INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
August 27, 2020

FOR:
Leaf River Cellulose, LLC
157 Buck Creek Road
New Augusta, Mississippi 39462 (Perry Co.)
Permit No. 2200-00005

FACILITY DESCRIPTION
Leaf River Cellulose, LLC is an existing pulp and paper mill located in New Augusta, Mississippi (Perry County).  The facility is applying for reissuance of their Title V Operating Permit.  The facility operates 24 hours per day,7 days per week, and 52 weeks per year. The reissuance will include the facility changes permitted in the PSD Permit to Construct issued February 1, 2018.

The facility consists of the following major processes. The significant sources of emissions (i.e., those with ≥ 1 lb/hr of a criteria pollutant and/or ≥ 0.1 lb/hr of any hazardous air pollutant (HAP), or otherwise subject to a federal standard) are addressed in Section 2 of the permit. The insignificant activities are noted in the process descriptions below.  
Woodyard (WY) Area (AA-001): The woodyard contains facilities, processes, and equipment for long wood and short log handling, debarking, chipping, and chip screening. The following are insignificant activities: Chipper Building (WY-3), Scalping/Screening Building (WY-4), Screening Building (WY-7), Purchased Chip Unloading (WY-12), Log Storage (WY-14), and Bulldozing (WY-16). The following are insignificant activities because they are sources associated with bark and wood-waste storage and handling, as listed in 11 Miss. Admin. Code Pt. 2, R. 6.7.B(13).: Bark Woodwaste Pile (bark and fines) (WY-9),  and Purchased Bark Unloading (WY-13). Both soft and hardwood are processed in the woodyard.  Purchased chips and bark are also handled in the woodyard. The only significant sources of emissions in the Woodyard Area are the Debarker (WY-11) and Bark Shredder (WY-8).

Kraft Pulp Mill Area (PM): The Kraft pulp mill area includes the Digester (AA-006) and Brownstock Washer Systems (AA-007).  Wood chips are digested to make pulp and further processed into brownstock. The following sources are insignificant activities operating within AA-006: Contaminated Condensate Flash Tank (PM-3), and Knot Recycle Conveyor (PM-41). The following sources are insignificant activities operating within AA-007: Knots and Rejects Drainer (PM-9), Bulk Defoamer Tank (PM-43) and Defoamer Day Tank (PM-43a).

Kraft Mill Multi-Stage Bleaching Process (BP) (AA-008): Brown stock is bleached by sending it through a multi-stage bleaching sequence utilizing different chemicals and operating conditions in each stage. The following sources are insignificant: No. 1 Bleached HD Storage Chest (BP-17), No. 2 Bleached Storage Chest (BP-18), ClO2, Caustic and Sodium Chlorate Storage Tanks, No. 1 Exhaust Fan (ER-3), No. 2 Exhaust Fan (ER-4), Roof Vent Fan (ER-5), and the Wall Vent Fans (ER-6 through ER-11). 

•	In order to comply with the requirements of 40 CFR 63, Subpart S, the First Stage Tower (BP-2), First Stage Washer (BP-3), First Stage Seal Chest (BP-4), Second ClO2 Tower (BP-8), and the Third ClO2 Tower (BP-14) all vent to the First Stage ClO2 Scrubber (BP-19).  In addition, the Second ClO2 Washer (BP-9), Second ClO2 Seal Chest (BP-10), Third ClO2 Washer (BP-15), and the Third ClO2 Seal Chest (BP-16) vent to the ClO2 Gas Scrubber (BP-20).
•	Although not required by Subpart S, the ClO2 Tail Gas Scrubber (ER-2), the First E(op) Washer (BP-6), First E(op) Seal Chest (BP-7), and the Second Ep Tower (BP-11) vent to the First Stage ClO2 Scrubber (BP-19), and the Second Ep Washer (BP-12) and the Second Ep Seal Chest (BP-13) vent to the ClO2 Gas Scrubber (BP-20).

Pulp Drying Process (PD) (AA-009):  Bleached pulp from the high density storage towers is dried through a series of slushers, screens and cleaners, the fourdrinier dryer, felt rollers, and the air borne dryer. The following sources are insignificant activities:  Blend Chest (PD-1), Machine Chest (PD-2), Broke Chest (PD-3), Slusher Exhaust (PD-4), Fourdrinier Exhausts Nos, 1, 2 and 3 (PD-5, PD-6, PD-116), Low Vacuum Blower (PD-8), Vacuum Pump Exhausts (PD-14, PD-15, PD-16), Wet End Roof Exhaust (PD-100), Roof Exhausts East Side of Oven (PD-101, PD-102, PD-103), Fluff Line Roof Exhausts (PD-104, PD-105), Bale Line Roof Exhausts (PD-106, PD-107), Fourdrinier False Ceiling Exhausts (PD-108, PD-109), Fluff Pit Exhaust (PD-110), Maintenance Shop Wall Exhaust (PD-111), North Crane Ventilation PD-112), No. 1 Dryer Exhaust Fan Northwest (PD-113) and the No. 2 Dryer Exhaust Fans (PD-114, PD-115).

