Facility Name: Packaging Corporation of America City: Clyattville County: Lowndes County AIRS #: 04-13-185-00001 Application #: 22133 Date SIP Application Received: September 16, 2013 Date Title V Application Received: Not Applicable Permit No: 2631-185-0001-V-02-7 Program Review Engineers Review Managers SSPP Tyneshia Tate David Matos SSCP Fred Francis Farhana Yasmin ISMP Anna Gray Daniel McCain TOXICS Dohyong Kim Michael Odom 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. Packaging Corporation of America, TV-22133 Page 1 of 21
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 Permit/Amendment Number Date of Issuance Yes 2631-1850001-V-02-0 October 1, 2009 X 2631-1850001-V-02-1 December 29, 2009 X 2631-1850001-V-02-2 March 16, 2010 X 2631-1850001-V-02-3 January 31, 2012 X 2631-1850001-V-02-5 June 13, 2013 X 2631-1850001-V-02-6 March 4, 2014 X 2631-1850001-V-02-8 October 22, 2015 X Table 2: Comments on Specific Permits Comments Permit Number Comments 2631-1850001-V-02-0 Title V Renewal 2631-1850001-V-02-1 Administrative Amendment to update Table 3.1 and the process description in Permit Condition 3.5.3. 2631-1850001-V-02-2 Administrative Amendment to include ASTM 4294 and ASTM D- 1552 as acceptable test methods for sulfur analyses in fuel oil. 2631-1850001-V-02-3 Administrative Amendment to correct a typographical error in Permit Condition 3.4.26 2631-1850001-V-02-5 Minor Modification with construction to modify the paper machine system and update 40 CFR 63 Subpart S permit conditions. 2631-1850001-V-02-6 Significant Modification with construction to convert the currently decommissioned No. 3. Recovery Furnace (Emission Unit 7020) to natural gas-fired Power Boiler No. 3 (Emission Unit 7020A). In addition, to decommission C.E. Power Boiler (Emission Unit 1017), and remove permanently shutdown equipment from the permit. 2631-1850001-V-02-8 Minor Modification without construction to revise Permit Condition 2.1.1 to increase its annual paper production limit to 595,400 oven dried tons per year on a 12-month rolling total basis. No Packaging Corporation of America, TV-22133 Page 2 of 21
B. Regulatory Status 1. PSD/NSR/RACT Packaging Corporation of America (PCA), Clyattville is classified as a major source under 40 CFR 52.21, Prevention of Significant Deterioration (PSD). The facility is located in an attainment area for all criteria pollutants. Per the narrative associated with Permit Number 2631-185-0001-V-02-0 PCA has taken some limits to avoid PSD on certain modifications. They are as follows: Sulfur dioxide emissions from the incineration of Total Reduced Sulfur (TRS) compounds in the NCG Thermal Oxidizer from the LVHC non-condensable gas system, HVLC non-condensable gas system and the foul condensate stripper off gases are limited to 40 tons per 12 consecutive month period. No. 4 Lime Kiln (Source Code 6063) 131.2 tons/12 consecutive months of total particulate matter. 119.4 tons/12 consecutive months of PM10. 116.7 tons/12 consecutive months of sulfur dioxide. 281.3 tons/12 consecutive months of nitrogen oxides. 117.4 tons/12 consecutive months of carbon monoxide. 81.30 tons/12 consecutive months of volatile organic compounds. Recovery Furnace No. 1 (Source Code 7000): Particulate matter emissions are limited to 68.87 tons/12 consecutive months TRS emissions are limited to 13.75 tons/12 consecutive months Black Liquor Firing Rate is limited to 153,966 tons of black liquor solids per 12 consecutive months Recovery Furnace No. 3 (Source Code 7020): Particulate matter emissions are limited to 25.6 lb/hour Package Boiler (Source Code 1058) Hours of operation is limited to 2,160 hours per year No. 3 Smelt Tank (Source Code 7025) Particulate matter emissions are limited to 13.7 lb/hour Packaging Corporation of America, TV-22133 Page 3 of 21
2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status Is the Pollutant Emitted? If emitted, what is the facility s Title V status for the Pollutant? Major Source Status Pollutant PM Y PM 10 Y PM 2.5 Y SO 2 Y VOC Y NO x Y CO Y TRS Y H 2 S Y Individual Y Total HAPs Y Total GHGs Y Major Source Requesting SM Status Non-Major Source Status II. Proposed Modification A. Description of Modification PCA proposes to add applicability of 40 CFR 63, Subpart DDDDD to the combination boilers which will result in applicable equipment changes described later in this document to comply with the regulation. B. Emissions Change Emissions increases are as provided in Table B-4 of Application Number 22133. For detailed emission factors and estimates, see Appendix B of Application 22133. Table 4: Emissions Change Due to Modification Pollutant Is the Pollutant Emitted? Net Actual Emissions Increase (Decrease) (tpy) 1 Net Potential Emissions Increase (Decrease) (tpy) PM Y +17.9 - PM 10 Y +13.3 - PM 2.5 Y +7.1 - SO 2 Y 0.0 - VOC Y 0.0 - Packaging Corporation of America, TV-22133 Page 4 of 21
Table 4: Emissions Change Due to Modification Pollutant Is the Pollutant Emitted? Net Actual Emissions Increase (Decrease) (tpy) 1 Net Potential Emissions Increase (Decrease) (tpy) NO x Y +14 - CO Y 0.0 - TRS N - - H 2 S N - - Individual HAP 2 Y - - Total HAPs Y - - Total GHGs 3 Y 0.0-1 Projected Future Actual emissions are presented in Appendix B of Application Number 22133. 2 HAP emissions were not provided in Application 22133. 3 In terms of carbon dioxide equivalence (CO 2 e). C. Title I Modification PSD/NSR Applicability According to Application Number 22133, PSD applicability determination was based on the total project-related emissions increases from the modified Combination Boilers. The following table is the summary of baseline emissions for some of the PSD regulated pollutants emitted from the Combination Boilers as included in Table B-1 of Appendix B to Application Number 22133. Source Riley Combination Boiler C.E. Combination Boiler Total Baseline Emissions Baseline Period Pollutant PM PM 10 PM 2.5 SO 2 NO x VOC CO GHG 1 124.5 111.7 72.1 11.2 365.4 45.3 1,465.8 283,593 67.6 66.2 42.8 5.1 26.9 26.9 869.5 168,112 192 178 115 16 587 72 2,334 451,705 2011 2008 2008 2008 2008 2008 2008 2008 2012 2009 2009 2009 2009 2009 2009 2009 1 In terms of carbon dioxide equivalence (CO 2 e). Packaging Corporation of America, TV-22133 Page 5 of 21
