not exceed 0.3 pounds per million Btu heat input. Rule (2) Rule (9) 4. Sulfur dioxide emissions shall not exceed the more stringent of 0.8 pounds per million Btu heat input and 38.6 tons per rolling 12-month period. Rule (2) 5. The fuel oil sulfur content shall not exceed 0.5 percent by weight. 6. Carbon monoxide emissions shall not exceed 0.5 pounds per million Btu heat input. Rule (2) Rule (9) 7. Volatile organic compound emissions shall be controlled by the work practice standard of boiler design and combustion practices for maximum fuel efficiency and carbon monoxide compliance. Rule (9)(b) 8. As a surrogate for HAPs, carbon monoxide emissions shall not exceed 3,500 ppm Rule (107) by volume on a dry basis corrected to 3% oxygen. 9. As a surrogate for HAPs, filterable particulate matter emissions shall not exceed 0.44 lb/mmbtu of heat input, 3-run average. Rule (107) 10. Mercury emissions shall not exceed 3,200 grams per 24-hour period. Rule (4) 11. Mercury emissions shall not exceed 5.7E-06 lb/mmbtu of heat input. Rule (107) 12. Hydrogen chloride emissions shall not exceed lb/mmbtu of heat input. Rule (107) Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate (PM) emission rates of this unit shall be determined by Reference Method 5 or 17 in Appendix A of 40 CFR 60. Alternate test methods may be used provided prior approval by the Department is granted. 2. Compliance with the sulfur dioxide lb/mmbtu emission limit shall be determined in accordance with the 40 CFR Part 60, Method 6. Alternate test methods may be used provided prior approval by the Department is granted. Rule (107) 3-2

23 Federally Enforceable Provisos 3. Compliance with the nitrogen oxide pounds per million Btu limit shall be determined with the continuous emission monitor based on a thirty day rolling average. The nitrogen oxide continuous emission monitoring system shall be audited at least once per calendar quarter. A relative accuracy test audit shall be performed at least once every four calendar quarters. A cylinder gas audit may be performed in three of four calendar quarters but in no more than three quarters in succession. Compliance with the pound per hour emission limit shall be determined in accordance with 40 CFR Part 60, Appendix A, Method 7, 7A, 7B, 7C, 7D or 7E. Alternate test methods may be used provided prior approval by the Department is granted. 4. Compliance with the opacity standard for this unit shall be determined by Reference Method 9 in Appendix A of 40 CFR Compliance with the carbon monoxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 10. Alternate test methods may be used provided prior approval by the Department is granted. 6. Compliance with the sulfur in fuel limit shall be determined in accordance with the appropriate ASTM Method. 7. Compliance with the mercury emission limit shall be determined in accordance with the 40 CFR Part 60, Method 105 for Subpart E, and Methods 29, 30A, or 30B for Subpart DDDDD. Alternate test methods may be used provided prior approval by the Department is granted. 8. Compliance with the hydrogen chloride emission limit shall be determined in accordance with the 40 CFR Part 60, Method 26 or 26A. Alternate test methods may be used provided prior approval by the Department is granted. Emission Monitoring 1. A continuous emission monitoring system for the measurement of opacity, shall be installed, operated and maintained. 40 CFR Part 60 App. F Rule Rule (107) Rule (107) 2. A particulate matter emission test shall be performed at least once per year. 3. For particulate matter, sulfur dioxide, and carbon monoxide periodic monitoring, the facility shall track all steam production three-hour block averages. If any three-hour block average steam production rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the steam production rate is to be lowered until compliance is successfully demonstrated at the higher rate. Rule For sulfur dioxide periodic monitoring, obtain fuel oil vendor certification of sulfur in fuel for every load received by the mill. 5. A continuous emission monitoring system for the measurement of nitrogen oxides and oxygen shall be installed, operated and maintained. This continuous emission monitoring system shall be subject to the quality control and quality assurance requirements of 40 CFR Chapter 1, Part 60, Appendix F. 6. Any time fuel oil is fired the sulfur dioxide emission rate is to be calculated in pounds per hour. 7. The facility shall calculate a 12-month rolling total of SO 2 emissions on a monthly basis. The basis for the calculation will be the nature and amount of fuel fired in the unit. The facility will make the calculations within 7 days of the end of each month, and shall maintain these records, in a form suitable for inspection, for at least 5 years. 40 CFR Part 60 App. F 8. A sulfur dioxide emission test shall be performed at least once every five years. 9. Mercury re-testing for Subpart E is only required if changes are made in the operation that would potentially increase emissions above the level determined by the most recent sludge test. Rule (4) 10. A hydrogen chloride (HCl) performance test shall be performed annually within 13 months of the previous test. If performance tests for at least 2 consecutive years show that the hydrogen chloride emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for Rule (107) 3-3

24 Federally Enforceable Provisos hydrogen chloride every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. 11. A mercury (Hg) performance test shall be performed annually within 13 months of the previous test. If performance tests for at least 2 consecutive years show that the mercury emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for mercury every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. 12. A carbon monoxide (CO) performance test shall be performed annually within 13 months of the previous test. If performance tests for at least 2 consecutive years show that the carbon monoxide emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the boiler or air pollution control equipment that could increase emissions, performance tests may be conducted for carbon monoxide every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. Recordkeeping and Reporting Requirements 1. All six-minute average opacities are to be recorded and maintained in a form suitable for inspection for at least five years. 2. A report of excess opacity emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information: a. The magnitude of emissions greater than 20 percent computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 3. Records of the steam production rate shall be made at least once per shift and maintained on file available for inspection for at least five years. 4. Records of all three-hour block average steam production rates shall be made and maintained on file available for inspection for at least five years. 5. Maintain vendor oil specifications in a form suitable for inspection for at least five years. 6. Records of the rolling 12-month average sulfur dioxide emissions in tons shall be made within 7 days of the end of each calendar month, and maintained in a form suitable for inspection for at least five years. 7. The NO x emission rate shall be determined each day in lb/mmbtu and shall calculate a 30-day rolling average emission rate shall be calculated on a daily basis. 8. The nitrogen oxides continuous emissions monitoring system audit report shall be submitted to the Department within thirty days of the end of each calendar quarter. 9. A report of excess nitrogen oxide emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports shall include the following information: a. The magnitude of excess emissions greater than 0.3 pounds per million Btu computed on a 30 day rolling average (data recorded during periods of nitrogen Rule (107) Rule (107) Rule Rule Rule Rule (1)(b) Rule (1)(b) Rule (1)(b) 3-4

25 Federally Enforceable Provisos oxide emission monitoring system breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the nitrogen oxide emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the nitrogen oxide emission monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 10. A sulfur dioxide emission test shall be submitted to the Department at least once every five years. 11. This source shall maintain all applicable records required under 40 CFR Rule (107) 12. This source shall submit all applicable reports required under 40 CFR Rule (107) 3-5

26 Gas Turbine and Duct Burner Informational Summary Description: Gas Turbine and Duct Burner Emission Unit No: GT01 - DB01 Installation Date: 1994 Reconstruction / Modification date: Operating Capacity: 40MW MMBtu/hr (Gas Turbine) MMBtu/hr (Duct Burner) Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart Db 40 CFR Part 60 Subpart GG Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard X026 Gas Turbine PM 2.6 lb/hr (natural gas) Rule (9) 16.8 lb/hr (fuel oil) X026 Duct Burner PM 0.01 lb/mmbtu and 2.7 lb/hr (natural Rule (1) & (2)(b) gas) Rule (9) 25 ppm at 15% O 2 on a dry basis and Rule (1) & (33) X026 Gas Turbine NOx 47.8 lb/hr (natural gas) Rule (9) 44 ppm at 15% O 2 and 88.3 lb/hr (fuel oil) X026 Duct Burner NOx 0.08 lb/mmbtu and 22.1 lb/hr (natural Rule (1) & (2)(b) gas) Rule X026 Gas Turbine CO 44.2 lb/hr Rule (9) X026 Duct Burner CO 22.1 lb/hr Rule (9) X026 Gas Turbine VOC 0.8 lb/hr (natural gas) Rule (9) 2.0 lb/hr (fuel oil) X026 Duct Burner VOC 8.3 lb/hr (natural gas) Rule (9) X026 Gas Turbine Benzene lb/hr Rule (9) X026 Duct Burner Benzene 0.33 lb/hr Rule (9) X026 Gas Turbine SO 2 < 0.5% sulfur content; X026 Gas Turbine and Duct Burner Opacity < 1,027,000 gal/12 month period < 20% with one 6-min period up to 40% in any one hour period Rule Permitted Fuels Fuel Max % Sulfur Max % Ash Natural Gas No. 2 Fuel Oil

27 Federally Enforceable Provisos Gas Turbine and Duct Burner Provisos Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (2) and a prevention of significant deterioration best available control technology limit for particulate matter, nitrogen oxide, carbon monoxide, volatile organic compounds and benzene. 3. This source is subject to the applicable requirements of Rule (1) and (2) and a prevention of significant deterioration synthetic minor limit for sulfur dioxide. 4. This source is subject to the requirements of ADEM Admin. Code for Visible Emissions. 5. This source is subject to the applicable requirements of Rule (2)(b) and Rule (33), New Source Performance Standards Subpart Db, and Subpart GG, respectively for particulate matter and nitrogen oxides. Emission Standards 1. Particulate matter emissions from the stationary gas turbine (firing natural gas) shall not exceed 2.6 pounds per hour. 2. Particulate matter emissions from the stationary gas turbine (firing fuel oil) shall not exceed 16.8 pounds per hour. 3. Particulate matter emissions from the duct burner (firing natural gas) shall not exceed the more stringent of 0.01 pounds per million Btu and 2.7 pounds per hour. 4. Nitrogen oxide emissions from the stationary gas turbine (firing natural gas) shall not exceed the more stringent of 25 parts per million by volume at 15 percent oxygen on a dry basis and 47.8 pounds per hour. 5. Nitrogen oxide emissions from the stationary gas turbine (firing fuel oil) shall not exceed the more stringent of 44 parts per million by volume at 15 percent oxygen on a dry basis and 88.3 pounds per hour. Rule Rule (1) & (2) Rule (9) Rule (1) & (2) Rule Rule (1) & (2)(b) Rule (33) Rule (9) Rule Rule (1) & (2)(b) Rule Rule (9) Rule (1) & (33) Rule (9) Rule (1) & (33) 6. Nitrogen oxide emissions from the duct burner (firing natural gas) shall not exceed the more stringent of 0.08 pounds per million Btu and 22.1 pounds per hour. Rule (1), (2)(b) Rule (9) 7. Carbon monoxide emissions from the stationary gas turbine shall not exceed 44.2 Rule (9) pounds per hour. 8. Carbon monoxide emissions from the duct burner shall not exceed 22.1 pounds per Rule (9) hour. 9. Volatile organic compound emissions from the stationary gas turbine (firing fuel oil) shall not exceed 2.0 pounds per hour as methane. Rule (9) 10. Volatile organic compound emissions from the stationary gas turbine (firing natural Rule (9) gas) shall not exceed 0.8 pounds per hour as methane. 11. Volatile organic compound emissions from the duct burner (firing natural gas) shall Rule (9) not exceed 8.3 pounds per hour as methane. 12. Benzene emissions from the stationary gas turbine shall not exceed pounds Rule (9) per hour. 13. Benzene emissions from the duct burner shall not exceed 0.33 pounds per hour. Rule (9) 14. The fuel oil sulfur content shall not exceed 0.5 percent. No more than 1,027,000 gallons per twelve month period of this fuel oil may be fired in the stationary gas Rule (1) & (33) turbine. 15. The duct burner of the heat recovery steam generator (HRSG) shall be restricted to the firing of natural gas only. Rule

