Facility Name: Georgia-Pacific Consumer Products LP Savannah River Mill City: Rincon County: Effingham AIRS #: 04-13-103-00007 Application #: 40890 Date SIP Application Received: March 7, 2016 Date Title V Application Received: March 7, 2016 Permit No: 2621-103-0007-V-04-5 Program Review Engineers Review Managers SSPP Cassie Smith Dave Matos SSCP N/A N/A ISMU N/A N/A TOXICS N/A N/A Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and operate and Section 502(b)(10) change to the Part 70 source. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections 391-3-1-.03(1), 391-3-1-.03(2), and 391-3-1-.03(10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of 1990. The following narrative is designed to accompany the permit and is presented in the same general order as the permit amendment. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Georgia-Pacific Consumer Products LP Savannah River Mill, TV-40890 Page 1 of 5
I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, all administrative amendments and minor and significant modifications to that permit, and any 502(b)(10) changes. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Comments Permit/Amendment Number Date of Issuance Yes No 2621-103-0007-V-04-0 September 25, 2012 2621-103-0007-V-04-1 August 14, 2013 2621-103-0007-V-04-2 June 27, 2014 2621-103-0007-V-04-3 January 21, 2015 2621-103-0007-V-04-4 July 6, 2015 2621-103-0007-V-04-5 April 20, 2016 Table 2: Comments on Specific Permits Permit Number 2621-103-0007-V-04-1 2621-103-0007-V-04-2 2621-103-0007-V-04-3 2621-103-0007-V-04-4 2621-103-0007-V-04-5 B. Regulatory 1. PSD/NSR/RACT Comments Installation of stationary reciprocating internal combustion engines. Administrative amendment for address change. Installation of a new converting line. Venting of trim removal system to atmosphere. Inclusion of normal operating ranges for pressure drop and scrubbant flow rate of two new scrubbers (SB09 and SB10). The Savannah River Mill is considered a major source under PSD. The facility has accepted the following PSD Limits: a. Emissions of SO 2 from Boiler No. 3 are limited to 491.4 pounds per hour. b. Emissions of NO X from Boiler Nos. 3, 4, and 5 are limited to 0.4 pounds per MMBtu heat input. c. Emissions of SO 2 from Boiler Nos. 4 and 5 are limited to 381.5 pounds per hour each. d. Emissions of NO X from each combined Combustion Turbine / Waste Heat Boiler stack are limited to 105.0 pounds per hour. e. The sulfur content of the no. 2 fuel oil burned at the mill is limited to 0.05 percent, by weight, or less. f. The mill may burn only natural gas in the Paper Machine dryer burners. g. Emissions of VOC from the Paper Machines combined are limited to less than 206.3 tons per year. h. Emissions of VOC from Paper Machine No. 20 are limited to 0.0067 pound per MMBtu heat input. i. The mill was required to install low NO X burners in the dryer hoods for Paper Machine No. 17. j. Emissions from Paper Machine No. 17 are limited to 0.005 pounds per MMBtu heat input of PM/PM 10, 0.0007 pounds per MMBtu heat input of SO 2, 0.036 pounds per MMBtu heat input of NO X, 0.184 pounds per MMBtu heat input of CO, and 0.006 pounds per MMBtu heat input of VOC. k. Emissions of PM/PM 10 from Paper Machine Nos. 16 through 19 are limited to less than 17.9 tpy, 16.8 tpy, 10.7 Georgia-Pacific Consumer Products LP Savannah River Mill, TV-40890 Page 2 of 5
tpy, and 5.6 tpy, respectively. l. Emissions of VOC from the combined Pulp Processing Area and Bleaching Systems are limited to less than 201.3 tpy. m. The mill must comply with a good operating practices plan for the Sodium Bisulfite Tank. The facility has accepted the following limits to avoid PSD: a. The mill must limit the sulfur content of fuel oil burned at the site to 0.05 percent, by weight. b. The mill must limit the size of Compressor Engines operated under Source Code CE01 to less than 750 hp. c. The mill must limit the operation of engines under Source Code CE01 to 12,000,000 hp-hours combined 2. Title V Major Source by Table 3: Title V Major Source Is the Emitted? Major Source PM PM 10 SO 2 VOC NO x CO TRS H 2 S Individual Total HAPs If emitted, what is the facility s Title V status for the? Major Source Requesting SM Non-Major Source II. Proposed Modification A. Description of Modification Application No. 40890 was submitted for the purpose of installing a new dust collection system and wet venturi scrubber on the winder section of Paper Machine 19 (PM04). The dust collection system will consist of an exhaust stack, wet scrubber (SB11), venturi section, fan, motor and hoods, and associated electrical, control, and monitoring equipment. This system will vent outside to the atmosphere