Per 40 CFR 52.21(r)(6), and Georgia Rule 391-3-1-.02(7) Prevention of Significant Deterioration of Air Quality[391-3-1-.02(7)(b)(15)], sources are obligated to track actual emission in the future for comparison against projected actual emissions. According to Application Number 22133, PM, PM 10, and PM 2.5 actual to future actual emissions estimates are 50% or more of the applicable significance levels and meet the reasonable possibility criteria. However, these estimates do not include any change to the PM limit or current PM controls. The estimates reflect an emission increase as a result of a conservative projection approach. Under this regulation, GHG emissions resulting from the proposed modification will only be reviewed. In accordance with page three of the US EPA PSD and Title V Permitting Guidance for Greenhouse Gases (March 2011) 1, under EPA s interpretation of the Clean Air Act and applicable rules, construction permits issued under the PSD program on or after January 2, 2011, must contain conditions addressing GHG emissions. The proposed modification to the existing Combination Boilers will take place after January 2011. Therefore, the Division will treat the proposed changes as a modification to existing sources and follow the determination of PSD applicability to GHGs emissions in accordance with the US EPA PSD and Title V Permitting Guidance for Greenhouse Gases (March 2011) Appendix D. GHG Applicability Flow Chart Modified Sources (On or after July 1, 2011) which is located on pages D-1 through D-4 of this document. According to Appendix D, GHG emissions increases from modified sources less than 75,000 tons per year on a CO 2 e basis do not have to undergo PSD review for GHG emissions if the sources are not subject to PSD for a regulated NSR pollutant other than GHGs. According to Application Number 22133, GHG emission increases are less than 75,000 tons per year on a CO 2 e basis. For emissions increases, see Table B-4 of Appendix B to Application Number 22133. Potential emissions of all NSR pollutants other than GHGs resulting from the proposed changes to the Combination Boilers are below the applicable significance levels for PSD review. Therefore, PSD review is not applicable to the GHG emissions from the proposed modification. Therefore, PSD is not applicable to this modification. NSPS Modification The proposed changes do not qualify as a modification under 40 CFR 60 as discussed below. NESHAP Modification The facility is not subject to any rules under 40 CFR 61. The proposed changes do not qualify as a modification under 40 CFR 63 as discussed below. 1 http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf Packaging Corporation of America, TV-22133 Page 6 of 21
III. Facility Wide Requirements A. Emission and Operating Caps There are no new facility-wide emission and operating caps associated with this modification. B. Applicable Rules and Regulations There are no new facility-wide applicable rules and regulations associated with this modification. C. Compliance Status No noncompliance issues were indicated in Application 22133. D. Operational Flexibility No request for facility-wide operational flexibility is associated with this modification. E. Permit Conditions No facility-wide permit conditions were added as a result of this modification. IV. Regulated Equipment Requirements A. Brief Process Description Packaging Corporation of America (PCA) is proposing to make improvements to the Mill s two (2) Combination Boilers (Riley and C.E., Source Codes 1005 and 1006, respectively) to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (Boiler MACT; 40 CFR Part 63, Subpart DDDDD). Provisions of 40 CFR 63, Subpart DDDDD that are applicable to the Combination Boilers are included in this permit. These will become effective on the respective compliance date in 40 CFR 63.7495, January 31, 2016. These two industrial boilers are in the 40 CFR 63 Subpart DDDDD hybrid suspension/grate subcategory for existing units, with US EPA concurrence on this determination on June 5, 2013. In addition to new regulatory requirements, proposed permit modifications to the Combination Boilers for Boiler MACT compliance purposes include changing the burners to provide sufficient capacity during startup and shutdown to meet the clean fuels provision of the Boiler MACT Rule and the addition of tire derived fuel (TDF) as an alternative fuel source, at less than 10% of the heat input on an annual basis, for the Combination Boilers. B. Equipment List for the New or Modified Process(es) The two (2) Combination Boilers (Riley and C.E., Source Codes 1005 and 1006, respectively) are as listed in the permit currently. Packaging Corporation of America, TV-22133 Page 7 of 21