Evaporators (AA-010)/Tall Oil Process (EV) (AA-042): Weak black liquor (BL) is concentrated to increase solid contents using multiple-effect evaporators. Soap and sulfuric acid are combined to convert the soap to tall oil. The following sources are insignificant activities: Crude Tall Oil Storage Tanks (EV-3, EV-4) and Nos. 1 and 2 Tall Oil Soap Tanks (EV-5, EV-6). 

Recausticizing Area (RC) (AA-014): The main function of the recausticizing area is to causticize green liquor with reburned lime to form white liquor (WL) for the next cooking cycle. 

Oxygen Delignification Process (AA-021): This process includes the Magnesium Sulfate Handling System, White Liquor Oxidizer (O2D-2) (Insignificant Activity), Oxygen Reactor Blowtube (O2D-4), the Filtrate Storage Tank (O2D-5) and Atmospheric Diffusion Washer (AA-023). 

Kraft Pulping Process Low Volume High Concentration (LVHC) System (AA-025):
40 CFR 63, Subpart S, defines the LVHC system as the collection of equipment including the digester, turpentine recovery, evaporator, steam stripper systems, and any other equipment serving the same function as those previously listed.  At this Mill, LVHC emission streams are controlled by the Lime Kiln (AA-013) or NCG incinerator (AA-016).  The stripper off-gases are routed to a methanol rectification system where the vapors are condensed into rectified liquid methanol, which in turn, is burned as a fuel in the NCG Incinerator or Lime Kiln.

The LVHC System includes the following process systems:  
•	Digester System, which consists of continuous digester(s), flash tank(s), blow tank(s), chip steamer(s) not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), and prehydrolysis unit(s) preceding the pulp washing system. The digester system consists of each continuous digester or each batch digester used for the chemical treatment of wood or non-wood fibers. The digester system equipment includes associated flash tank(s), blow tank(s), chip steamer(s) not using fresh steam, blow heat recovery accumulator(s), relief gas condenser(s), prehydrolysis unit(s) preceding the pulp washing system, and any other equipment serving the same function as those previously listed. The digester system includes any of the liquid streams or condensates associated with batch or continuous digester relief, blow, or flash steam processes.  For this Mill, the following equipment exists that is part of the LVHC system: Continuous Digester (PM-40), Chip Steaming Vessel (PM-7), No. 1C Flash Tank, No. 2 Flash Tank. 
The No. 1C Flash Tank is pressurized and normally vents to the Chip Steaming Vessel. The No. 2 Flash Tank normally vents to the Chip Bin.  The continuous digester (PM-40) is controlled in the NCG Incinerator or Lime Kiln as part of the LVHC NCG system (AA-025) as required by 40 CFR 60, Subpart BB and 40 CFR 63, Subpart S.  The Chip Steaming Vessel (PM-7) is controlled in the NCG Incinerator or Lime Kiln as part of the LVHC NCG system (AA-025) as required by 40 CFR 63, Subpart S. 
•	Turpentine Recovery System (AA-040), which consists of condenser(s), decanter(s), and storage tank(s) used to recover turpentine from digester system gases. Turpentine recovery system means all equipment associated with recovering turpentine from digester system gases including condensers, decanters, storage tanks, and any other equipment serving the same function as those previously listed. The turpentine recovery system includes any liquid streams associated with the turpentine recovery process such as turpentine decanter underflow. Liquid streams that are intended for byproduct recovery are not considered turpentine recovery system condensate streams.  For this Mill, the following equipment exists that is part of the LVHC system: Turpentine Decanter Underflow Tank (PM-20) and Turpentine Condenser. These units vent to a gas cooler and are then collected in the LHVC NCG system.
•	Evaporator System, which consists of the multi-effect evaporators, associated condenser(s), and hotwell(s). The evaporator system means all equipment associated with increasing the solids content and/or concentrating spent cooking liquor from the pulp washing system including pre-evaporators, multi-effect evaporators, concentrators, and vacuum systems, as well as associated condensers, hotwells, and condensate streams, and any other equipment serving the same function as those previously listed.  For this Mill, the following equipment exists that is part of the LVHC system: Nos. 1 and 2 Multiple-Effect Evaporators (EV-36, EV-36a)
•	Steam Stripper System (AA-041), which consists of the steam stripper(s), stripper feed tank(s), condenser(s), heat exchanger(s), rectifier(s), condenser(s), decanter(s), and storage tank(s) associated with any methanol rectification process. The steam stripper system consists of the steam stripper(s), stripper feed tank(s), condenser(s), heat exchanger(s), rectifier(s), condenser(s), decanter(s), and storage tank(s) associated with any methanol rectification process.  For this Mill, the following equipment exists that is part of the LVHC system: No. 1 Foul Condensate Storage Tank (EV-31), No. 2 Foul Condensate Storage Tank (EV-31a), Methanol Condenser, Methanol Storage Tank, Methanol Rectification Column, Methanol Partial Condenser, Red Oil Decanter. Under normal operations, the stripper off-gases from the two steam strippers are sent to the methanol rectification system and are not vented to atmosphere.  If the methanol rectification system is not operating, the strippers are shutdown. The methanol condenser, partial condenser and rectification column are collected and are sent to the LVHC NCG system. The gases from the red oil decanter and the methanol storage tank combine and are also sent to the LVHC NCG system.