28 Federally Enforceable Provisos 16. Visible emissions shall not be greater than 20% opacity, as determined by six (6) minute averages, except during one six (6) minute period in any sixty (60) minute period, an opacity not greater than that designated as forty percent (40%) may be discharged to the atmosphere. 17. The gas turbine pre-cooler shall not be operated for greater than 4220 hours per any 12-month period. 18. Compliance with the Duct Burner particulate matter emission limit is demonstrated through compliance with the sum of the Gas Turbine and Duct Burner particulate matter emission limit of 5.3 lb/hr when firing natural gas. 19. Compliance with the Duct Burner nitrogen oxide emission limit is demonstrated through compliance with the sum of the Gas Turbine and Duct Burner nitrogen oxide emission limit of 69.9 lb/hr when firing natural gas. 20. Compliance with the Duct Burner carbon monoxide emission limit is demonstrated through compliance with the sum of the Gas Turbine and Duct Burner carbon monoxide emission limit of 66.3 lb/hr when firing natural gas. 21. Compliance with the Duct Burner volatile organic compound emission limit is demonstrated through compliance with the sum of the Gas Turbine and Duct Burner volatile organic compound emission limit of 9.1 lb/hr when firing natural gas. 22. Compliance with the Duct Burner benzene emission limit is demonstrated through compliance with the sum of the Gas Turbine and Duct Burner benzene emission limit of lb/hr when firing natural gas. Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60, Method 5 or other approved methods by the Department. 2. Compliance with the nitrogen oxide limit shall be determined in accordance with the 40 CFR Part 60, Method 20 or other approved methods by the Department. 3. Compliance with the carbon monoxide limit shall be determined in accordance with the 40 CFR Part 60, Method 10 or other approved methods by the Department. 4. Compliance with the volatile organic compound limit shall be determined in accordance with the 40 CFR Part 60, Method 25A or 25B or other approved methods by the Department. 5. Compliance with the benzene limit shall be determined in accordance with (c) (3) or other approved methods by the Department. 6. Compliance with the sulfur in fuel limit shall be determined in accordance with the appropriate ASTM Method or other approved methods by the Department. 7. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60, Method 9 or other approved methods by the Department. Emission Monitoring 1. A continuous emission monitoring system for the measurements of nitrogen oxides and oxygen shall be installed, calibrated, operated and maintained. The continuous emission monitoring systems shall be subject to the requirements of 40 CFR (b). 2. For sulfur dioxide periodic monitoring obtain fuel oil vendor certification of sulfur in fuel for every load received by the mill. 3. A stationary gas turbine and a duct burner particulate matter emission test shall be performed at least once every 5 years. 4. A stationary gas turbine and a duct burner carbon monoxide emission test shall be performed at least once every 5 years. 5. A stationary gas turbine and a duct burner volatile organic compound emission test shall be performed at least once every 5 years. 6. A stationary gas turbine and a duct burner benzene emission test shall be performed at least once every 5 years. Rule Rule (9) Rule (9) Rule (9) Rule (9) Rule (9) Rule (2) Rule (33) 4-3

29 Federally Enforceable Provisos 7. The owner or operator of any stationary gas turbine subject to the provisions of this section shall monitor sulfur content of the fuel being fired in the turbine. The frequency of determination of these values shall be as follows: a. If the turbine is supplied its fuel from a bulk storage tank, the values shall be determined on each occasion that fuel is transferred to the storage tank from any other source. b. If the turbine is supplied its fuel without intermediate bulk storage the values shall be determined and recorded daily. Owners, operators or fuel vendors may develop custom schedules for determination of the values based on the design and operation of the affected facility and the characteristics of the fuel supply. These custom schedules shall be substantiated with data and must be approved by the Administrator before they can be used to comply with paragraph 3 of this section. 8. For particulate matter, carbon monoxide, volatile organic compound and benzene periodic monitoring, if any three-hour block average stationary gas turbine natural gas or fuel oil firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the stationary gas turbine natural gas or fuel oil firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. 9. For particulate matter, carbon monoxide, volatile organic compound and benzene periodic monitoring, if any three-hour block average duct burner natural gas firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the duct burner natural gas firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. 10. The gas turbine pre-cooler hours of operation on a 12-month rolling basis shall be monitored. 11. The nitrogen oxide continuous emission monitoring system shall be audited at least once per calendar quarter. A relative accuracy test audit shall be performed at least once every four calendar quarters. A cylinder gas audit may be performed in three of four calendar quarters but in no more than three quarters in succession. 12. For particulate matter and opacity periodic monitoring while burning fuel oil, once per day, (weather permitting) one minute visible emissions readings of the stack s plume opacity shall be made and recorded (4 readings taken approximately every 15 seconds) by a person trained in, but not necessarily certified by, EPA Reference Method 9. If the opacity of the stack appears to be above 10 percent, immediate action to identify and correct the cause of the visible emissions is to be taken. After corrective action has been taken, another one minute observation (weather permitting) shall be taken of the stack s opacity. If the opacity observed does not appear to be in excess of 10%, then no further action is needed. If visible emissions still appear to be in excess of 10%, a 6-minute visible emissions reading shall be conducted (weather permitting) before the end of the day by a person certified in EPA Reference Method 9 to determine if the opacity is 20% or less. If the observed opacity is 20% or less, no further action is needed. If the observed opacity is greater than 20% but no greater than 40% another six-minute visible emission reading shall be conducted by the certified person to determine if the opacity is 20% or less. If no Method 9 reading is conducted despite emissions appearing to be in excess of the limit after corrective action has been taken or the source exceeds the opacity limit, the source shall be considered out of compliance with the permitted opacity limit for that day except if the reading was prevented due to weather conditions. If the required Method 9 reading is not taken due to weather conditions, one shall be taken the next day that weather conditions permit. Recordkeeping and Reporting Requirements Rule (33) Rule Rule Rule Rule CFR Part 60 App. F Rule

30 Federally Enforceable Provisos 1. A report of any daily period during which the sulfur content of the fuel being fired in the gas turbine exceeds 0.5 percent will be submitted to the Department for each calendar quarter within the month following the end of the quarter. 2. A stationary gas turbine and a duct burner particulate matter emission test report shall be submitted at least once every five years. 3. A stationary gas turbine and a duct burner carbon monoxide emission test report shall be submitted at least once every five years. 4. A stationary gas turbine and a duct burner volatile organic compound emission test report shall be submitted at least once every five years. 5. A stationary gas turbine and a duct burner benzene emission test report shall be submitted at least once every five years. 6. Records of all three-hour block average stationary gas turbine natural gas or fuel oil firing rates shall be made and maintained on file available for inspection for at least five years. 7. Records of all three-hour block average duct burner natural gas firing rates shall be made and maintained on file available for inspection for at least five years. 8. Records of daily one-minute visible emissions readings shall be made and maintained on file available for inspection for a period of five years. 9. Records shall be kept of the hours of operation of the gas turbine pre-cooler on a 12- month rolling basis on file available for inspection for at least 5 years. 10. The nitrogen oxide continuous emission monitoring system audit report shall be submitted to the Department within thirty days of the end of each calendar quarter. Rule Rule Rule (1) & (2)(b) 4-5

31 No. 1 Recovery Furnace Informational Summary Description: No. 1 Recovery Furnace Emission Unit No: RB01 Installation Date: 1966 Reconstruction / Modification date: 1981 Operating Capacity: 450 MMBtu/hr (1.8 MMlbs BLS per day) Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart MM Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard Z001 No. 1 Recovery Furnace PM < grains per SDCF at 8 % oxygen Z001 No. 1 Recovery Furnace TRS < 20 ppm at 8% oxygen (daily 12- hour average) and 4.5 ppm at 8% oxygen (12-month rolling average) Rule Z001 No. 1 Recovery Furnace (328,500 Tons of Black Liquor Solids Per Year) CO < 6.8 pounds per ton of black liquor solids Z001 No. 1 Recovery Furnace SO 2 < 107 pounds per hour Z001 No. 1 Recovery Furnace Opacity < 35 percent Rule Z001 No. 1 Recovery Furnace HAPs (Particulate as surrogate) < grains per SDCF at 8 % oxygen Rule (38) Permitted Fuels Fuel Max % Sulfur Max % Ash Black Liquor Solids 15 7 No. 2 4 Fuel Oil Natural Gas