C. Equipment & Rule Applicability Emission and Operating Caps No emission caps were removed or modified as a result of this permit modification. The capability to fire TDF in the boilers in quantities as discussed above was added. Applicable Rules and Regulations - 40 CFR 60, Subpart D This regulation is applicable to each fossil-fuel-fired steam generating unit of more than 73 megawatts (MW) heat input rate (250 million British thermal units per hour that commenced construction or modification after August 17, 1971. [40 CFR 60.40] The C.E. Combination Boiler has a heat input capacity of 243 x 10 6 Btu/hr and was constructed prior to August 17, 1971. Therefore this boiler is not subject to 40 CFR 60, Subpart D. The Riley Combination Boiler has a heat input capacity of 360 x 10 6 Btu/hr and was constructed prior to August 17, 1971. Although the heat input of the Riley Combination Boiler is within the regulated capacity, the construction date of the boiler is prior to the applicability of 40 CFR 60, Subpart D. Furthermore, the Riley Combination Boiler has never been modified or reconstructed, according to Application Number 22133. However, the Riley Combination Boiler is potentially subject to this regulation if it is determined to be a modified or reconstructed source under this regulation. Per 40 CFR 60.40b(j), any affected facility meeting the applicability requirements under 40 CFR 60.40b(a) and commencing construction, modification, or reconstruction after June 19, 1986 is not subject to 40 CFR 60, Subpart D. Since the Riley Combination Boiler is potentially subject to 40 CFR 60, Subpart Db as discussed below, this regulation does not apply. 40 CFR Subpart Da The regulation is applicable to each electric utility steam generating unit that is capable of combusting more than 73 megawatts (Mw) (250 million British thermal units per hour) heat input of fossil fuel (either alone or in combination with any other fuel), was constructed, modified, or reconstructed after September 18, 1978 [40 CFR 60.40Da (a)]. Per 40 CFR 60.41Da, an electric utility steam-generating unit means any steam electric generating unit that is constructed for the purpose of supplying more than one-third of its potential electric output capacity and more than 25 MW net-electrical output to any utility power distribution system for sale. Also, any steam supplied to a steam distribution system for the purpose of providing steam to a steam-electric generator that would produce electrical energy for sale is considered in determining the electrical energy output capacity of the affected facility. The C.E. Combination Boiler has a heat input capacity of 243 x 10 6 Btu/hr and was constructed prior to September 18, 1978. The Riley Combination Boiler has a heat input capacity of 360 x 10 6 Btu/hr and was constructed prior to September 18, 1978. Furthermore, PCA operates under a federal enforceable permit condition limiting the electric output to a utility power distribution system for sale to no more than 219,000 megawatt hours (MWh) during any consecutive 12-month period. Therefore this regulation does not apply. Packaging Corporation of America, TV-22133 Page 8 of 21
40 CFR 60, Subpart Db This regulation applies to each steam generating unit that commences construction, modification, or reconstruction after June 19, 1984, and that has a heat input capacity from fuels combusted in the steam generating unit of greater than 29 megawatts (Mw) (100 million British thermal units per hour (10 6 Btu/hr)) [40 CFR 60.40b(a)]. Any affected facility that meets the applicability requirements and is subject to 40 CFR Part 60 Subpart Ea, 40 CFR 60 Subpart Eb, or 40 CFR 60 Subpart AAAA if it is not covered by this subpart [40 CFR 60.40b(h)]. The original Combination Boilers, each with heat inputs greater than 100 x 10 6 Btu/hr, were constructed prior to August 17, 1971, predating the regulation. However, the Combination Boilers are potentially subject to this regulation if they are determined to be modified or reconstructed sources under this regulation. Per 40 CFR 60.14, a modification is any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act. Upon modification, an existing facility shall become an affected facility for each pollutant to which a standard applies and for which there is an increase in the emission rate to the atmosphere. This regulation establishes emission standards for sulfur dioxide (SO 2 ), PM, and NO x emissions from applicable sources. According to emission estimates provided in Tables B-12 and B-13 of in Appendix B of Application Number 22133, the proposed changes to the Combination Boilers will not result in an increase in the short-term emissions of the 40 CFR 60, Subpart Db regulated pollutants. Therefore, the change to the Combination Boilers does not meet the definition of a modification under this regulation. Per 40 CFR 60.15, reconstruction occurs when the components of an existing facility are replaced to such an extent that: (1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, and (2) It is technologically and economically feasible to meet the applicable standards set forth in this part. This evaluation did not include in the cost of reconstruction for the affected facility equipment that is part of the affected facility, but not part of the manufacturing or operation process. According to page 4-5 of Application Number 22133, a review of the fixed capital costs associated with the proposed changes to the Combination Boilers indicated that the proposed project does not meet the definition of reconstruction under this regulation. Therefore, this regulation does not apply. 40 CFR 60, Subpart Dc This regulation applies to each steam generating unit for which construction, modification, or reconstruction is commenced after June 9, 1989 and that has a maximum design heat input capacity of 29 megawatts (MW) (100 million British Thermal Units per hour) or less, but greater than or equal to 2.9 MW (10 million British Thermal Units per hour) [40 CFR 60.40c(a)]. The Combination Boilers each have a rated heat input capacity of greater than 100 x 10 6 Btu/hr, and therefore are not subject to this regulation. 40 CFR 63, Subpart DDDDD This regulation is applicable to new, reconstructed, or existing industrial, commercial, and institutional boilers and process heaters located at major sources of HAP [40 CFR 63.7480 and 40 CFR63.7490(a)]. The regulation is applicable to Combination Boilers and Power Boiler No. 3 at the facility. The specific requirements for the Power Boiler No. 3 were addressed in a separate permit modification. Packaging Corporation of America, TV-22133 Page 9 of 21