Kraft Pulping System Process Condensates (AA-028): Pulping process condensates are collected from the turpentine recovery system, the evaporator system for each stage where weak liquor is introduced (feed stages), the evaporator vacuum system for each stage where weak liquor is introduced (feed stages), the HVLC collection system, and the LVHC collection system. 40 CFR 63, Subpart S requires that pulping process condensates from the following equipment systems be treated:  each digester system; each turpentine recovery system; each evaporator system condensate from, (1) the vapors from each stage where weak liquor is introduced (feed stages); and (2) each evaporator vacuum system for each stage where weak liquor is introduced (feed stages); each HVLC collection system; and each LVHC collection system.  
Wastewater Collection and Treatment Operations (WW-1 through WW-30) (AA-035):  Wastewater generated from the mill is treated using an activated sludge process.  Treated water is discharged through the NPDES permitted outfall and includes various clarifiers, lift stations, ponds/basins, wastewater tanks, reactors, filters, lime dust collector (WW-16), and chemical treatment tanks (e.g., caustic, acid, anhydrous ammonia, alum, and polymer).

Petroleum Coke Operation (AA-036):  The petroleum coke operation includes the ground petroleum coke silo.  The two (2) petroleum coke silos are each equipped with a baghouse to control particulate matter emissions during unloading.

Kraft Pulping Process High Volume Low Concentration (HVLC) System (AA-043):
The MACT rule, at 40 CFR 63, Subpart S, defines the HVLC system as the collection of equipment including the pulp washing, knotter, screen, decker, and oxygen delignification systems, weak liquor storage tanks, and any other equipment serving the same function as those previously listed. The HVLC System includes the following process systems:

•	Pulp washing System, Pulp Washing System means all equipment used to wash pulp and separate spent cooking chemicals following the digester system and prior to the bleaching system, oxygen delignification system, or paper machine system (at unbleached mills). The pulp washing system equipment includes vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, foam breakers or tanks, and any other equipment serving the same function as those previously listed. The pulp washing system does not include deckers, screens, knotters, stock chests, or pulp storage tanks following the last stage of pulp washing. The system consists of vacuum drum washers, diffusion washers, rotary pressure washers, horizontal belt filters, intermediate stock chests, and their associated vacuum pumps, filtrate tanks, foam breakers or tanks. The Unscreened HD Storage Tank vents to the Atmospheric Diffusion Washer. The Atmospheric Diffusion Washer, No. 1 Atmospheric Diffuser Filtrate Tank, and the Unscreened HD Storage Tank are not required to be collected and controlled under NSPS Subpart BB. This equipment complies with the requirements of 40 CFR 63, Subpart S using the Clean Condensate Alternative (CCA). The BSW Filtrate Tank vents to the Vacuum Drum Washer and the Vacuum Drum Washer is collected as part of the Mill’s HVLC NCG system. The HVLC NCG’s are combusted in the NCG Incinerator (AA-016) or Lime Kiln (AA-013). The Pressure Diffuser Washer and the associated No. 2 Pressure Diffuser Filtrate Tank are pressurized, enclosed vessels with no vent to the atmosphere. 
•	Knotter System, which consists of the knotter, knot drainer tanks and ancillary tanks. Knotter System means equipment where knots, oversized material, or pieces of uncooked wood are removed from the pulp slurry after the digester system and prior to the pulp washing system. The knotter system equipment includes the knotter, knot drainer tanks, ancillary tanks, and any other equipment serving the same function as those previously listed.  For this Mill, the following equipment exists that is part of the HVLC system: Knot Drainer (PM-25), Open Knot Bin (PM-27), Knots and Rejects Tank (PM-30), Knotters (two primary and one secondary). 
•	Screen System, which consists of a drainer, tanks, chests and screens for removing oversized particles from the pulp slurry. Screen System means equipment in which oversized particles are removed from the pulp slurry prior to the bleaching or papermaking system washed stock storage.  For this Mill, the following equipment exists that is part of the HVLC system: Tertiary Screen Rejects Drainer (PM-35); Primary Screen Feed Tank (PM-36); Primary Screen Rejects Tank (PM-37); Secondary Screen Rejects Chest (PM-38); Tertiary Screen Accepts Chest (PM-39); Nos, 1, 2, 3 and 4 Primary Screens, Secondary Screen and Tertiary Screen.
•	Decker System, which consists of decker vents, filtrate tanks and associated vacuum pumps used to thicken the pulp slurry. Decker System means all equipment used to thicken the pulp slurry or reduce its liquid content after the pulp washing system and prior to high-density pulp storage. The decker system includes decker vents, filtrate tanks, associated vacuum pumps, and any other equipment serving the same function as those previously listed.  For this Mill, the following equipment exists that is part of the HVLC system: Brown Stock Decker (PM-31) and Decker Filtrate Seal Tank (PM-32).
•	Oxygen Delignification System, which consists of the blow tank, washers, filtrate tanks, any interstage pulp storage tanks. Oxygen is used to remove lignin from the pulp. Oxygen Delignification System means the equipment that uses oxygen to remove lignin from pulp after high-density stock storage and prior to the bleaching system. The oxygen delignification system equipment includes the blow tank, washers, filtrate tanks, any interstage pulp storage tanks, and any other equipment serving the same function as those previously listed. The Oxygen Delignification System includes No. 1 Oxygen Reactor, No. 2 Oxygen Reactor, No. 2 Oxygen Reactor Blowtube (No. 02D-4)(AA-021), Filtrate Storage Tank (O2D-5)(AA-021) and Atmospheric Diffusion Washer (No. 02D-6) (AA-023). The Mill has a two-stage Oxygen Delignification System.  The No. 1 Oxygen Reactor vents to the No. 2 Oxygen Reactor, which ultimately vents to the No. 2 Oxygen Reactor Blowtube. The oxygen delignification system is subject to 40 CFR 63, Subpart S and complies with these requirements by utilizing the Clean Condensate Alternative of Subpart S.
•	Weak Liquor Storage Tanks consist of tanks containing spent liquor recovered from the pulping process. Weak Liquor Storage Tank means any storage tank except washer filtrate tanks containing spent liquor recovered from the pulping process and prior to the evaporator system.  For this Mill, the following equipment exists that is part of the HVLC system: Filtered Weak BL Tank (PM-18); Weak Black Liquor (BL) Spill Tank (PM-12), Nos. 1, 2, and 3 Weak BL Tanks (EV-10, EV-15, EV-16) and Boilout/Spill Tank (EV-16a)