32 Federally Enforceable Provisos No. 1 Recovery Furnace Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to PSD synthetic minor limits for particulate matter, total reduced sulfur, carbon monoxide and sulfur dioxide. 3. This source is subject to the applicable requirements of Rule such that the opacity limit is the same as but the source is not subject to the New Source Performance Standards, Subpart BB for Kraft recovery furnaces. 4. This source is subject to the requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63, Subpart MM as referenced in ADEM Admin. Code (38). Emission Standards 1. Particulate matter emissions shall not exceed grains per SDCF at 8 % oxygen. This alternate limit was established as provided under 40 CFR (a) (1) (ii). This unit is bubbled with the No. 3 Lime Kiln, No. 2 Recovery Furnace, and the Nos. 1 and 2 Smelt Tanks. 2. Total reduced sulfur emissions shall not exceed: a. 20 parts per million corrected to 8 percent oxygen on a daily twelve-hour basis. If an owner or operator demonstrates to the satisfaction of the Director that emissions in excess of the levels otherwise authorized in this regulation occur as a result of properly performed startups, shutdowns or unavoidable malfunctions these emissions will not constitute a violation. b. 4.5 ppmv corrected to 8 percent oxygen on a 12-month rolling average. 3. Carbon monoxide emissions shall not exceed 6.8 pounds per ton of black liquor Rule Rule Rule (1) & (38) Rule (5) Rule (38) Rule solids. 4. Sulfur dioxide emissions shall not exceed 107 pounds per hour. 5. Opacity shall not exceed 35% as determined by six-minute average. Rule (38) Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60, Method 5. Alternate test methods may be used provided prior approval by the Department is granted. 2. Compliance with the total reduced sulfur emission limit shall be determined in accordance with the continuous emission monitor, 40 CFR Part 60, Method 16, 16A or 16B. Alternate test methods may be used provided prior approval by the Department is granted. 3. Compliance with the carbon monoxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 10. Alternate test methods may be used provided prior approval by the Department is granted. 4. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 6. Alternate test methods may be used provided prior approval by the Department is granted. 5. Compliance with the opacity limit shall be determined in accordance with 40 CFR Part 60, Appendix A, Method 9. Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. 2. For particulate matter and opacity periodic monitoring, if the average of any ten consecutive six-minute opacity averages exceeds 20 percent the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Rule

33 3. For particulate matter, carbon monoxide and sulfur dioxide periodic monitoring, if Rule any three-hour rolling average liquor firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the liquor firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. 4. A continuous emission monitoring system for the measurement of opacity shall be installed, operated and maintained. Rule (38) 5. A continuous emission monitoring system for the measurement of total reduced sulfur and oxygen shall be installed, operated and maintained. Rule A carbon monoxide emission test shall be performed at least once every five years. Rule A sulfur dioxide emission test shall be performed at least once every five years. Rule For carbon monoxide periodic monitoring, if any three-hour rolling average stack Rule oxygen percentage is less than 50 percent of the average oxygen percentage set by the required complying periodic test or a complying emission test approved by the Department, the oxygen percentage is to be raised until compliance is successfully demonstrated at the lower rate. 9. The first periodic particulate matter performance test shall be performed by October 13, 2020 pursuant to and every five years thereafter. Rule (38) Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all 1-hour rolling average six-minute average opacities shall be made Rule and maintained on file available for inspection for at least five years. These records shall include any period when operating parameter levels were inconsistent with levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred the time the corrective action was initiated and completed, and the corrective action taken. 3. Records of all three-hour rolling average liquor firing rates shall be made and maintained on file available for inspection for at least five years. 4. A report of excess total reduced sulfur emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information: Rule (9) a. The magnitude of excess emissions greater than 20 parts per million adjusted to 8 percent oxygen computed from twelve hour averages (data recorded during periods of total reduced sulfur emission monitoring system breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the total reduced sulfur emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the total reduced sulfur emission monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 5. A report of excess opacity emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The report will include the following information: Rule (9) 5-3

34 a. The magnitude of emissions 20 percent and greater computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 6. A carbon monoxide emission test report shall be submitted to the Department at least every five years. 7. A sulfur dioxide emission test report shall be submitted to the Department at least every five years. 8. Records of all three-hour rolling average stack oxygen values shall be made and maintained in a form suitable for inspection for at least five years. 9. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of any occurrence when corrective action is required when the average of ten consecutive 6-minute averages result in a measurement greater than 20 percent opacity, and when a violation is noted when opacity is greater than 35 percent for 6 percent or more of the operating time within any quarterly period. Upon the compliance date of October 11, 2019, a violation will be when opacity is greater than 35 percent for 2 percent or more of the operating time within any semiannual period. The facility must also maintain records and documentation of supporting calculations for compliance determinations made under 40 CFR (a) through (d). 10. The facility shall maintain records of all 6-minute periods when the opacity is greater than 35%. 11. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of the black liquor firing rates in terms of tons/day or Mg/day. 12. Records and supporting documentation shall be kept for the compliance determinations, operating ranges, and parameter ranges established for this unit. 13. Records of total reduced sulfur emissions shall be made and maintained in a form suitable for inspection for at least five years. Rule (1) & (38) Rule (1) & (38) Rule (1) & (38) 5-4

35 14. Pursuant to 40 CFR Part 63, Subpart MM the facility must submit an Excess Emissions Report containing the information required in 40 CFR (c), as well as the number and duration of occurrences when the average of ten consecutive 6- minute averages result in a measurement greater than 20 percent opacity, and when the opacity is greater than 35 percent for 6 percent or more of the operating time within any quarterly period. The report is required to be submitted quarterly if the unit exceeds 35 percent for 6 percent or more of the operating time within any quarterly period, or semi-annually if the unit does not. The reports will include the following information: a. The magnitude of emissions greater than 35 percent computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report. The report is required to be submitted quarterly if the unit exceeds 20 percent for 6 percent or more of the operating time within any quarterly period, or semi-annually if the unit does not. Note that after the compliance date of October 11, 2019 for Subpart MM, an excess emission will be 35 percent opacity for 2 percent or more of the operating time within any semiannual period. Rule (1) & (38) 5-5

36 No. 1 Smelt Dissolving Tank Informational Summary Description: No. 1 Smelt Tank Emission Unit No: ST01 Installation Date: 1966 Reconstruction / Modification date: 2013 Operating Capacity: 75,000lb BLS/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart MM Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard Z003 No. 1 Smelt Tank PM < 0.5 lb/adtp, 3-hour Rule average Z003 No. 1 Smelt Tank (State only) TRS < lb/tbls Rule Z003 No. 1 Smelt Tank Opacity < 20% with one 6-min period Rule up to 40% in any one hour period Z003 No. 1 Smelt Tank HAPs (Particulate as surrogate) < lb/tbls (0.158 grains per dry standard cubic foot) Rule (38) 6-1

37 Federally Enforceable Provisos No. 1 Smelt Dissolving Tank Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to the requirements of ADEM Admin. Code (2) (b) particulate matter from Kraft pulp mill smelt tanks. 3. This source is subject to the requirements of ADEM Admin. Code for opacity. 4. This source is subject to the requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code (38). Emission Standards 1. Particulate matter emissions shall not exceed pounds per ton of black liquor solids (dry weight) (0.158 gr/dscf). This alternate limit was established as provided under 40 CFR (a)(1)(ii). This unit is bubbled with the No. 3 Lime Kiln, Nos. 1 and 2 Recovery Furnaces, and the No. 2 Smelt Tank. 2. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty minute period, a person may discharge into the atmosphere from any source of emission, particulate of an opacity not greater than that designated as forty percent. Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate (PM) emission rates of this unit shall be determined by Reference Method 5 in Appendix A of 40 CFR 60. Alternate test methods may be used provided prior approval by the Department is granted. 2. Compliance with the opacity standard for this unit shall be determined by Reference Method 9 in Appendix A of 40 CFR 60. Alternate test methods may be used provided prior approval by the Department is granted. Rule Rule (2)(b) Rule Rule (1) & (38) Rule (2)(b) Rule (38) Rule Rule Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. 2. Pursuant to 40 CFR Part 63, Subpart MM, the facility shall monitor the scrubber total liquid supply flow rate (combined flow to the fan and lower zone spray nozzles) and the fan ampere. The parametric monitoring system shall meet the requirements listed in 40 CFR 63.8(c). Monitoring of the flow rate and fan ampere is an approved alternative to the requirements listed in 40 CFR (e)(10). This unit shall not have 6 or more 3-hour average parameter values within any 6- month reporting period that are outside the range of values established in accordance with 40 CFR (j) and (k). No more than one exceedance will be attributed in any given 24-hour period. Rule (1) & (38) 3. For particulate matter periodic monitoring, if any three-hour rolling average liquor firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the liquor firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. 4. For particulate matter periodic monitoring if any three-hour rolling average wet scrubber liquid flow rate is less than 90 percent of its respective average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Fan on/off status shall be monitored. Rule Rule

38 Federally Enforceable Provisos 5. The first periodic particulate matter performance test shall be performed by October 13, 2020 pursuant to and every five years thereafter. Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all three-hour rolling average liquor firing rates shall be made and maintained in a form suitable for inspection for at least five years. 3. Records of all three-hour rolling average wet scrubber liquid flow rates and Fan on/off status shall be made and maintained in a form suitable for inspection for at least five years. 4. Records and supporting documentation shall be kept for the compliance determinations, operating ranges, and parameter ranges established for this unit. 5. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of any occurrence when corrective action is required (when a 3-hour average flow rate or rpm value is outside the established range of values), and when a violation is noted (when six or more 3-hour average flow rate or ampere values within any 6-month reporting period are outside the established range of values). 6. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of parametric monitoring data required under 40 CFR , including any period when the 3-hour average flow rate or ampere value were inconsistent with the levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred, and the time corrective action was initiated and completed, and corrective action taken. The facility must also maintain records and documentation of supporting calculations for compliance determinations made under 40 CFR (a) through (d). The facility must also maintain the records of the monitoring parameter ranges for the fan amperes and scrubber flow rates. 7. The facility shall submit an Excess Emissions Report containing the information required in 40 CFR (c), as well as the number and duration of three hour averages when the flow rate or ampere values were outside of the established ranges. The report is required to be submitted quarterly if there is an exceedance of parameters, or semi-annually if there is not. Rule (38) Rule (38) Rule (1) & (38) Rule (1) & (38) Rule (38) 6-3