A boiler or process heater is to be new if it commenced construction after June 4, 2010 [40 CFR 63.7490(b)]. A boiler is considered to be reconstructed if the reconstruction criteria as defined in 40 CFR 63.2 are met, reconstruction commenced after June 4, 2010 [40 CFR 63.7490(c)]. (d) A boiler is existing if it is not new or reconstructed [40 CFR 63.7490(d)]. Per 40 CFR 63.2, reconstruction, unless otherwise defined in a relevant standard, means the replacement of components of an affected or a previously nonaffected source to such an extent that: (1) The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new source; and (2) It is technologically and economically feasible for the reconstructed source to meet the relevant standard(s) established by the Administrator (or a State) pursuant to section 112 of the Act. Upon reconstruction, an affected source, or a stationary source that becomes an affected source, is subject to relevant standards for new sources, including compliance dates, irrespective of any change in emissions of hazardous air pollutants from that source. According to pages 4-7 of Application Number 22133, a review of the fixed capital costs associated with the proposed changes to the Combination Boilers indicated that the proposed project does not meet the definition of reconstruction under this regulation. Therefore, the Combination boilers will be considered as existing units under 40 CFR 63, Subpart DDDDD. Existing boilers must comply with this regulation no later than January 31, 2016, except as provided in 40 CFR 63.6(i) [40 CFR 63.7495(b)]. The Combination Boilers, which are both designed for burning wet biomass fuel, meet criteria for two subcategories under 40 CFR 63, Subpart DDDDD. Per 40 CFR 63.7575, a stoker/sloped grate/other unit designed to burn wet biomass means the unit is in the units designed to burn biomass/bio-based solid subcategory that is either a stoker, sloped grate, or other combustor design and any of the biomass/bio-based solid fuel combusted in the unit exceeds 20 percent moisture on an annual heat input basis. Per 40 CFR 63.7575, a hybrid suspension grate boiler means a boiler designed with air distributors to spread the fuel material over the entire width and depth of the boiler combustion zone. The biomass fuel combusted in these units exceeds a moisture content of 40 percent on an as-fired annual heat input basis. The drying and much of the combustion of the fuel takes place in suspension, and the combustion is completed on the grate or floor of the boiler. Fluidized bed, dutch oven, and pile burner designs are not part of the hybrid suspension grate boiler design category. Emission limits are different for these subcategories for PM and carbon monoxide (CO) emissions. Therefore, PCA requested and received a determination from U.S. EPA Region 4 (included with Application Number 22133) concurring with PCA that the Combination Boilers should be classified as hybrid suspension grate units designed to burn biomass/bio-based solid subcategory. The following table summarizes the applicable emission limits for the hybrid suspension grate subcategory that is applicable to the Combination Boilers. These emission limits apply at all times, except during periods of startup and shutdown during which time PCA must comply only with Table 3 to 40 CFR 63, Subpart DDDDD [40 CFR 63.7500(f)]. Packaging Corporation of America, TV-22133 Page 10 of 21
40 CFR 63, Subpart DDDDD Emissions Limits for Potentially Applicable Subcategories for Existing Units Subcategory Hybrid Suspension Grate Boiler Designed to Burn Biomass/Bio-Based Solids [40 CFR 63.7499(h), 40, CFR 63.7500(a), 40 CFR 63, Subpart DDDDD Table 2] Filterable PM (lbs/10 6 Btu heat input) Total Selected Metals [TSM] (lbs/10 6 Btu heat input) 1 parts per million by volume on a dry basis 2 Not Applicable Hydrogen Chloride [HCl] (lbs/10 6 Btu heat input) Mercury [Hg] (lbs/10 6 Btu heat input) 0.44 4.5 x 10-4 NA 2 NA 2 CO (ppmvd 1 @ 3% oxygen [O 2 ]) 3,500; 3-run average; (900 using CEMS; 30-day rolling average) In a separate off permit change submittal, PCA proposed to install an oxygen trim system on the Combination Boilers. As a result, the facility must perform the following work practices standards specified in Table 3 of 40 CFR 63, Subpart DDDDD [40, CFR 63.7500(a)]. Existing boilers with a continuous oxygen trim system that maintains an optimum air to fuel ratio PCA must conduct a tune-up of the Combination Boilers every 5 years as specified in 40 CFR 63.7540. Existing boilers located at a major source facility, not including limited use units PCA must have a one-time energy assessment performed as specified by Item 4 in Table 3 of 40 CFR 63, Subpart DDDDD. Existing boilers subject to emission limits in Table 2 of 40 CFR 63, Subpart DDDDD during startup PCA must complete all applicable requirements under Item 5 of 40 CFR 63, Subpart DDDDD during startup of the Combination Boilers. Existing boilers subject to emission limits in Table 2 of 40 CFR 63, Subpart DDDDD during shutdown PCA must complete all applicable requirements under Item 6 of 40 CFR 63, Subpart DDDDD during shutdown of the Combination Boilers. Packaging Corporation of America, TV-22133 Page 11 of 21