Smelt Dissolving Tank (AA-012): The smelt dissolving tank is used to dissolve smelt from the Recovery Furnace (AA-011)  

Plant Utilities:  Plant fuel burning utilities include:
•	190 MMBTU/hr Package Boiler used for steam production (AA-005)
•	1755.3 MMBTUH Recovery Furnace combusting black liquor (AA-011)
•	138.6 MMBTU/hr Lime Kiln for converting lime mud to calcium oxide for reuse (AA-013)
•	846 MMBTU/hr Power Boiler used for steam production (AA-015)
•	31.5 MMBTU/hr Incinerator used to incinerate NCGs (AA-016)
•	10.0 MMBTU/hr Natural Gas-Fired Boiler used for steam production (AA-024) This unit will be decommissioned after the modification to the Recovery Furnace (AA-011) is completed (PSD Permit to Construct issued February 1, 2018). 

Emergency Engines: 

•	340 hp Diesel Powered Fire Pump (AA-037)
•	61 hp Lime Kiln Back-Up CI Diesel Engine (AA-037)
•	53 hp Back-Up Dump Tank Agitator Drive CI Diesel Engine (AA-037)
•	210 hp Diesel Powered Fire Pump (AA-037)
•	250 hp Effluent Waste Lift Diesel-fired CI Emergency Engine (AA-038)

TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential-to-emit exceeds the Title V major source thresholds for Particulate Matter less than 10 microns and less than 2.5 microns (PM10/PM2.5), Sulfur Dioxides (SO2), Nitrogen Oxides (NOX), Carbon Monoxide (CO), Total Reduced Sulfur (TRS), Volatile Organic Compounds (VOCs), total Hazardous Air Pollutants (HAPs), and individual HAPs (including but not limited to Hydrochloric Acid, Cresylic Acid, Acetaldehyde, Phenol and Methanol)

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR 64 specifies the requirements for Compliance Assurance Monitoring (CAM). The general applicability is in 40 CFR 64.2 and requires any Part 70 or Part 71 source to comply with the CAM requirements if the following criteria are met:

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1), and

2.	The unit uses a control device to meet the standard, and

3.	The unit has pre-control emissions exceeding major source thresholds.

Emission Points AA-042 (Tall Oil Reactor), AA-013 (Lime Kiln), AA-016 (NCG Incinerator) and AA-015 (Power Boiler) are subject to an emission limitation or standard, use a control device, and have pre-control emissions that exceed the major source thresholds. Therefore, CAM does apply to these emission points, and a CAM Plan is provided in Appendix B of the permit.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
The facility is subject to the following New Source Performance Standards (NSPS):  
40 CFR 60, Subpart BB - Standards of Performance for Kraft Pulp Mills
Emission Points AA-006, AA-007, AA-010, AA-011, AA-012, AA-013, AA-016 and AA-041 are subject to and shall comply with 40 CFR 60, Subpart BB - Standards of Performance for Kraft Pulp Mills.
40 CFR 60, Subpart D - Standards of Performance for Fossil-Fuel-Fired Steam Generators
Emission Point AA-015 is subject to and shall comply with 40 CFR 60, Subpart D - Standards of Performance for Fossil-Fuel-Fired Steam Generators for which construction commenced after August 17, 1971. Emission Point AA-005 was constructed in 1983 but has a heat input rate of less than 250 MMBtu/hr; therefore, it is NOT subject to Subpart D.  The boiler was constructed in 1983 and has not been modified or reconstructed after June 19, 1984; therefore, it is NOT subject to Subpart Db. 
40 CFR 60, Subpart Db - Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units
Both Emission Points AA-005 and AA-015 were constructed in 1983, prior to the applicability date of this subpart (i.e., June 19, 1984). Neither boiler has been modified or reconstructed; therefore, the boilers are NOT subject to Subpart Db. 
40 CFR 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984
The facility operates a methanol storage tank (AA-008) and a turpentine storage tank (AA-040). Both tanks have a capacity less than 151 m3 and maximum vapor pressure less than 15 kPa. Therefore, these tanks are NOT subject to Subpart Kb.
40 CFR 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE)
The engines in Emission Point AA-037 are not subject to 40 CFR 60, Subpart IIII – Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines (ICE), since the construction commenced prior to the applicability date and/or the engines were manufactured prior to the applicability dates.  
Emission Point AA-038 is a CI ICE that was manufactured after April 1, 2006; therefore the unit is subject to 40 CFR 60, Subpart IIII.