39 State Only Enforceable Provisos Applicability (State Only) 1. This source is subject to the requirements of ADEM Admin. Code (7) total reduced sulfur from kraft pulp mill smelt tanks. Emission Standards (State Only) 1. Total reduced sulfur emissions shall not exceed pounds per ton of black liquor solids. If an owner or operator demonstrates to the satisfaction of the Director that emissions in excess of the levels otherwise authorized in this regulation occur as a result of properly performed startups, shutdowns or unavoidable malfunctions these emissions will not constitute a violation. Compliance and Performance Test Methods and Procedures (State Only) 1. Compliance with the total reduced sulfur emission limit shall be determined in accordance with the continuous emission monitor, 40 CFR Part 60, Method 16, 16A or 16B. Emission Monitoring (State Only) 1. A total reduced sulfur emission test shall be performed within 90 days of permit issuance or re-issuance to certify compliance and set periodic monitoring parameters. 2. For total reduced sulfur periodic monitoring, if the three-hour block average wet scrubber weak wash recirculation flow rate is less than 90 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within 24 hours. Fan on/off status shall be monitored. Recordkeeping and Reporting Requirements (State Only) 1. A total reduced sulfur emission test report shall be submitted to the Department at least once every 5 years. 2. Records of all three-hour block average wet scrubber weak wash recirculation flow rates shall be made and maintained in a form suitable for inspection for at least five years. Rule (7) Rule Rule

40 No. 2 Recovery Furnace Informational Summary Description: No. 2 Recovery Furnace Emission Unit No: RB02 Installation Date: 1981 Operating Capacity: 675 MMBtu/hr Reconstruction / Modification date: (2.7 MMlb BLS/day) Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart MM Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard Z010 No. 2 Recovery Furnace PM < gr / SDCF at 8% O 2 Rule (28) Rule (9) Rule (38) Z010 No. 2 Recovery Furnace TRS < 5 ppmv at 8% O 2 Rule (1) & (28) Rule (9) Z010 No. 2 Recovery Furnace SO 2 < 1901 tpy Rule (9) Z010 No. 2 Recovery Furnace NOx < lb/hr Rule (9) Z010 No. 2 Recovery Furnace Opacity < 35% Rule Rule (9) Z010 No. 2 Recovery Furnace CO < lb/hr Rule (9) Z010 No. 2 Recovery Furnace VOC Work practice standard of boiler design and operating practices to minimize total reduced sulfur Rule (9) Z010 No. 2 Recovery Furnace HAPs (Particulate as surrogate) < gr / SDCF at 8% O 2 Rule (38) Permitted Fuels Fuel Max % Sulfur Max % Ash Natural Gas No. 2 4 Fuel Oil 0 Black Liquor Solids

41 Federally Enforceable Provisos No. 2 Recovery Furnace Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (28) New Source Performance Standards Subpart BB for Kraft pulp mills. 3. This Source is subject to the requirements of ADEM Admin. Code (9)(b) for particulate matter, total reduced sulfur, sulfur dioxide, nitrogen oxide, carbon monoxide, volatile organic compounds and opacity. 4. This source is subject to the requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code (38). Emission Standards 1. Particulate matter emissions shall not exceed grains per SDCF at 8% oxygen. This limit is established under 40 CFR (a)(1)(ii). This unit is bubbled with the No. 3 Lime Kiln, No. 1 Recovery Furnace, and the Nos. 1 and 2 Smelt Tanks. 2. Total reduced sulfur emissions shall not exceed 5 parts per million by volume at 8% oxygen. Rule Rule (1) & (28) Rule (9) Rule (1) & (38) Rule (1) & (28) Rule (9) Rule (1) & (28) Rule (9) 3. Sulfur dioxide emissions shall not exceed 1901 tons per year. Rule (9) 4. Nitrogen oxide emissions shall not exceed pounds per hour. Rule (9) 5. Opacity shall not exceed 35 percent as determined by six-minute average and shall be less than 20 percent as determined by 1 hour average. Rule (28) Rule (9) 6. Carbon monoxide emissions shall not exceed pounds per hour. Rule (9) 7. Volatile organic compound emissions shall be controlled by the work practice standard of boiler design and operating practices to minimize total reduce sulfur. Rule Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60, Method 5. Alternate test methods may be used provided prior approval by the Department is granted. 2. Compliance with the total reduced sulfur emission limit shall be determined in accordance with 40 CFR Part 60, Method 16, 16A or 16B or the continuous emission monitor. Alternate test methods may be used provided prior approval by the Department is granted. 3. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 6. Alternate test methods may be used provided prior approval by the Department is granted. 4. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 7 or 7e. Alternate test methods may be used provided prior approval by the Department is granted. 5. Compliance with the opacity limit shall be determined in accordance with 40 CFR Part 60, Appendix A, Method Compliance with the carbon monoxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 10. Alternate test methods may be used provided prior approval by the Department is granted. Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. 2. For particulate matter and opacity periodic monitoring, if the average of any ten consecutive six-minute opacity averages exceeds 20 percent the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Rule

42 Federally Enforceable Provisos 3. For particulate matter, total reduced sulfur, sulfur dioxide, nitrogen oxides and carbon monoxide, periodic monitoring, if any three-hour rolling average liquor firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the liquor firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. 4. The continuous emission monitoring system for the measurement of total reduced sulfur and oxygen shall be, calibrated, operated and maintained. 5. The continuous emission monitoring system for the measurement of opacity shall be Rule Rule (28) Rule (38) calibrated, operated and maintained. 6. A sulfur dioxide emission test shall be performed at least once every five years. 7. A nitrogen oxide emission test shall be performed at least once every five years. 8. A carbon monoxide emission test shall be performed at least once every five years. 9. For carbon monoxide periodic monitoring, if any three-hour rolling average stack oxygen percentage is less than 50 percent of the average oxygen percentage set by the required complying periodic test or a complying emission test approved by the Department, the oxygen percentage is to be raised until compliance is successfully demonstrated at the lower rate. 10. The first periodic particulate matter performance test shall be performed by October 13, 2020 pursuant to and every five years thereafter. Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all one-hour rolling average six-minute average opacities shall be made and maintained in a form suitable for inspection for at least five years. These records shall include any period when operating parameter levels were inconsistent with levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred the time the corrective action was initiated and completed, and the corrective action taken. 3. Records of all three-hour rolling average liquor firing rates shall be made and maintained on file available for inspection for at least five years. 4. A report of excess total reduced sulfur emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information: a. The magnitude of excess emissions above 5 parts per million adjusted to 8 percent oxygen computed from twelve hour averages (data recorded during periods of total reduced sulfur emission monitoring system breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the total reduced sulfur emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the total reduced sulfur emission monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 5. A sulfur dioxide emission test report shall be submitted to the Department at least every five years. 6. A nitrogen oxide emission test report shall be submitted to the Department at least every five years. Rule (38) 7-3

43 Federally Enforceable Provisos 7. Pursuant to 40 CFR Part 63, Subpart MM the facility must submit an Excess Emissions Report containing the information required in 40 CFR 63.10(c), as well as the number and duration of occurrences when the average of ten consecutive 6-minute averages result in a measurement greater than 20 percent opacity, and when the opacity is greater than 35 percent for 6 percent or more of the operating time within any quarterly period. The report is required to be submitted quarterly if the unit exceeds 35 percent for 6 percent or more of the operating time within any quarterly period, or semiannually if the unit does not. The reports will include the following information: a. The magnitude of emissions greater than 35 percent computed on a six-minute average (data recorded during periods of opacity monitor breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted. d. The date and time identifying each period during which the opacity monitor was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the opacity monitor was not inoperative or did not require repairs or adjustments, such information will be stated in the report. The report is required to be submitted quarterly if the unit exceeds 20 percent for 6 percent or more of the operating time within any quarterly period, or semi-annually if the unit does not. Upon the compliance date of October 11, 2019, a violation will be when opacity is greater than 35 percent for 2 percent or more of the operating time within any semiannual period. 8. A carbon monoxide emission test report shall be submitted to the Department at least every five years. 9. Records of all three-hour rolling average stack oxygen values shall be made and maintained in a form suitable for inspection for at least five years. 10. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of any occurrence when corrective action is required when the average of ten consecutive 6- minute averages result in a measurement greater than 20 percent opacity, and when a violation is noted when opacity is greater than 35 percent for 6 percent or more of the operating time within any quarterly period. Upon the compliance date of October 11, 2019, a violation will be when opacity is greater than 35 percent for 2 percent or more of the operating time within any semiannual period. The facility must also maintain records and documentation of supporting calculations for compliance determinations made under 40 CFR (a) through (d). 11. The facility shall maintain records of all 6-minute periods when the opacity is greater than 35%. 12. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of the black liquor firing rates in terms of tons/day or Mg/day. 13. Records and supporting documentation shall be kept for the compliance determinations, operating ranges, and parameter ranges established for this unit. Rule (1) & (38) Rule (1) & (38) Rule (1) & (38) Rule (1) & (38) 7-4

44 No. 2 Smelt Dissolving Tank Informational Summary Description: No. 2 Smelt Dissolving Tank Emission Unit No: ST02 Installation Date: 1981 Reconstruction / Modification date: Operating Capacity: 112,500 lb BLS/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart MM Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard Z011 No. 2 Smelt Dissolving Tank PM < 0.2 lb/tbls (dry weight) Rule (1) & (28) Rule (9) Z011 No. 2 Smelt Dissolving Tank TRS < lb/tbls Rule (1) & (28) Rule (9) Z011 No. 2 Smelt Dissolving Tank SO 2 < 11.4 lb/hr Rule (9) Z011 No. 2 Smelt Dissolving Tank Opacity < 20% with one 6-min period up to Rule % in any one hour period Z011 No. 2 Smelt Dissolving Tank VOC Work practice standard of low volatile Rule (9) organic compound containing scrubber medium in the smelt tank scrubber Z011 No. 2 Smelt Dissolving Tank HAPs (Particulate as a surrogate) Particulate as a surrogate Rule (1) & (38) 8-1