The Combination Boilers currently operate a venturi scrubber. As a result, the facility must comply with the following operating limits specified in Table 4 of 40 CFR 63, Subpart DDDDD [40, CFR 63.7500(a)]. Wet PM scrubber control on a boiler not using a PM CPMS - Maintain the 30- day rolling average pressure drop and the 30-day rolling average liquid flow rate at or above the lowest one-hour average pressure drop and the lowest one-hour average liquid flow rate, respectively, measured during the most recent performance test demonstrating compliance with the PM emission limitation according to 40 CFR 63.7530(b) and Table 7 to this subpart. Performance Testing - boilers that demonstrate compliance with a performance test, maintain the operating load of each unit such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test. According to Application Number 22133, the TDF that will be fired at the facility will be provided from a managed tire collection program. Therefore, the TDF is considered to be a non-waste fuel, and does not meet the definition of solid waste per 40 CFR 241.3(b)(2)(1). As provided in Permit Application Number 22133, the following tables summarize the applicable emission limits, operating limits, and work practice standards based on the different proposed operating scenarios of the Combination Boilers. 40 CFR 63, Subpart DDDDD Emissions Limits for the Applicable Subcategory for Existing Units for the Combination Boilers Regulatory Citation 40 CFR 63.7499(h), 40 CFR 7500(a)(1), Tables 1, 2, and 13 of 40 CFR 63, Subpart DDDDD Subcategory Pollutant Emission Limit Existing Biomass Hybrid Suspension Grate HCl Hg 2.2 x 10-2 lb/10 6 Btu heat input Alternatively: 2.5 x 10-2 lb/10 6 Btu of steam output or 0.27 lb/megawatt hour (MWh) 5.7 x 10-6 lb/10 6 Btu heat input CO Alternatively: 6.4 x 10-6 lb/10 6 Btu of steam output or 7.3 x 10-5 MWh 3,500 ppmvd @ 3% O 2 (3-run stack test average); or 900 ppmvd @ 3% O 2 (30-day CEMS rolling average) Alternatively: 3.5 x 10-2 lb/10 6 Btu of steam output (3-run stack test average); or 31 lb/mwh (3-run stack test average) Packaging Corporation of America, TV-22133 Page 12 of 21
Filterable PM (or TSM) 4.4 x 10-1 lb/10 6 Btu heat input (or 4.5 x 10-4 lb/10 6 Btu heat input) Alternatively: 5.5 x 10-1 lb/10 6 Btu of steam output or 6.2 MWh (5.7 x 10-4 lb/10 6 Btu of steam output or 6.3 x 10-3 lb/mwh) 40 CFR 63, Subpart DDDDD Work Practice Standards for Applicable Subcategory for Existing Units for the Combination Boilers Regulatory Citation Subcategory Work Practice Standard 40 CFR 63.7500(a)(1), Tables 1, 3, 4, 5, and 6 of 4 CFR 63, Subpart DDDDD Existing Boilers Subject to Emission Limits Conduct a tune-up every five years as specified in 40 CFR 63.7540. Initial tune-up must be conducted by January 31, 2016. Conduct one-time energy assessment on or after January 1, 2008. During Boiler Startup: o Operate all CMS. o Use one or a combination of clean fuels. o Vent emission to the main stack(s) and engage dust scrubber. o Compliance with emission limits is required at all times except during periods of startup and shutdown conforming with this work practice. o Monitoring data must be collected during startup and records must be kept. Reports concerning activities and period of startup must be provided as specified in 40 CFR 63.7555. Note: Startup ends when steam or heat is supplied for any purpose. During Boiler Shutdown: o Operate all CMS. o Vent emissions to the main stack(s) and operate the dust scrubber. Packaging Corporation of America, TV-22133 Page 13 of 21
o Compliance with emission limits is required at all times except during periods of startup and shutdown confirming with this work practice. o Monitoring data must be collected during periods of shutdown and records must be kept. Reports concerning activities and periods of shutdown must be provided as specified in 40 CFR 63.7555. 40 CFR 63, Subpart DDDDD Operating Limits for Applicable Subcategory for Existing Units for the Combination Boilers Regulatory Citation 40 CFR 63.7500(a)(2) and Table 4 of 40 CFR 63, Subpart DDDDD Subcategory Control Device Operating Limit Existing Biomass Hybrid Suspension Grate Wet Scrubber Maintain 30-day rolling average pressure drop and 30-day rolling average liquid flow rate at or above the lowest one-hour average pressure drip and liquid flow rate measure during the most recent performance test. Note: Startup is as defined in 63.7575 as amended in 40 CFR 63, Subpart DDDDD Reconsideration Rule 40 CFR 64 Except for backup utility units that are exempt under paragraph (b)(2) of 40 CFR 64.2, the requirements of 40 CFR Part 64 apply to a pollutant-specific emissions unit at a major source that is required to obtain a part 70 or 71 permit if the unit satisfies all of the following criteria: (1) The unit is subject to an emission limitation or standard for the applicable regulated air pollutant (or a surrogate thereof), other than an emission limitation or standard that is exempt under paragraph (b)(1) of 40 CFR 64.2; (2) The unit uses a control device to achieve compliance with any such emission limitation or standard; and (3) The unit has potential pre-control device emissions of the applicable regulated air pollutant that are equal to or greater than 100 percent of the amount, in tons per year, required for a source to be classified as a major source. Where potential pre-control device emissions has the same meaning as potential to emit, as defined in 40 CFR 64.1, except that emission reductions achieved by the applicable control device are not taken into account [40 CFR 64.2(a)]. Packaging Corporation of America, TV-22133 Page 14 of 21