NATIONAL EMISSION STANDRADS FOR HAZERDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is a major source of hazardous air pollutants (HAPs) and is subject to the following 40 CFR Part 63 standards for major sources:  
40 CFR 63, Subpart S – National Emission Standards for the Pulp and Paper Industry
Emission Points AA-008, AA-025, AA-028, and AA-043 are subject to and shall comply with 40 CFR 63, Subpart S – National Emission Standards for the Pulp and Paper Industry. In order to comply with the requirements of Subpart S, the First Stage Tower (BP-2), First Stage Washer (BP-3), First Stage Seal Chest (BP-4), Second ClO2 Tower (BP-8), and the Third ClO2 Tower (BP-14) all vent to the First Stage ClO2 Scrubber (BP-19). The Second ClO2 Washer (BP-9), Second ClO2 Seal Chest (BP-10), Third ClO2 Washer (BP-15), and the Third ClO2 Seal Chest (BP-16) vent to the ClO2 Gas Scrubber (BP-20) to comply with Subpart S. 
40 CFR 63, Subpart MM – National Emission Standards for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semi-chemical Pulp Mills 
Emission Points AA-011, AA-012 and AA-013 are subject to and shall comply with 40 CFR 63, Subpart MM – National Emission Standards for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semi-chemical Pulp Mills.
40 CFR 63, Subpart ZZZZ – National Emission Standards for Stationary Reciprocating Internal Combustion Engines (RICE)
The engines in Emission Points AA-037 and AA-038 are subject to and shall comply with 40 CFR 63, Subpart ZZZZ – National Emission Standards for Stationary Reciprocating Internal Combustion Engines (RICE).  The engines in Emission Point AA-037 are considered existing emergency compression ignition (CI) RICE of less than 500 brake horsepower located at a major source of HAP.  There are subject to limited requirements related to operation and maintenance.  Emission Point AA-038 is considered a new emergency CI RICE and meets the requirements of Subpart ZZZZ by complying with 40 CFR 60, Subpart IIII.
40 CFR 63, Subpart DDDDD – National Emission Standards for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters 
Emission Points AA-005 and AA-015 are subject to and shall comply with 40 CFR 63, Subpart DDDDD – National Emission Standards for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters for existing boilers.  Emission Point AA-005 is considered an existing natural gas-fired boiler in the “units designed to burn gas 1 fuels” subcategory.  This boiler is required to comply with the annual tune-up work practice standards. Emission Point AA-015 is considered an existing boiler in the “stokers/sloped grate/other units designed to burn wet biomass/bio-based solid” subcategory. In addition to annual tune-ups, this boiler has various emission standards, continuous monitoring, and periodic testing requirements.