45 Federally Enforceable Provisos No. 2 Smelt Dissolving Tank Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (28), New Source Performance Standards Subpart BB for Kraft pulp mills. 3. This source is subject to the applicable requirements of Rule for particulate matter, total reduced sulfur, sulfur dioxide and volatile organic compounds. 4. This source is subject to the requirements of ADEM Admin. Code for opacity. 5. This source is subject to the requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code (38). Emission Standards 1. Particulate matter emissions shall not exceed 0.2 pounds per ton of black liquor solids (dry weight). This limit was established as provided under 40 CFR (a)(1)(ii), the total particulate matter emissions shall not exceed grains per dry standard cubic foot. This unit is bubbled with the No. 3 Lime Kiln, Nos. 1 and 2 Recovery Furnaces, and the No. 1 Smelt Tank. 2. Total reduced sulfur emissions shall not exceed pounds per ton of black liquor solids. Rule Rule (1) & (28) Rule Rule Rule (1) & (38) Rule (1) & (28) Rule (9) Rule (1) & (38) Rule Rule (9) 3. Sulfur dioxide emissions shall be no greater than 11.4 pounds per hour. Rule (9) 4. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty minute period, a person may discharge into the atmosphere from any source of emission, particulate of an opacity not greater than that designated as forty percent. 5. This source is subject to the applicable requirements of ADEM Admin. Code for volatile organic compounds. Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60, Method 5, or other method approved by the Department. 2. Compliance with the total reduced sulfur emission limit shall be determined in accordance with 40 CFR Part 60, Method 16, 16A or 16B, or other method approved by the Department. 3. Compliance with the sulfur dioxide emission limit shall be determined in accordance with 40 CFR Part 60, Method 6, or other method approved by the Department. Rule Rule (9) 4. Compliance with the opacity limit shall be determined in accordance with the 40 CFR Part 60, Method 9. Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. 2. A total reduced sulfur emission test shall be performed at least once every five years. 3. A sulfur dioxide emission test shall be performed at least once every five years. 4. For particulate matter and total reduced sulfur periodic monitoring, if any three-hour rolling average liquor firing rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the liquor firing rate is to be lowered until compliance is successfully demonstrated at the higher rate. Rule

46 Federally Enforceable Provisos 5. For particulate matter periodic monitoring, if any three-hour rolling average wet scrubber liquid flow rate is less than 90 percent of its respective average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Fan on/off status shall be monitored. 6. For total reduced sulfur and sulfur dioxide periodic monitoring, if any three-hour rolling average wet scrubber liquid recirculation flow rate is less than 90 percent of its respective average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. Fan on/off status shall be monitored. 7. Volatile organic compound emissions shall be controlled by the work practice standard of low volatile organic compound containing scrubber medium in the smelt tank scrubber. 8. Pursuant to 40 CFR Part 63, Subpart MM, the facility shall monitor the scrubber total liquid supply flow rate (combined flow to the fan and lower zone spray nozzles) and the fan ampere. The parametric monitoring system shall meet the requirements listed in 40 CFR 63.8(c). Monitoring of the flow rate and fan ampere is an approved alternative to the requirements listed in 40 CFR (e)(10). This unit shall not have 6 or more 3-hour average parameter values within any 6- month reporting period that are outside the range of values established in accordance with 40 CFR (j) and (k). No more than one exceedance will be attributed in any given 24-hour period. 9. The first periodic particulate matter performance test shall be performed by October 13, 2020 pursuant to and every five years thereafter. Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all three-hour rolling average liquor firing rates shall be made and maintained in a form suitable for inspection for at least five years. 3. Records of all three-hour rolling average wet scrubber liquid flow rates and fan on/off status shall be made and maintained in a form suitable for inspection for at least five years. 4. A sulfur dioxide emission test report shall be submitted to the Department at least once every five years. 5. A total reduced sulfur emission test report shall be submitted to the Department at least once every five years. 6. Records and supporting documentation shall be kept for the compliance determinations, operating ranges, and parameter ranges established for this unit. 7. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of any occurrence when corrective action is required (when a 3-hour average flow rate or rpm value is outside the established range of values), and when a violation is noted (when six or more 3-hour average flow rate or ampere values within any 6-month reporting period are outside the established range of values). Rule Rule Rule (1) & (38) Rule (38) Rule (38) Rule (1) & (38) 8-3

47 Federally Enforceable Provisos 8. Pursuant to 40 CFR Part 63, Subpart MM the facility must maintain records of parametric monitoring data required under 40 CFR , including any period when the 3-hour average flow rate or ampere value were inconsistent with the levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred, and the time corrective action was initiated and completed, and corrective action taken. The facility must also maintain records and documentation of supporting calculations for compliance determinations made under 40 CFR (a) through (d). The facility must also maintain the records of the monitoring parameter ranges for the fan amperes and scrubber flow rates. 9. The facility shall submit an Excess Emissions Report containing the information required in 40 CFR (c), as well as the number and duration of three hour averages when the scrubber flow rate or ampere values were outside of the established ranges. The report is required to be submitted quarterly if there is an exceedance of parameters, or semi-annually if there is not. Rule (1) & (38) Rule (38) 8-4

48 No. 1 Multiple Effect Evaporators Informational Summary Description: No. 1 Multiple Effect Evaporators Emission Unit No: EV01 Installation Date: 1966 Reconstruction / Modification date: 1995 Operating Capacity: Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z004 No. 1 Multiple Effect Evaporators TRS Incineration Rule (1) & (28) Z004 No. 1 Multiple Effect Evaporators HAPs Incineration Rule (1) & (18) 9-1

49 No. 1 Multiple Effect Evaporators Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits" 2. This source is subject to federal New Source Performance Standards Subpart BB and 40 CFR 60 Subpart A, General Provisions. 3. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes Process Condensates and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. All gases discharged that contain total reduced sulfur in excess of 5 parts per million on a dry basis corrected to 10% oxygen shall be incinerated in either the No. 3 Lime Kiln or Standby Incinerator subjecting the gases to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 seconds. 2. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Compliance and Performance Test Methods and Procedures 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Emission Monitoring 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Recordkeeping and Reporting Requirements 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Rule Rule (1) & (28) Rule (1) & (18) Rule (28) Rule (18) Rule (18) Rule (18) Rule (18) 9-2

50 No. 2 Multiple Effect Evaporators Informational Summary Description: No. 2 Multiple Effect Evaporators Emission Unit No: EV02 Installation Date: 1981 Reconstruction / Modification date: Operating Capacity: Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z013 No. 2 Multiple Effect Evaporators TRS Incineration Rule (1) & (28) Z013 No. 2 Multiple Effect Evaporators HAPs Incineration Rule (1) & (18) 10-1

51 No. 2 Multiple Effect Evaporators Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits" 2. This source is subject to federal New Source Performance Standards Subpart BB and 40 CFR 60 Subpart A, General Provisions. 3. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. All gases discharged that contain total reduced sulfur in excess of 5 parts per million on a dry basis corrected to 10% oxygen shall be incinerated in either the No. 3 Lime Kiln or Standby Incinerator subjecting the gases to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 seconds. 2. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Compliance and Performance Test Methods and Procedures 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Emission Monitoring 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Recordkeeping and Reporting Requirements 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for details. Rule Rule (1) & (28) Rule (1) & (18) Rule (28) Rule (18) Rule (18) Rule (18) Rule (18) 10-2

52 No. 3 Lime Kiln Informational Summary Description: No. 3 Lime Kiln Emission Unit No: LK03 Installation Date: 1986 Reconstruction / Modification date: Operating Capacity: 31,667 lb CaO/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart MM Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard X019 No. 3 Lime Kiln PM < gr/sdcf at 10 % O 2 when firing liquid fossil fuel or 42 lbs/hr; and gr/sdcf at 10% O 2 when firing gaseous fossil fuel Rule (28) Rule (9) Rule (38) X019 No. 3 Lime Kiln TRS < 8 ppm at 10% O 2 Rule (28) Rule (9) X019 No. 3 Lime Kiln SO 2 < 8.5 lb/hr X019 No. 3 Lime Kiln CO < 3.4 lb/hr Rule X019 No. 3 Lime Kiln NOx < 37.3 lb/hr Rule (9) X019 No. 3 Lime Kiln Opacity < 20% with one 6min period up to 40% in any Rule one hour period X019 No. 3 Lime Kiln VOC Work practice standard of kiln design and process Rule (9) control practices X019 No. 3 Lime Kiln HAPs < gr/sdcf at 10 % O 2 when firing liquid fossil fuel or 42 lbs/hr; and gr/sdcf at 10% O 2 when firing gaseous fossil fuel Rule (1) & (38) Fuel Max % Sulfur Max % Ash Natural Gas

53 Federally Enforceable Provisos No. 3 Lime Kiln Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to federal New Source Performance Standards 40 CFR 60 Subpart A and Subpart BB. 3. This Source is subject to the requirements of ADEM Admin. Code (9)(b) for particulate matter, sulfur dioxide, carbon monoxide, nitrogen oxide and volatile organic compounds. 4. This source is subject to the requirements of ADEM Admin. Code for opacity. 5. This source is subject to the requirements of National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart MM and 40 CFR Part 63 Subpart MM as referenced in ADEM Admin. Code (38). Emission Standards 1. Particulate emissions shall not exceed gr/sdcf at 10 percent oxygen when liquid fossil fuel is fired. Particulate emissions shall not exceed gr/sdcf at 10 percent oxygen when gaseous fossil fuel is fired. The above emission limits are based on Bubble limits with the Nos. 1 and 2 Recovery Furnaces, and Nos. 1 and 2 Smelt Tanks. 2. Total reduced sulfur emissions shall not exceed 8 parts per million at 10 percent oxygen averaged over discrete 12 hour periods. Rule Rule (1) & (28) Rule (9) Rule Rule (1) & (38) Rule (28) Rule (9) Rule (38) Rule (28) Rule (9) 3. Sulfur dioxide emissions shall not exceed 8.5 pounds per hour. 4. Combined sulfur dioxide emissions from the No. 3 Lime Kiln and the Backup Noncondensable Gas Incinerator shall not exceed 37.2 tons per 12-month rolling period. The incinerator operating time is limited to no more than 1465 hours per rolling 12- month period. Rule (9) 5. Carbon monoxide emissions shall not exceed 3.4 pounds per hour. Rule (9) 6. Nitrogen oxide emissions shall not exceed 37.3 pounds per hour. Rule (9) 7. Opacity shall not exceed twenty percent as determined by six-minute average. During one six-minute period in any sixty-minute period, a person may discharge into the atmosphere from any source of emission, particulate of an opacity not greater than that designated as forty percent. Rule Volatile organic compound emissions shall be controlled by the work practice standard of kiln design and process control practices that are being performed for total reduced sulfur compliance. Compliance and Performance Test Methods and Procedures 1. Compliance with the particulate matter emission limit shall be determined in accordance with the 40 CFR Part 60 Method 5. Alternate test methods may be used provided prior approval by the Department is granted. 2. Compliance with the sulfur dioxide emission limit shall be determined in accordance with the 40 CFR Part 60 Method 6. Alternate test methods may be used provided prior approval by the Department is granted. 3. Compliance with the carbon monoxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 10. Alternate test methods may be used provided prior approval by the Department is granted. 4. Compliance with the nitrogen oxide emission limit shall be determined in accordance with the 40 CFR Part 60, Method 7e. Alternate test methods may be used provided prior approval by the Department is granted. Rule (9) 11-2