The Combination Boilers vent to a common venturi scrubber. The control device will be used to achieve compliance with an applicable emission limit or standard. Potential PM and SO 2 emissions, the controlled pollutants, are above the applicable major source thresholds. Per 40 CFR 64.2(b)(1)(i), emission limitations or standards proposed by the Administrator after November 15, 1990 pursuant to section 111 or 112 of the Clean Air Act are exempted from this regulation. Particulate matter emissions from the combination boilers are limited by 40 CFR 63, Subpart DDDDD. This regulation was promulgated under Section 112 of the Clean Air Act after November 15, 1990. Therefore, PM emissions from the Combination Boilers are exempted from requirements of 40 CFR 64. The SO 2 emissions from the Combination Boilers are already regulated under 40 CFR 64, and the requirements of this regulation for the Combination Boilers SO 2 emissions are already incorporated in the facility s existing Title V permit. Therefore, no additional requirements of 40 CFR 64 result from the proposed changes to the Combination Boilers. Georgia Rule for Air Quality Control (Georgia Rule) 391-3-1-.02(2)(b) Emission Limitations and Standards Visible Emissions This regulation limits opacity to less than forty (40) percent, except as may be provided in other more restrictive or specific rules or subdivisions of Georgia Rule 391-3-1-.02(2). This limitation applies to direct sources of emissions such as stationary structures, equipment, machinery, stacks, flues, pipes, exhausts, vents, tubes, chimneys or similar structures. This regulation is applicable to the Combination Boilers since the proposed changes will not result in units being extensively modified. This regulation is already incorporated into the existing permit for these sources. Georgia Rule 391-3-1-.02(2)(d) Emission Limitations and Standards Fuel Burning Equipment This regulation limits particulate emissions from fuel burning equipment. For fuel burning equipment in operation or under construction on or before January 1, 1972 with a heat input greater than 10 million Btu heat input per hour, and equal to or less than 2,000 million Btu heat input per hour, allowable particulate emissions shall be calculated using the following equation: P = 0.7 [10/R] 0.202 pounds per million BTU heat input, Where: P = allowable weight of emissions of fly ash and/or other particulate matter in pounds per million Btu heat input R = heat input of fuel-burning equipment in million Btu per hour. This particulate emission limit is applicable to the Combination Boilers. The applicability of this regulation is already addressed and subsumed by existing emission limitations. Applicability of 40 CFR 63, Subpart DDDDD PM emissions limits, as applicable, will also subsume the requirements of this regulation. Packaging Corporation of America, TV-22133 Page 15 of 21
Georgia Rule 391-3-1-.02(2)(g) Sulfur Dioxide This regulation regulates fuel sulfur content, by weight. All fuel burning sources greater than or equal to 100 million BTUs of heat input per hour shall not burn fuel containing more than 3 percent sulfur, by weight. This regulation is applicable to the Combination Boilers. The applicability of this regulation is already addressed by existing emission limitations. According to Application Number 22133, the sulfur content of the TDF used by PCA will be less than three percent sulfur, by weight. Georgia Air Toxics Guidelines Assessment According to Application Number 22133, PCA completed a site-wide toxic impact assessment in 2005, and the proposed project will not change the conclusions of the original air toxics modeling evaluation. Therefore no updated assessment was conducted as part of this application. Regulatory requirements of 40 CFR 63, Subpart DDDDD will involve demonstrating continuous compliance with many toxics potentially emitted from the Combination Boilers. Therefore, the Division agrees that no toxic impact assessment is deemed applicable at this time. D. Compliance Status No noncompliance issues were indicated in Application 22133. E. Operational Flexibility No operational flexibility is added, removed, or modified as associated with this permit modification. F. Permit Conditions Permit Condition 3.3.41 defines the combination boilers and stack per applicability of 40 CFR 63, Subpart DDDDD. Permit Condition 3.3.42 through 3.3.45 define boiler tune-up requirements, energy assessment, fuel usage limitations, and emission limitations for the combinations boilers per 40 CFR 63, Subpart DDDDD. Permit Conditions 3.3.46 through 3.3.48 specify initial, continuous compliance and work practice standards for the combination boilers per 40 CFR 63, Subpart DDDDD. Permit Condition 3.5.7 specified the types of fuels that may be fired in the combination boilers. V. Testing Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Not Applicable. Packaging Corporation of America, TV-22133 Page 16 of 21