SPECIFIC APPLICABLE REQUIREMENTS
EMISSION LIMITS	
Emission Point No.	Pollutant/ Parameter	Draft Permit Emission Limits	Monitoring Requirements	
Facility-wide	PM	E=4.1(p)0.67	Maintain records of all inspections, maintenance, and cleanings conducted in accordance with Section 3.D. Operate control devices for control of PM per the applicable federal standards and CAM requirements.	
AA-005	PM	E = 0.8808 * I –0.1667	Maintain records monthly of the Annual Fuel Consumption Rate and calculate a 12-month rolling total for each fuel used.  Since the boiler only combusts clean fuels, the margin of compliance with the State standards is significant.	
	SO2	4.8 lbs/MMBTU		
	Fuel Restriction	Fuels other than natural gas or propane are prohibited.		
AA-005	PM
SO2
NOX
CO
VOC	0.92 lbs/hr
0.11 lbs/hr
15.0 lbs/hr
7.2 lbs/hr
0.53 lbs/hr	Stack test within 18 months of the permit issuance and every five years thereafter.	
AA-005	Hours of Operation	The permittee shall not operate Emission Point AA-005 simultaneously with AA-011 and AA-015 for more than 1,000 hours per year (on a 365-day rolling total).	Maintain daily records of the hours of operation.  Calculate and record daily the hours of simultaneous operation with Emission Points AA-011 and AA-015 on a 365-day rolling total.	
AA-005	Work Practices	Work practices provided in Table 3 of Subpart DDDDD 	Conduct an annual tune-up of the unit to demonstrate continuous compliance.	
AA-006 AA-007 AA-010	TRS	Total reduced sulfur (TRS) is limited to 5 ppm by volume on a dry basis corrected to 10% oxygen unless:
1.	Exhaust gases are combusted in the Lime Kiln (AA-013) in accordance with 40 CFR 60.283(a)(5); or
2.	Exhaust gases are combusted in the incinerator (AA016) and subjected to a minimum temperature of 1200 F for at least 0.5 second.	Continuously monitor TRS concentration from lime kiln and continuously monitor the combustion temperature of the incinerator.	
AA-008	HAP	Bleaching system equipment shall be enclosed and routed to a control device where the total chlorinated HAP emissions excluding chloroform shall be reduced to 10 ppmv or less.	Perform testing annually where specified by 40 CFR 63, Subpart S and biennially for all other testing requirements not specified. 
Install, calibrate, certify, operate, and maintain a CMS to measure the gas scrubber parameters.	
AA-008	HAP	Reduce chloroform air emissions to the atmosphere by compliance with the applicable effluent limitation guidelines and standards specified in 40 CFR 430.		
AA-008	HAP	Each enclosure and closed-vent system shall meet the requirements specified by 40 CFR 63.450.	Conduct, record, and maintain enclosure and closed-vent system inspections.  	
AA-010	H2S	≤ 1 grain per 100 standard cubic feet	No additional monitoring required since NSPS addresses controls and monitoring.	
AA-011	PM	E = 0.8808 * I –0.1667	Maintain daily records of the hours of operation, the amount of fossil fuel fired and actual heat input of fossil fuel (Natural Gas/Propane)
Record monthly a Fossil Fuel Annual Capacity Factor calculated on a 12-month rolling average each calendar quarter.
Record daily the BLS firing rate (tons/day) and calculate a 12-month rolling total.
Potential emissions from firing black liquor are below the State standards for PM and SO2.	
	SO2	4.8 lbs/MMBTU		
	Fuel Restriction	Black liquor is the primary fuel, but natural gas, propane, and diesel fuel can be used as auxiliary fuel.		
	Fuel Restriction	The fossil fuel annual capacity factor shall be 10% or less when combusting natural gas and propane.		
AA-011	Opacity	≤ 35%
Periods of excess emissions shall not exceed 35% for 6% or more of the operating time in any quarterly period.	Install, maintain, operate, and calibrate a COMS to record opacity every successive 10-second period and calculate and record each successive 6-min average.	
AA-011	TRS	5 ppm by volume on a dry basis corrected to 8% oxygen; and periods of excess emissions shall not exceed 1% of the operating time within any quarterly period.	Monitor and record the TRS concentration on a dry basis using a CMS.  	
AA-011	PM (filterable only)	0.044 gr/dscf (0.10 g/dscm) corrected to 8% oxygen.	Stack test biennially with the initial test occurring within 18 months of the permit issuance date.  	
	PM(filterable only)	4 lbs/ton of equivalent air-dried Kraft pulp.		
	SO2	300 ppm corrected to 8% oxygen		
	CO	300 ppm corrected to 8% oxygen (8-hr average)		
	NOX	80 ppm corrected to 8% oxygen (8-hr average)		
	GHG	208.1 lb/MMBTU                                                                    365,318 lb/hr and 1,600,092 TPY	Record fossil fuel and BLS firing rate. The limits are based on the potential fossil fuel and BLS firing rates, as limits by the permit, and the GHG emission factors from the GHG Mandatory Reporting Rule.  Therefore, meeting the fuel throughput limits ensures compliance with the GHG/CO2e limits.	
	CO2e	208.5 lb/MMBTU
365,977 lb/hr and 1,602,979 TPY		
AA-012	SO2	500 ppm	Stack test biennially with the initial test occurring within 18 months of the permit issuance date.  
Monitor and record, at least once per shift, the pressure loss of the gas stream through the control equipment (scrubber) utilizing a CMS. 
Monitor and record, at least once per shift, the scrubbing liquid supply pressure once per operating shift.
Monitor and record the pressure drop and liquid flow rate at least once every successive 15-minute period.	
	H2S	1 grain per 100 standard cubic feet		
	PM (filterable only)	0.2 lbs/ton Black Liquor Solids (dry weight)		