54 Federally Enforceable Provisos Compliance with the opacity limit shall be determined in accordance with the 40 CFR Rule Part 60, Method Compliance with the total reduced sulfur emission limit shall be determined utilizing a continuous emissions monitor or in accordance with 40 CFR Part 60, Method 16, 16A or 16B. Rule (28) Emission Monitoring 1. A particulate matter emission test shall be performed at least once per year. Rule For particulate matter, sulfur dioxide, carbon monoxide and nitrogen oxide periodic Rule monitoring, if any three-hour rolling average lime mud feed rate is greater than 110 percent of its average value set by the required complying periodic test or a complying test approved by the Department, the feed rate is to be lowered until compliance is successfully demonstrated at the higher rate. 3. For particulate matter periodic monitoring, if any three-hour rolling average pressure Rule drop or liquid flow rate is less than 90 percent of its respective average value set by the required complying periodic test or a complying test approved by the Department, the cause is to be investigated and appropriate corrective action is to be taken within twenty-four hours. 4. A total reduced sulfur continuous emission monitor shall be installed, calibrated, Rule (28) maintained and operated in accordance with 40 CFR , except that monitoring spans may be approved by the Director. 5. A sulfur dioxide emission test shall be performed at least once every five years. 6. A nitrogen oxide emission test shall be performed at least once every five years. 7. A carbon monoxide emission test shall be performed at least once every five years. 8. The number of hours of backup non-condensable gas incinerator operation when the unit is incinerating non-condensable gases shall be monitored. 9. In accordance with 40 CFR Part 63, Subpart MM, the facility shall monitor the wet scrubber liquid supply flow rate and pressure drop. The parametric monitoring system shall meet the requirements listed in 40 CFR 63.8(c). This unit shall not have 6 or more 3-hour average parameter values within any 6- month reporting period that are outside the range of values established in accordance with 40 CFR (j) and (k). No more than one exceedance will be attributed in any given 24-hour period. Rule (38) 10. The first periodic particulate matter performance test shall be performed by October Rule (38) 13, 2020 pursuant to and every five years thereafter. Recordkeeping and Reporting Requirements 1. A particulate matter emission test report shall be submitted to the Department at least once per year. 2. Records of all three-hour block average lime mud flow rates shall be made and maintained in a form suitable for inspection for at least five years. 3. Records of all three-hour rolling average wet scrubber pressure drops and liquid flow rates shall be made and maintained in a form suitable for inspection for at least five years. 4. A report of excess total reduced sulfur emissions, as defined below, will be submitted to the Department for each calendar quarter within the month following the end of the quarter. The reports will include the following information: Rule (28) a. The magnitude of excess emissions greater than 8 parts per million adjusted to 10 percent oxygen computed from twelve hour averages (data recorded during periods of total reduced sulfur emission monitoring system breakdowns, repairs, calibration checks and zero and span adjustments shall not be included in the data averages). b. The date and time of commencement and completion of each time period of excess emissions. c. The nature and cause of the excess emissions (if known) and the corrective action taken or preventative measures adopted.

55 Federally Enforceable Provisos d. The date and time identifying each period during which the total reduced sulfur emission monitoring system was inoperative (except for zero and span checks) and the nature of the system repairs or adjustments. e. When no excess emissions have occurred and the total reduced sulfur emission monitoring system was not inoperative or did not require repairs or adjustments, such information will be stated in the report. 5. A sulfur dioxide emission test report shall be submitted to the Department at least every five years. 6. A carbon monoxide emission test report shall be submitted to the Department at least every five years. 7. A nitrogen oxide emission test report shall be submitted to the Department at least every five years. 8. A record of the number of hours per rolling 12-month period of backup noncondensable gas incinerator operation (when the unit is incinerating non-condensable gases) shall be maintained in a form suitable for inspection for at least 5 years. 9. Pursuant to 40 CFR Part 63, Subpart MM the facility must submit an Excess Emissions Report containing the information required in (c), as well as the number and duration of occurrences when the 3-hour rolling average parameter value is outside the range established at the time of a required periodic test that showed compliance or a test approved by the Department that showed compliance. This report is required to be submitted quarterly if the unit has six (6) or more rolling 3-hour average values that are outside the range established at the time of a required periodic test that showed compliance or a test approved by the Department that showed compliance, within any quarterly period, otherwise this report is to be submitted semi-annually. 10. Records and supporting documentation shall be kept for the compliance determinations, operating ranges, and parameter ranges established for this unit. 11. In accordance with 40 CFR Part (b), the facility must maintain records of any occurrence when corrective action is required (when a 3-hour average flow rate or pressure drop value is outside the established range of values), and when a violation is noted (when six or more 3-hour average flow rate or pressure drop values within any 6-month reporting period are outside the established range of values). 12. In accordance with 40 CFR (c), the facility shall maintain the following records in addition to the general records required by 40 CFR 63.10(b)(2): a. Maintain records of parametric monitoring data required under 40 CFR , including any period when the 3-hour average flow rate or pressure drop values were inconsistent with the levels established during the initial performance test, with a brief explanation of the cause of the deviation, the time the deviation occurred, the time corrective action was initiated and completed, and corrective action taken. b. Maintain records and documentation of supporting calculations for compliance determination made under 40 CFR (a) through (d). c. Maintain the records of the monitoring parameter ranges for the scrubber flow rates and scrubber pressure drop. Rule (1) Rule (38) Rule (1) & (38) Rule (38) 11-4

56 Nos. 1-4 Digester Systems Informational Summary Description: No. 1-4 Digester Systems Emission Unit No: DG14 Installation Date: 1966 Reconstruction / Modification date: Operating Capacity: 58,480 lb air dried pulp/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z005 Nos. 1-4 Digester Systems TRS Incineration Rule (1)(b)(5) (State Only) Z005 Nos. 1-4 Digester Systems HAPS Incineration Rule (1) & (18) 12-1

57 Nos. 1-4 Digester Systems Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R , "Major Source Operating Permits". 2. Digesters 1-4 are subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Emission Monitoring 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Recordkeeping and Reporting Requirements 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Rule Rule (1) & (18) Rule (1) & (18) Rule (1) & (18) Rule (1) & (18) 12-2

58 State Only Enforceable Provisos Applicability (State Only) 1. Digesters 1 through 4 are subject to the requirements of ADEM Admin. Code (5) total reduced sulfur from kraft pulp mill digesters. Emission Standards (State Only) 1. For Digesters 1 through 4 all gases discharged that contain total reduced sulfur in excess of 5 parts per million shall be incinerated in either the No. 3 Lime Kiln or Standby Incinerator subjecting the gases to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 seconds. If an owner or operator demonstrates to the satisfaction of the Director that emissions in excess of the levels otherwise authorized in this regulation occur as a result of properly performed startups, shutdowns or unavoidable malfunctions these emissions will not constitute a violation. Compliance and Performance Test Methods and Procedures (State Only) 1. There are no compliance and performance test methods and procedures for this source. Emission Monitoring (State Only) 1. For total reduced sulfur periodic monitoring at least once per day mill personnel shall determine if the gases are being vented to the atmosphere and if gases are being vented to the atmosphere, investigate and take corrective action within twenty-four hours. Recordkeeping and Reporting Requirements (State Only) 1. At least once per day records of whether or not total reduced sulfur gases are being vented to the atmosphere shall be made and maintained on file available for inspection for a period of five years. Rule (5) Rule (5) 12-3

59 Nos Digester Systems Informational Summary Description: No Digester Systems Emission Unit No: DG50 Installation Date: 1977 (5); 1982 (6,7,8); 1986 (9,10) Reconstruction / Modification date: Operating Capacity: 87,720 lb air dried pulp/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z015 Nos Digester Systems TRS Incineration Rule (28) Z015 Nos Digester Systems HAPS Incineration Rule (1) & (18) 13-1

60 Nos Digester Systems Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of ADEM Admin. Code R , "Major Source Operating Permits". 2. Digesters 5-10 are subject to federal New Source Performance Standards Subpart BB. 3. Digesters 5-10 are subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. For Digesters 5-10 all gases discharged that contain total reduced sulfur in excess of 5 parts per million shall be incinerated in either the No. 3 Lime Kiln or Standby Incinerator subjecting the gases to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 seconds. 2. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. Emission Monitoring 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. 2. For total reduced sulfur periodic monitoring at least once per day mill personnel shall determine if the gases are being vented to the atmosphere and if gases are being vented to the atmosphere, investigate and take corrective action within twenty-four hours. Recordkeeping and Reporting Requirements 1. See Provisos for Pulping System Processes, Process Condensates, and Enclosures and Closed Vent Systems for additional requirements. 2. At least once per day records of whether or not total reduced sulfur gases are being vented to the atmosphere shall be made and maintained on file available for inspection for a period of five years. Rule Rule (28) Rule (1) & (18) Rule (28) Rule (1) & (18) Rule (1) & (18) Rule (1) & (18) 13-2

61 No. 1 Brownstock Washer System (Including 4 th stage) Informational Summary Description: No. 1 Brownstock Washer System (including 4 th stage) Emission Unit No: BW01 Installation Date: 1966 Reconstruction / Modification date: 1981 Operating Capacity: 73,100 lb air dried pulp/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Point Description Pollutant Emission Limit Standard Z014 No. 1 Brownstock Washer System TRS < tpy Rule (4th Stage Only) Z014 No. 1 Brownstock Washer System (Including 4th Stage) HAPs Approved CCA Plan Rule (1) & (18) 14-1