B. Equipment Groups (all subject to the same test requirements): 40 CFR 63, Subpart DDDDD PCA must conduct the following performance testing for both of the Combination Boilers. Per 40 CFR 63.7515(a), PCA must conduct all applicable performance tests according to 40 CFR 63.7520 on an annual basis, except as specified in paragraphs (b) through (e), (g), and (h) of 40 CFR 63.7515. Annual performance tests must be completed no more than 13 months after the previous performance test, except as specified in paragraphs (b) through (e), (g), and (h) of 40 CFR 63.7515. PCA must report the results of performance tests and the associated fuel analyses within 60 days after the completion of the performance tests. This report must also verify that the operating limits for each boiler have not changed or provide documentation of revised operating limits established according to 40 CFR 63.7530 and Table 7 to 40 CFR 63, Subpart DDDDD, as applicable. The reports for all subsequent performance tests must include all applicable information required in 40 CFR 63.7550 [40 CFR 63.7515(f)]. PCA must demonstrate initial compliance with each applicable emission limit by conducting initial performance tests and fuel analyses and establishing operating limits, as applicable, according to 40 CFR 63.7520, paragraphs (b) and (c) of 40 CFR 7530, and Tables 5 and 7 to 40 CFR 63, Subpart DDDDD. Boilers that demonstrate compliance through performance testing must establish each applicable site-specific operating limit in Table 4 to 40 CFR 63, Subpart DDDDD according to the requirements in 40 CFR 63.7520, Table 7 to 40 CFR 63, Subpart DDDD, and paragraph (b)(4) of 63.7530, as applicable. PCA must also conduct fuel analyses according to 40 CFR 63.7521 and establish maximum fuel pollutant input levels according to paragraphs (b)(1) through (3) of 40 CFR 63.7530, as applicable, and as specified in 40 CFR 63.7510(a)(2). PCA must conduct all performance tests according to 40 CFR 63.7(c), (d), (f), and (h). PCA must also develop a site-specific stack test plan according to the requirements in 40 CFR63.7(c). PCA must conduct all performance tests under such conditions as the Division specifies to be based on the representative performance of each boiler for the period being tested. Upon request, PCA shall make available to the Division such records as may be necessary to determine the conditions of the performance tests per 40 CFR 63.7525(a). PCA must conduct each performance test according to the requirements in Table 5 to 40 CFR 63, Subpart DDDDD. The tests have to meet the specific conditions list in Tables 5 and 7 to 40 CFR 63, Subpart DDDDD. PCA must conduct performance tests at representative operating load conditions while burning the type of fuel or mixture of fuels that has the highest content of chlorine and mercury, and TSM if PCA is opting to comply with the TSM alternative standard and must demonstrate initial compliance and establish operating limits based on these performance tests. These requirements could result in the need to conduct more than one performance test. Following each performance test and until the next performance test, PCA must comply with the operating limit for operating load conditions specified in Table 4 to 40 CFR 63, Subpart DDDDD [40 CFR 63.7520(c)]. For solid and liquid fuels, PCA must conduct fuel analyses for chloride and mercury according to the procedures in paragraphs (b) through (e) of 40 CFR 63.7521 and Table 6 to 40 CFR 63, Subpart DDDDD, as applicable. For solid fuels, PCA must also conduct fuel analyses for TSM if opting to comply with the TSM alternative standard. Sampling and analysis of the individual gaseous streams prior to combining is not required. PCA is not required to conduct fuel analyses for fuels used for only startup, unit shutdown, and transient flame stability purposes. PCA is required to conduct fuel analyses only for fuels and units that are subject to emission limits for mercury, HCl, or TSM in Tables 1 and 2 or 11 through 13 to 40 CFR 63, Subpart DDDDD. Certain gaseous and certain liquid fuels are exempt from the sampling requirements in paragraphs (c) and (d) of 40 CFR 63.21 and Table 6 to 40 CFR 63, Subpart DDDDD. Packaging Corporation of America, TV-22133 Page 17 of 21
Per 40 CFR 63.7521(b), PCA must develop a site-specific fuel monitoring plan according to the following procedures and requirements in paragraphs (b)(1) and (2) of 40 CFR 63.7521, if required to conduct fuel analyses as specified in 40 CFR 63.7510. Permit Condition 4.1.6 specifies the testing methods for the combination boilers per 40 CFR 63, Subpart DDDDD. Permit Conditions 4.2.16 through 4.2.18 specify the testing requirements for applicable standards per 40 CFR 63, Subpart DDDDD. Permit Conditions 4.2.19 through 4.2.21 specify the testing plan requirements per 40 CFR 63, Subpart DDDDD. Permit Condition 4.2.22 through 4.2.26 specify applicable initial and subsequent testing requirements for applicable standards per 40 CFR 63, Subpart DDDDD. Permit Conditions 4.2.27 through 4.2.29 specify applicable fuel analysis requirements for applicable standards per 40 CFR 63, Subpart DDDDD. VI. Monitoring Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Not Applicable. B. Equipment Groups (all subject to the same monitoring requirements): 40 CFR 63, Subpart DDDDD PCA must conduct the following monitoring for each of the Combination Boilers. PCA must monitor and collect data according to 40 CFR 63.7535 and the site-specific monitoring plan required by 40 CFR 63.7505(d). Per 40 CFR 63.7540(a)(10), PCA must conduct an annual tune-up of the Combination Boilers to demonstrate continuous compliance as specified in 40 CFR 63.7540(a)(10)(i) through (vi). Boilers subject