	TRS	0.033 lbs/ton Black Liquor Solids (measured as H2S)		
	SO2	36 ppm in stack gas		
AA-013	SO2	500 ppm	Stack test biennially with initial test occurring within 18 months of permit issuance date.  
Record daily CaO production rate (in tons/day)
To ensure the scrubber is working effectively, monitor and maintain records of the Scrubber Liquid Flow Rate once per shift. Monitor and maintain records of the Scrubber Liquid pH while burning Pet Coke.	
	PM (filterable only)	0.066 gr/dscf  (0.15 g/dscm) corrected to 8% oxygen, when gaseous fossil fuel is burned.
0.13 gr/dscf (0.30 g/dscm) corrected to 10% oxygen, when liquid fossil fuel is burned.		
	Opacity	≤ 20%
Periods of excess emissions shall not exceed 20% for 6% or more of the operating time within any quarterly period.		
	SO2	17.5 lbs/hr and 76.9 TPY		
	NOX	100 lbs/hr and 438 TPY		
	CO	50.0 lbs/hr and 220.0 TPY		
AA-013	TRS	8 ppm corrected to 10% oxygen, not to exceed 2.81 lbs/hr and 12.3 TPY	Monitor and record the TRS concentration on a dry basis using a CMS.  	
AA-013	Fuel Restriction	Natural gas, propane, No. 6 fuel oil, on-site generated used oil, petroleum coke, and tall oil is authorized for use as fuel.  NCGs controlled by the Lime Kiln also have a fuel value.	Maintain records daily of the amount and type of fuel combusted.  Maintain records monthly of the amount of on-site generated used oil burned as fuel on a 12-month rolling total. Perform and maintain an annual chemical analysis of the on-site generated used oil to ensure that it is not a hazardous waste.	
AA-013	Fuel Restriction	Maximum annual fuel usage rate of 10,000 gallons per year of on-site generated used oil.		
AA-013	Control Device	The Lime Kiln shall not operate without the use of the scrubber.	Monitor and maintain records of the Scrubber Liquid Flow Rate once per shift.
Monitor and maintain records of the Scrubber Liquid pH while burning Pet Coke	
AA-015	PM (filterable only)	0.10 lb/MMBTU heat input from fossil fuel and/or wood residue.	Stack test biennially with initial test occurring within 18 months of permit issuance date.  Monitor opacity continuously to demonstrate EPS is operating effectively to control PM.	
	NOX	0.30 lb/MMBTU heat input derived from gaseous fossil fuel, liquid fossil fuel, and wood residue.		
	PM(filterable only)	0.30 gr/dscf		
	SO2	4.8 lbs/MMBTU		
	CO	338.4 lbs/hr		
AA-015	Opacity	≤ 20% except for one 6-minute period per hour of not > 27%.	Install, calibrate, maintain, and operate a CMS to measure and record opacity.  	
AA-015	PM	E = 0.8808 * I –0.1667, when burning fossil fuels	Maintain daily records of the amount(s) and type(s) of fuel combusted.	
	SO2	4.8 lbs/MMBTU		
AA-015	Work Practices 	Work practices provided in Table 3 of Subpart DDDDD 	Conduct an annual tune-up of the unit to demonstrate continuous compliance.	
AA-015	HCl	2.2E-02 lb per MMBtu of heat input 	Conduct applicable performance tests according to 40 CFR 63.7520 on an annual basis or once every three years.	
	Hg	5.7E-06 lb per MMBtu of heat input		
AA-015	CO (or CEMS)	720 ppm by volume on a dry basis corrected to 3% oxygen using 30-day rolling average		
AA-015	Filterable PM (or TSM)	Filterable PM (or TSM) is limited to 3.7E-02 lb per MMBtu of heat input 		
AA-016	SO2	500 ppm	Stack test biennially with the initial test occurring within 18 months of the permit issuance date.  
Monitor and maintain records of the Scrubber Liquid pH & Flow Rate to demonstrate scrubber is working effectively to control SO2.	
	SO2	9.0 lbs/hr and 39.42 tons/year		
	NOX	6.0 lbs/hr and 26.3 tons/year		
	CO	22.0 lbs/hr and 96.36 tons/year		
AA-016	PM	0.2 gr/dscf corrected to 12% CO2	Maintain daily records of the amount(s) and type(s) of fuel combusted.	
	Fuel Restriction	Fuels other than natural gas, propane, or NCGs are prohibited.  NCGs controlled by the Incinerator also have a fuel value.		
AA-016	TRS
	Minimum temperature of 1200 F for at least 0.5 second.	Continuously monitor the temperature to ensure complete combustion.	
		2.1 lbs/hr and 9.2 tons/year		
AA-016	HAP	Control HAPs by using the incinerator (AA-016) where the total HAP concentration at the outlet is reduced to 20 ppm or less by volume, corrected to 10% oxygen on a dry gas basis.	Monitor and record the combustion temperature at the point of incineration of effluent gases.  The monitoring device is to be certified to be accurate within 1 percent of the temperature being measured.	
AA-021	CO	19.3 lbs/hr and 84.5 tons/year	Stack test biennially with the initial test occurring within 18 months of the permit issuance date.  	
	VOC	37.8 lbs/hr and 165.4 tons/year		
AA-023	VOC	8.1 lbs/hr and 35.5 tons/year		
AA-025	HAP	1.	Control HAPs by venting emissions to the lime kiln (AA-013) flame zone by use of a steam injector; or
2.	Control HAPs by using the incinerator (AA-016) where the total HAP concentration at the outlet is reduced to 20 ppm or less by volume, corrected to 10% O2 on a dry gas basis.	Continuously monitor temperature for the incinerator and scrubber liquid flow for the kiln per the MACT requirements.	
AA-025 	HAP	Each enclosure and closed-vent system shall meet the requirements specified by 40 CFR 63.450.	Conduct, record, and maintain enclosure and closed-vent system inspections.  	
AA-028	HAP	Collect a total HAP mass of 11.1 lbs/ton of Oven-Dried Pulp (ODP) from 85% of the total HAP in the condensate streams being collected on a 15-day rolling average to be collected and treated in accordance with 40 CFR 63.446(d) & (e).	Perform testing annually where specified by 40 CFR 63, Subpart S and biennially for all other testing requirements not specified.