62 No. 1 Brownstock Washer System (Including 4 th stage) Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (28) New Source Performance Standards Subpart BB for Kraft pulp mills and ADEM Admin. Code for total reduced sulfur. 3. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. As required by 40 CFR (a)(1)(iv) this unit is exempt from the Standard for total reduced sulfur. However, total reduced sulfur emissions from the 4 th Stage only shall not exceed tons per year. 2. See Provisos for Pulping System Processes and Enclosures and Closed Vent Systems for additional requirements. 3. As required by the requirements of 40 CFR Part 63 Subpart S, emissions shall be controlled by an approved Clean Condensate Alternative. Compliance and Performance Test Methods and Procedures 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Emission Monitoring 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Recordkeeping and Reporting Requirements 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Rule Rule (1) & (28) Rule Rule (1) & (18) Rule (28) Rule Rule (1) & (18) Rule Rule (1) & (18) Rule (1) & (18) Rule (1) & (18) 14-2

63 No. 2 Brownstock Washer System Informational Summary Description: No. 2 Brownstock Washer System Emission Unit No: BW02 Installation Date: 1982 Reconstruction / Modification date: Operating Capacity: 73,100 lb air dried pulp/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 60 Subpart BB 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard Z016 No. 2 Brownstock Washer System TRS < 11 lb/hr Rule (9) Z016 No. 2 Brownstock Washer System HAPs Approved CCA Plan Rule (1) & (18) 15-1

64 No. 2 Brownstock Washer System Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to the applicable requirements of Rule (1) and (28) New Source Performance Standards Subpart BB for Kraft pulp mills and ADEM Admin. Code for total reduced sulfur. 3. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and Subpart S (See Provisos for Pulping System Processes and Enclosures and Closed Vent Systems for additional requirements). Emission Standards 1. Per 40 CFR (a)(1)(iv) this unit is exempt from the Standard for total reduced sulfur. However, total reduced sulfur emissions shall not exceed 11 pounds per hour. 2. See Provisos for Pulping System Processes and Enclosures and Closed Vent Systems for additional requirements. 3. Per the requirements of 40 CFR Part 63, Subpart S emissions shall be controlled by an approved Clean Condensate Alternative. Compliance and Performance Test Methods and Procedures 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Emission Monitoring 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Recordkeeping and Reporting Requirements 1. See Provisos for Enclosures and Closed Vent Systems for details. Also, as listed in the approved CCA Plan. Rule Rule (1) & (28) Rule Rule (1) & (18) Rule (28) Rule Rule (1) & (18) Rule Rule (1) & (18) Rule (1) & (18) Rule (1) & (18) 15-2

65 Pulping System Processes Informational Summary Description: Pulping System Processes Emission Unit No: PC01 Installation Date: Reconstruction / Modification date: Operating Capacity: Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard LV01 Pulping System Processes LVHC, Batch Digester Systems, Multiple Effect Evaporator System, Turpentine Recovery System and Condensate Collection System HAPs Equipment systems shall be enclosed and vented into a closed-vent system and routed to the ASB or into Rule (18) the LVHC NCG system Pulping System Processes HVLC, Brown Stock Washer System Approved CCA Plan for the control of HVLC emissions. 16-1

66 Pulping System Processes Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and 40 CFR Part 63, Subpart S. Emission Standards 1. For the pulping system processes, per the requirements of 40 CFR Part 63, Subpart S, Low Volume High Concentration Gases shall be controlled. 2. Pursuant to 40 CFR , this source shall adhere to an approved Clean Condensate Alternative control plan for the control of HVLC emissions. 3. Periods of excess emissions reported under 40 CFR shall not be a violation of 40 CFR (c) and (d) provided that the time of excess emissions divided by the total process operating time in a semi-annual reporting period does not exceed the following levels: a. One percent for control devices used to reduce the total HAP emissions from the LVHC system; and b. Four percent for control devices used to reduce the total HAP emissions from the HVLC system; and c. Four percent for control devices used to reduce the total HAP emissions from both the LVHC and HVLC systems. 4. Equipment systems listed in provisos 1 of this section shall be enclosed and vented into a closed-vent system and routed to a control device that meets the requirements specified in the following bullet. The enclosures and closed-vent system shall meet the requirements specified in the Enclosures and Closed-Vent Systems Emission Standards Proviso 1(b)-(d). 5. The control device used to reduce total HAP emissions from each equipment system listed in provisos 1 of this section shall: a. Reduce total HAP emissions by 98 percent or more by weight; or b. Reduce the total HAP concentration at the outlet of the thermal oxidizer to 20 parts per million or less by volume, corrected to 10 percent oxygen on a dry basis; or c. Reduce total HAP emissions using a thermal oxidizer designed and operated at a minimum temperature of 871 C (1600 F) and a minimum residence time of 0.75 seconds; or d. Reduce total HAP emissions using one of the following: i. A boiler, lime kiln, or recovery furnace by introducing the HAP emission stream with the primary fuel or into the flame zone; or ii. A boiler or recovery furnace with a heat input capacity greater than or equal to 44 megawatts (150 million British thermal units per hour) by introducing the HAP emission stream with the combustion air. Compliance and Performance Test Methods and Procedures 1. See Compliance and Performance Test Methods and Procedures provisos for Enclosures and Closed Vent Systems for details. Emission Monitoring 1. For the closed-vent system see the Emission Monitoring provisos for Enclosures and Closed-Vent Systems. Recordkeeping and Reporting Requirements Rule Rule (1) &.06(18) Rule Rule (18) Rule &.06(18) Rule CFR CFR CFR Rule (18) 16-2

67 Federally Enforceable Provisos 1. For the LVHC sources, per the requirements of 40 CFR Part 63 Subpart S, the permittee shall meet the Recordkeeping and Reporting Requirements section of the Enclosures and Closed-Vent Systems provisos. 2. For the pulping system processes and each applicable enclosure opening, closedvent system, and closed collection system, per the requirements of 40 CFR , the permittee shall meet the Recordkeeping and Reporting Requirements section of the Enclosures and Closed-Vent Systems provisos. Rule Rule

68 Process Condensates Informational Summary Description: Process Condensates Emission Unit No: PC01 Installation Date: Reconstruction / Modification date: Operating Capacity: 146,200 lb air dried pulp/hr Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard S446 Process Condensates HAPs Collect > 5.5 kg HAP/megagram Rule (18) (1) Each digester system; (2) Each turpentine recovery system; and (3) Each LVHC collection system. (11.1 lb/ton) of ODP S446 Process Condensates HAPs Remove > 5.1 kg HAP/megagram (10.2 lb/ton) of ODP Rule (18) 17-1

69 Process Condensates Provisos Federally Enforceable Provisos Applicability 1. This source is subject to the applicable requirements of Rule , "Major Source Operating Permits". 2. This source is subject to federal National Emission Standards for Hazardous Pollutants General Provisions as provided for in Table 1 of Subpart S and 40 CFR 63, Subpart S. Emission Standards 1. For Process Condensates, per the requirements of 40 CFR Part 63, Subpart S, pulping process condensates shall be collected and treated. 2. The combined pulping process condensates that in total contain a total HAP mass of 5.5 kilograms or more of total HAP per megagram (11.1 pounds per ton) of ODP shall be controlled as specified in Bullets 3 through 5 of this section. 3. The pulping process condensates from the equipment systems in this section shall be conveyed in a closed collection system that is designed and operated to meet the requirements specified in bullets (a) and (b) of this section. a. Each closed collection system shall meet the individual drain system requirements specified in 40 CFR , , and of subpart RR of this part, except for closed vent systems and control devices shall be designed and operated in accordance with 40 CFR (d) and , instead of in accordance with 40 CFR as specified in 40 CFR (a)(3)(ii), (b)(3)(ii)(a), and (b)(3)(ii)(b)(5)(iii); and b. If a condensate tank is used in the closed collection system, the tank shall meet the following requirements: (i) The fixed roof and all openings (e.g., access hatches, sampling ports, gauge wells) shall be designed and operated with no detectable leaks as indicated by an instrument reading of less than 500 parts per million above background, and vented into a closed-vent system that meets the requirements in and routed to a control device that meets the requirements in (d); and (ii) Each opening shall be maintained in a closed, sealed position (e.g., covered by a lid that is gasketed and latched) at all times that the tank contains pulping process condensates or any HAP removed from a pulping process condensate stream except when it is necessary to use the opening for sampling, removal, or for equipment inspection, maintenance, or repair. 4. Each HAP removed from a pulping process condensate stream during treatment and handling under this section shall be discharged below the liquid surface of a biological treatment system and treated to meet the requirements specified in paragraph (e)(3), (4), or (5) of 40 CFR and total HAP shall be measured as specified in 40 CFR (g). 5. At mills that perform bleaching, treat the pulping process condensates to remove 5.1 kilograms or more of total HAP per megagram (10.2 pounds per ton) of ODP, or achieve a total HAP concentration of 330 parts per million or less by weight at the outlet of the control device. Compliance and Performance Test Methods and Procedures 1. An initial performance test is required by one of the procedures to determine total HAP or methanol in liquid samples described in 40 CFR For the closed-vent system see the Compliance and Performance Test Methods and Procedures provisos for Enclosures and Closed-Vent Systems. Rule Rule (1) & (18) Rule Rule Rule Rule Rule CFR Rule (18) 17-2