to a CO emission limit in Tables 1, 2, or 11 through 13 to 40 CFR 63 Subpart DDDDD must install, operate, and maintain an oxygen analyzer system, which includes oxygen trim systems, as defined in 40 CFR 63.7575, and demonstrate compliance through performance testing or install, certify, operate and maintain continuous emission monitoring systems for CO and oxygen according to the procedures in paragraphs (a)(1) through (7) of 40 CFR 63.7525. Per Table 8 units with O2 Trim systems as defined in 40 CFR 63.7575 are exempt from the O2 operating limit monitoring but the O2 Trim system must be operated per 40 CFR 63.7525(a)(7). Boilers with an operating limit that requires the use of a CMS other than a PM CPMS or COMS must install, operate, and maintain each CMS according to the procedures in paragraphs (d)(1) through (5) of 40 CFR 63.7525 by the compliance date specified in 40 CFR 63.7495. Permit Conditions 5.2.18 through 5.2.22 specify monitoring requirements for applicable equipment per 40 CFR 63, Subpart DDDDD. Packaging Corporation of America, TV-22133 Page 18 of 21
Permit Condition 5.2.23 through 5.2.27 specify the site specific plans and performance evaluations for the combination boilers per 40 CFR 63, Subpart DDDDD. Permit Condition 5.2.28 and 5.2.29 specify applicable monitoring requirements associated with fuel analysis for the combination boilers per 40 CFR 63, Subpart DDDDD. VII. Other Record Keeping and Reporting Requirements 40 CFR 63, Subpart DDDDD PCA must complete all applicable notifications as required by 40 CFR 63.7545. PCA must keep all applicable records according to 40 CFR 63.7555(a)(1) and (2). PCA must submit a compliance report with the applicable information in 40 CFR 63.7550(c). Per 40 CFR 63.7560, records must be in a form suitable and readily available for expeditious review, according to 40 CFR 63.10(b)(1). PCA must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The records must be kept on site, or they must be accessible from on-site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to 40 CFR 63.10(b)(1). Records can be kept off site for the remaining 3 years. PCA must submit all of the notifications in 40 CFR 63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b) through (h) that apply by the dates specified [40 CFR 63.7545(a)]. PCA must include with the Notification of Compliance Status a signed certification that the energy assessment was completed according to Table 3 to 40 CFR 63, Subpart DDDDD and is an accurate depiction of the facility at the time of the assessment [40 CFR 63.7530(e)]. PCA must submit the Notification of Compliance Status containing the results of the initial compliance demonstration according to the requirements in 40 CFR 63.7545(e) [40 CFR 63.7530(f)]. PCA must demonstrate continuous compliance with each applicable emission limit in Tables 1 and 2 or 11 through 13 to 40 CFR 63, Subpart DDDDD, the applicable work practice standards in Table 3 to 40 CFR 63, Subpart DDDDD, and the applicable operating limits in Table 4 to 40 CFR 63, Subpart DDDDD according to the methods specified in Table 8 to 40 CFR 63, Subpart DDDDD and paragraphs (a)(1) through (19) of 40 CFR 63.7540. PCA must report each instance in which each applicable emission limit and operating limit in Tables 1 through 4 or 11 through 13 to 40 CFR 63, Subpart DDDDD are not met. These instances are deviations from the emission limits or operating limits, respectively, in 40 CFR 63, Subpart DDDDD. These deviations must be reported according to the requirements in 40 CFR 63.7550 [40 CFR 63.7540(b)]. Permit Conditions 6.2.37 through 6.2.45 specify the record keeping and reporting requirements for the combination boilers per 40 CFR 63, Subpart DDDDD. Permit Conditions 6.2.46 through 6.2.49 specify the record keeping for the combination boilers per 40 CFR 63, Subpart DDDDD. Permit Conditions 6.2.50 and 6.2.51 specify the site specific plans requirements for the combination boilers per 40 CFR 63, Subpart DDDDD. Packaging Corporation of America, TV-22133 Page 19 of 21
VIII. Specific Requirements A. Operational Flexibility No operational flexibility is added, removed, or modified as associated with this permit modification. B. Alternative Requirements There are no alternative requirements associated with this modification. C. Insignificant Activities There are no added insignificant activities associated with this modification. D. Temporary Sources There are no temporary sources associated with this modification. E. Short-Term Activities There are no short-term activities associated with this modification. F. Compliance Schedule/Progress Reports No compliance schedule/progress reports were added as a result of this modification. G. Emissions Trading There is no emissions trading associated with this modification. H. Acid Rain Requirements This permit modification does not affect the applicability of Acid Rain requirements to this facility. I. Prevention of Accidental Releases This permit modification does not affect the applicability of Prevention of Accidental Releases requirements to this facility. J. Stratospheric Ozone Protection Requirements This permit modification does not affect the applicability of Stratospheric Ozone Protection requirements to this facility. K. Pollution Prevention This permit modification does not affect the applicability of Pollution Prevention requirements to this facility. Packaging Corporation of America, TV-22133 Page 20 of 21
L. Specific Conditions There are no specific conditions associated with this modification. Packaging Corporation of America, TV-22133 Page 21 of 21