If an inspection identifies visible defects in the closed collection system, or if an instrument reading of 500 ppm or greater above background is measured, corrective actions shall be taken. (The Method 21 instrument readings only apply to components on the condensate tank that are or have the potential to operate above the liquid level in the tank. No other components in the closed collection system, other than condensate tanks, must be tested for leaks with Method 21.) 	
AA-028	HAP	Treat a total of at least 10.2 lbs/ton ODP of total HAP on a 15-day rolling average.		
AA-028	HAP	All equipment shall be enclosed with emissions collected and vented to a control device as follows:
1.	Control HAPs by venting emissions to the lime kiln (AA-013) or power boiler (AA-015) flame zone by use of a steam injector; or
2.	Control HAPs by using the incinerator (AA-016) where the total HAP concentration at the outlet is reduced to 20 ppmv or less, corrected to 10% O2 on a dry gas basis.	Install, calibrate, certify, operate, and maintain a CMS to measure foul condensate collection. In a letter to the MDEQ on May 28, 2003, LRC established condensate flow to the steam strippers (AA-041) combined with Mill-specific HAP factors) to comply with the condensate collection requirements. Per 40 CFR 63.446(c) the Mill currently bases collection on a 15-day rolling average lbs/ODTP.	
AA-028	HAP	The pulping process condensates shall be conveyed in a closed collection system as specified in 40 CFR 63.446(d)(1) & (2).	Monitor, inspect, and record each pulping process condensate closed collection system used to comply with 40 CFR 63.446(d).	
AA-036	PM/PM10
Operational Limitation	0.21 lbs/hr and 0.9 TPY
The baghouse must be operated at all times the ground petroleum coke silo is operated.	Perform monthly visible emissions evaluation during unloading operations using EPA Ref. Method 9.
Perform inspections and maintenance each month, or more often as needed, to ensure proper operation of the baghouse is maintained.	
AA-037	PM	0.6 lbs/MMBTU	No monitoring due to large margin of compliance	
	SO2	4.8 lbs/MMBTU		
AA-037  AA-038     	Operating Requirements	Operate emergency stationary RICE for the purpose of maintenance checks and readiness testing, which is limited to 100 hours per year. Emergency RICE can be operated up to 50 hours per year in non-emergency situations, but those 50 hours are counted towards the 100 hours per year provided for maintenance and testing.
There is no time limit on the use of emergency stationary RICE in emergency situations.	Install non-resettable hour meter.  Document hours spent for emergency and non-emergency operation.	
AA-037	Maintenance Requirements	Comply with the following requirements:
1.	Change oil and filter every 500 hours of operation or annually, whichever comes first;
2.	Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;
3.	Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary.
During periods of startup, the permittee shall minimize the engine’s time spent at idle and minimize the engine’s startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30 minutes.	Maintain records of maintenance records that demonstrate engines operated and maintained in accordance with the written plan, and maintain operating hours recorded on non-resettable hour meter.  Document hours spent for emergency and non-emergency operation.	
AA-038	PM/PM10	0.6 lbs/MMBTU	No monitoring due to large margin of compliance	
	Fuel Requirement	15 ppm S	Recordkeeping	
	NMHC+NOx CO                         PM	4.0 g/kW-hr of NMHC+NOx, 3.5 g/kW-hr of CO and 0.2 g/kW-hr of PM.  	Engine certification	
AA-041	HAPs	Maintain a closed collection system	Use a CMS to measure the process waste water feed rate (condensate flow), steam feed rate, and the stripper column feed temperature. These parameters are used to calculate a steam flow to condensate flow ratio. Per 40 CFR 63.446(e) the HAP destruction is based on a 15-day rolling average lbs/ODTP.
If an inspection identifies visible defects in the closed collection system, or if an instrument reading of 500 ppm or greater above background is measured, corrective actions shall be taken. (The Method 21 instrument readings only apply to components on the condensate tank that are or have the potential to operate above the liquid level in the tank. No other components in the closed collection system, other than condensate tanks, must be tested for leaks with Method 21.)  	
AA-042	H2S	≤ 1 grain per 100 standard cubic feet	Monitor and maintain records of the Scrubber Liquid pH & Flow Rate (Pump On/Off).	
AA-043	HAP	Collect a total HAP mass of at least 2.0 lbs/ton ODP from 15% of the total HAP in the condensate streams being collected on a 15-day rolling average.  	Only the oxygen delignification system, atmospheric diffusion washer and associated filtrate tank comply with the HVLC requirements of Subpart S using the Clean Condensate Alternative.
Perform testing annually where specified by 40 CFR 63, Subpart S and biennially for all other testing requirements not specified.	
AA-043	HAP	Treat a total of at least 1.8 lbs/ton ODP of total HAP on a 15-day rolling average.  		

Note:  The previous permit specified most State standards and Federal standards as “PM/PM10” standards.  However, these standards only regulate PM, as determined by EPA Method 5. Therefore, the permit has been revised throughout to reflect this correction and note these limits as “PM (filterable only).”  Any references to Method 201/201A have also been removed.