70 Federally Enforceable Provisos Emission Monitoring 1. For the pulping process condensates from the equipment systems of this section per the requirements of 40 CFR , the permittee shall meet the requirements of 40 CFR A continuous monitoring system (CMS, as defined in 40 CFR Part 63, Subpart A General Provisions 63.2) shall be installed, calibrated, certified, operated, and maintained according to the manufacturer s specifications. The CMS shall include a continuous recorder. 3. A CMS shall be operated to measure the appropriate parameters determined according to the procedures specified in paragraph 5 of this section to comply with the condensate applicability requirements specified in 40 CFR (c). 4. Each owner or operator using an open biological treatment system to comply with 40 CFR (e)(2) shall perform the daily monitoring procedures specified in either paragraph 4(a) or (b) of this section and shall conduct a performance test each quarter using the procedures specified in paragraph 4(c) of this section. a. Comply with the monitoring and sampling requirements specified in paragraphs (a)(i) and (ii) of this section. i. On a daily basis, monitor the following parameters for each open biological treatment unit: A. Composite daily sample of outlet soluble BOD5 concentration to monitor for maximum daily and maximum monthly average; B. Mixed liquor volatile suspended solids; C. Horsepower of aerator unit(s); D. Inlet liquid flow; and ii. E. Liquid temperature. If the Inlet and Outlet Concentration Measurement Procedure (Procedure 3) in appendix C of 40 CFR Part 63 is used to determine the fraction of HAP compounds degraded in the biological treatment system as specified in 40 CFR (l), conduct the sampling and archival requirements specified in paragraphs 4(a)(ii)(A) and (B) of this section. A. Obtain daily inlet and outlet liquid grab samples from each biological treatment unit to have HAP data available to perform quarterly performance tests specified in paragraph 4(c) of this section and the compliance tests specified in paragraph 7 of this section. B. Store the samples as specified in 40 CFR (n) until after the results of the soluble BOD5 test required in paragraph 4(a)(i)(A) of this section are obtained. The storage requirement is needed since the soluble BOD5 test requires 5 days or more to obtain results. If the results of the soluble BOD5 test are outside of the range established during the initial performance test, then the archive sample shall be used to perform the mass removal or percent reduction determinations. b. As an alternative to the monitoring requirements of paragraph 4(a) of this section, conduct daily monitoring of the site-specific parameters established according to the procedures specified in paragraph 5 of this section. c. Conduct a performance test as specified in 40 CFR (l) within 45 days after the beginning of each quarter and meet the applicable emission limit in 40 CFR (e)(2). 5. To establish or reestablish, the value for each operating parameter required to be monitored by this section or to establish appropriate parameters for paragraph 4(b) of this section, each owner or operator shall use the following procedures: a. During the initial performance test required in 40 CFR (a) or any subsequent performance test, continuously record the operating parameter; Rule Rule Rule Rule Rule

71 Federally Enforceable Provisos b. Determinations shall be based on the control performance and parameter data monitored during the performance test, supplemented if necessary by engineering assessments and the manufacturer s recommendations; c. The owner or operator shall provide for the Administrator s approval the rationale for selecting the monitoring parameters necessary to comply with paragraph 3 of this section; and d. Provide for the Administrator s approval the rationale for the selected operating parameter value, and monitoring frequency, and averaging time. Include all data and calculations used to develop the value and a description of why the value, monitoring frequency, and averaging time demonstrate continuous compliance with the applicable emission standard. 6. Each owner or operator of a control device subject to the monitoring provisions of this section shall operate the control device in a manner consistent with the minimum or maximum (as appropriate) operating parameter value or procedure required to be monitored under paragraphs 1 through 5 of this section and established under this subpart. Except as provided in paragraph 7 of this section, 40 CFR (e), or (g), operation of the control device below minimum operating parameter values or above maximum operating parameter values established under this subpart or failure to perform procedures required by this subpart shall constitute a violation of the applicable emission standard of this subpart and be reported as a period of excess emissions. 7. The procedures of this paragraph apply to each owner or operator of an open biological treatment system complying with paragraph 4 of this section whenever a monitoring parameter excursion occurs, and the owner or operator chooses to conduct a performance test to demonstrate compliance with the applicable emission limit. A monitoring parameter excursion occurs whenever the monitoring parameters specified in paragraphs (a)(i)(a) through (C) of this section or any of the monitoring parameters specified in paragraph (b) of this section are below minimum operating parameter values or above maximum operating parameter values established in paragraph 5 of this section. a. As soon as practical after the beginning of the monitoring parameter excursion, the following requirements shall be met: i. Before the steps in paragraph 7(a)(ii) or (iii) of this section are performed, all sampling and measurements necessary to meet the requirements in paragraph 7(b) of this section shall be conducted. ii. Steps shall be taken to repair or adjust the operation of the process to iii. end the parameter excursion period. Steps shall be taken to minimize total HAP emissions to the atmosphere during the parameter excursion period. b. A parameter excursion is not a violation of the applicable emission standard if the results of the performance test conducted using the procedures in this paragraph demonstrate compliance with the applicable emission limit in 40 CFR (e)(2). i. Conduct a performance test as specified in 40 CFR using the monitoring data specified in paragraph 4(a) or (b) of this section that coincides with the time of the parameter excursion. No maintenance or changes shall be made to the open biological treatment system after the beginning of a parameter excursion that would influence the results of the performance test. ii. iii. If the results of the performance test specified in paragraph 7(b)(i) of this section demonstrate compliance with the applicable emission limit in 40 CFR (e)(2), then the parameter excursion is not a violation of the applicable emission limit. If the results of the performance test specified in paragraph 7(b)(i) of this section do not demonstrate compliance with the applicable Rule Rule

72 Federally Enforceable Provisos iv. emission limit in 40 CFR (e)(2) because the total HAP mass entering the open biological treatment system is below the level needed to demonstrate compliance with the applicable emission limit in 40 CFR (e)(2), then the owner or operator shall perform the following comparisons: A. If the value of fbio (MeOH) determined during the performance test specified in paragraph 7(b)(i) of this section is within the range of values established during the initial and subsequent performance tests approved by the Administrator, then the parameter excursion is not a violation of the applicable standard. B. If the value of fbio (MeOH) determined during the performance test specified in paragraph 7(2)(i) of this section is not within the range of values established during the initial and subsequent performance tests approved by the Administrator, then the parameter excursion is a violation of the applicable standard. The results of the performance test specified in paragraph 7(b)(i) of this section shall be recorded as specified in 40 CFR (f). c. If an owner or operator determines that performing the required procedures under paragraph 7(b) of this section for a non-thoroughly mixed open biological system would expose a worker to dangerous, hazardous, or otherwise unsafe conditions, all of the following procedures shall be performed: i. Calculate the mass removal or percent reduction value using the procedures specified in 40 CFR (l) except the value for fbio (MeOH) shall be determined using the procedures in appendix E to this part. ii. iii. iv. Repeat the procedures in paragraph 7(c)(i) of this section for every day until the unsafe conditions have passed. A parameter excursion is a violation of the standard if the percent reduction or mass removal determined in paragraph 7(c)(i) of this section is less than the percent reduction or mass removal standards specified in 40 CFR (e)(2), as appropriate, unless the value of fbio (MeOH) determined using the procedures in appendix E of this section, as specified in paragraph 7(c)(i), is within the range of fbio (MeOH) values established during the initial and subsequent performance tests previously approved by the Administrator. The determination that there is a condition that exposes a worker to dangerous, hazardous, or otherwise unsafe conditions shall be documented according to requirements in 40 CFR (e) and reporting in 40 CFR (f). v. The requirements of paragraphs 7(a) and (b) of this section shall be performed and met as soon as practical but no later than 24 hours after the conditions have passed that exposed a worker to dangerous, hazardous, or otherwise unsafe conditions. Recordkeeping and Reporting Requirements 1. For the pulping process condensates from the equipment systems of this section per the requirements of 40 CFR , the permittee shall meet the Recordkeeping and Reporting Requirements section of the Enclosures and Closed-Vent Systems provisos. 2. For each applicable enclosure opening, closed-vent system, and closed collection system, the owner or operator shall meet the Recordkeeping and Reporting Requirements section of the Enclosures and Closed-Vent Systems provisos. Rule Rule

73 Federally Enforceable Provisos 3. The owner or operator shall record and report the CMS parameters specified in 40 CFR and meet the requirements specified in the Recordkeeping and Reporting Requirements section of the Enclosures and Closed-Vent Systems Proviso Number 1 for any new affected process equipment or pulping process condensate stream that becomes subject to the standards in this subpart due to a process change or modification. 4. The owner or operator of an open non-thoroughly mixed biological treatment system complying with 40 CFR (p)(3) instead of 40 CFR (p)(2) shall prepare a written record identifying the specific conditions that would expose a worker to dangerous, hazardous, or otherwise unsafe conditions. The record must include a written explanation of the specific reason(s) why a worker would not be able to perform the sampling and test procedures specified in 40 CFR (l). 5. The owner or operator of an open biological treatment system complying with 40 CFR (p) shall prepare a written record specifying the results of the performance test specified in 40 CFR (p)(2). 6. If the owner or operator uses the results of the performance test required in 40 CFR (p)(2) to revise the approved values or ranges of the monitoring parameters specified in 40 CFR (j)(1) or (2), the owner or operator shall submit an initial notification of the subsequent performance test to the Administrator as soon as practicable, but no later than 15 days, before the performance test required in 40 CFR (p)(2) is scheduled to be conducted. The owner or operator shall notify the Administrator as soon as practicable, but no later than 24 hours, before the performance test is scheduled to be conducted to confirm the exact date and time of the performance test. 7. To comply with the open biological treatment system monitoring provisions of 40 CFR (p)(3), the owner or operator shall notify the Administrator as soon as practicable of the onset of the dangerous, hazardous, or otherwise unsafe conditions that did not allow a compliance determination to be conducted using the sampling and test procedures in 40 CFR (l). The notification shall occur no later than 24 hours after the onset of the dangerous, hazardous, or otherwise unsafe conditions and shall include the specific reason(s) that the sampling and test procedures in 40 CFR (l) could not be performed Rule Rule Rule Rule Rule

74 Enclosures and Closed-Vent Systems Informational Summary Description: Enclosures and Closed-Vent Systems Emission Unit No: Installation Date: Reconstruction / Modification date: Operating Capacity: Operating Schedule: 8760 hours/year This unit contains equipment that is subject to the following NSPSs, NESHAPs, or MACTs: 40 CFR Part 63 Subpart S Pollutants Emitted: Emission Point Description Pollutant Emission Limit Standard S450 Enclosures and Closed-Vent Systems (1) Pulping System and (2) Bleaching System HAPs Each component of the closed-vent system used to comply with Secs (c), (b), and (b) that is operated at positive pressure and located prior to a control device shall be designed for and operated with no detectable leaks as indicated by an instrument reading of less than 500 parts per million by volume above background, as measured by the procedures specified in Sec (d) Rule (18) 18-1