and is being installed primarily to enhance worker comfort/health and safety. This project is expected to begin in July 2016, with final the installation expected in September. The wet venturi scrubber is a control device with controlled PM emissions of 3.1 tpy. Based on engineering estimates and design removal efficiency, uncontrolled emission from the paper machine would be more than 100 tpy. Therefore the scrubber is needed to meet the equipment SIP Rule PM allowable emission limit. Since this control device is for an other pollutant-specific emission unit (less than 100% of the major source threshold after control device), the facility will submit a compliance assurance monitoring plan for the new scrubber (SB11) with the next Title V renewal application per 40 CFR 64.5(b), adopted by reference in 391-3-1-.02(11). Georgia-Pacific Consumer Products LP Savannah River Mill, TV-40890 Page 3 of 5
B. Emissions Change The Paper Machine 19 dust collection system will not increase production capability beyond the currently permitted potential rate of 307 air dried tons finished paper per day (ADTFP/day). However, a new dust collection system may increase production on an annual basis by up to 1,243 MDT/yr. This is due to reducing machine downtime to clean dust. The facility assessed PSD applicability by comparing past actual emissions for the April 2012-March 2013 time period to the projected future actual emissions from Paper Machine 19. Projected actual emissions from the paper machine are based on a future actual production rate of 98,550 MDT/yr (104,463 ADT/yr). The PM emissions for the paper machines are calculated using an interim emission factor (1.0 pound/paper machine ton). After having undertaken an extensive paper machine emissions testing program, the facility is currently reviewing test data from these machines. Preliminary results indicate that the total combined roof vent/stack emissions from Paper Machine 19 might be more than the current estimate of 1.0 lb/paper machine ton. Therefore, they utilized a conservative estimate of 1.75 lb/paper machine ton emission factor based on a worst case scenario to calculate potential emissions for this project. A wet venturi scrubber will also be installed. PM emissions from the new scrubber (SB11) were calculated using a 1.0 lb/hr emission factor. This emission factor is based on the scrubber manufacturer vendor guarantee. PM test results on similar scrubbers and paper machines were also used to confirm the reasonableness of the emission factor and determine the PM 10 /PM 2.5 speciation. Potential emissions from the scrubber were calculated based on the vendor guarantee of 8,760 hours of operation. Since the new dust collection system may increase production, other potentially-affected sources (boilers, pulp mill, and converting line) were also included in the emissions calculations that would attribute to increases in NO X, SO 2, VOC, and PM. The table below summarizes the total emissions increases with respect to the PSD significant emission rates (SER). These emissions do not exceed PSD thresholds. Detailed emissions calculations are included in the application. Table 4: Emissions Change Due to Modification C. Title I Modification Emission Increase (tpy) PSD Threshold (tpy) Percent of Threshold (%) PM 12.2 25 49% PM 10 10.7 15 71% PM 2.5 9.1 10 91% PSD/NSR Applicability SO 2 4.6 40 12% SAM 3.36E-02 7 <1% NO x 1.5 40 4% CO 1.3 100 1% VOC 3.7 40 9% Pb 3.71E-05 0.6 <1% CO 2 e 1,990.7 75,000 3% The modification is not subject to PSD or NSR Georgia-Pacific Consumer Products LP Savannah River Mill, TV-40890 Page 4 of 5
III. Facility Wide Requirements IV. Regulated Equipment Requirements The new scrubber will be subject to general state emission requirements for particulate matter per 391-3-1-.02(2)(11)(b) and (e). V. Testing Requirements (with Associated Record Keeping and Reporting) VI. Monitoring Requirements (with Associated Record Keeping and Reporting) Condition 5.2.19 was added to require the facility to monitor the pressure drop and scrubbant flow rate for the new scrubber (Source Code SB11) and to record the data once per operating shift, in accordance with 40 CFR Part 52.21 and Georgia Rules 391-3-1-.02(2)(b) and 391-3-1-.02(2)(e). VII. Other Record Keeping and Reporting Requirements Condition 6.1.9 was added to require the facility to report excursions for the new scrubber (Source Code SB11) in accordance with new Condition 6.2.25. Condition 6.2.25 was added to allow the facility 90 days to establish normal operating ranges for the new scrubber (Source Code SB11). VIII. Specific Requirements Georgia-Pacific Consumer Products LP Savannah River Mill, TV-40890 Page 5 of 5